Web Accessibility Standards - Cornell University

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CORNELL UNIVERSITYPOLICY LIBRARYWeb Accessibility StandardsPOLICY 5.12Volume: 5, Information TechnologyChapter: 12, Web AccessibilityResponsible Executive: VicePresident for InformationTechnology and Chief InformationOfficerResponsible Office: CornellInformation TechnologiesOriginally Issued: October 12, 2018Last Full Review: May 2, 2019Last Updated: May 2, 2019POLICY STATEMENTCornell University is committed to providing an environment in which all peoplehave an equal opportunity to participate in the university’s programs, activities, andservices. To support this environment, all new, newly added or redesigned universityweb content, web pages, web functionality, websites, and web applications must bemade accessible to people with disabilities to the standard prescribed by the WebContent Accessibility Guidelines (WCAG) 2.0 Level AA, except where doing sowould result in a fundamental alteration in the nature of a service, program, oractivity or in undue financial and administrative burdens.When fundamental alteration or undue burden applies, equally effective alternativemeans of access must be provided so that, to the maximum extent possible,individuals with disabilities receive the same benefits and services.REASON FOR POLICYCornell recognizes that websites and web-based applications are often integral to theacademic and administrative work of the university. The university strives to ensurethat people with disabilities are able to acquire the same information, engage in thesame interactions, and enjoy the same benefits and services within the sametimeframe as their nondisabled peers, with substantially equivalent ease of use; thatthey are not excluded from participation in, denied the benefits of, or otherwisesubjected to discrimination in any university programs, services, and activitiesdelivered online, and that they receive effective communication of the university’sprograms, services, and activities delivered online.Additionally, the university strives to comply with federal and state laws andregulations requiring accessibility and equal access for individuals with disabilities,including the Americans with Disabilities Act (ADA), Section 504 of theRehabilitation Act of 1973, the New York State Human Rights Law, and Section 1557of the Affordable Care Act.ENTITIES AFFECTED BY THIS POLICY Ithaca-based locations Cornell Tech campus Weill Cornell Medicine campuses1University Policy Officewww.policy.cornell.edu

Cornell Policy LibraryVolume: 5, InformationTechnologiesResponsible Executive: VicePresident for InformationTechnology and ChiefInformation OfficerResponsible Office:CornellInformation TechnologiesOriginally Issued: October 12,2018Last Full Review: May 2, 2019Last Updated: May 2, 2019POLICY 5.12Web Accessibility StandardsWHO SHOULD READ THIS POLICY‒ Anyone who is creating, editing, or placing content on a Cornell Universitywebsite or web application‒ Anyone purchasing web products and web services‒ Unit headsMOST CURRENT VERSION OF THIS POLICY‒ ity-standards2University Policy Officewww.policy.cornell.edu

Cornell Policy LibraryVolume: 5, InformationTechnologiesResponsible Executive: VicePresident for InformationTechnology and ChiefInformation OfficerResponsible Office:CornellInformation TechnologiesOriginally Issued: October 12,2018Last Full Review: May 2, 2019Last Updated: May 2, 2019POLICY 5.12Web Accessibility StandardsCONTENTS0BPolicy StatementReason for PolicyEntities Affected by this PolicyWho Should Read this PolicyMost Current Version of this PolicyContentsRelated plesIntroduction 9Scope of this Policy 9Role of the EITA Coordinator 9ProceduresRequired Website Footer Information 10Procuring Accessible IT 10Addressing Concerns 10Alternative Access 10Training 1111122345679103University Policy Officewww.policy.cornell.edu

Cornell Policy LibraryVolume: 5, InformationTechnologiesResponsible Executive: VicePresident for InformationTechnology and ChiefInformation OfficerResponsible Office:CornellInformation TechnologiesOriginally Issued: October 12,2018Last Full Review: May 2, 2019Last Updated: May 2, 2019POLICY 5.12Web Accessibility StandardsRELATED RESOURCESExternal DocumentationAmericans with Disabilities Act of 1990Section 504 of the Rehabilitation Act of 1973Section 1557 of the Affordable Care ActWCAG 2.0 Level AA Guidelines published by the Web Accessibility Initiative of the World Wide WebConsortiumUniversity Forms and SystemsIthaca-Based LocationsWeill Cornell Medicine CampusesAccessibility InformationWeill Accessibility Information (Login required)Accessibility ResourcesWeill’s Siteimprove Resource (Login required)Siteimprove4University Policy Officewww.policy.cornell.edu

Cornell Policy LibraryVolume: 5, InformationTechnologiesResponsible Executive: VicePresident for InformationTechnology and ChiefInformation OfficerResponsible Office:CornellInformation TechnologiesOriginally Issued: October 12,2018Last Full Review: May 2, 2019Last Updated: May 2, 2019POLICY 5.12Web Accessibility StandardsCONTACTSDirect any general questions about this policy to your college or unit administrativeoffice. If you have questions about specific issues, contact the following offices.SubjectContactTelephoneEmail/Web AddressPolicy Clarification andInterpretation,Accommodation Requests(Ithaca Campus andCornell Tech)CIT - Electronic InformationTechnology Accessibility (EITA)CoordinatorPolicy Clarification andInterpretation,Accommodation Requests(WCM Campus)Associate Director, IT Experience(212) 746-6819accessibility@med.cornell.eduProcurement ProcessClarifications (IthacaCampus and Cornell Tech)Procurement and PaymentServices(607) 255-3804www.dfa.cornell.edu/procurementProcurement ProcessClarifications (WCMCampus)Weill Cornell Medicine .cornell.edu5University Policy Officewww.policy.cornell.edu

Cornell Policy LibraryVolume: 5, InformationTechnologiesResponsible Executive: VicePresident for InformationTechnology and ChiefInformation OfficerResponsible Office:CornellInformation TechnologiesOriginally Issued: October 12,2018Last Full Review: May 2, 2019Last Updated: May 2, 2019POLICY 5.12Web Accessibility StandardsDEFINITIONSThese definitions apply to terms as they are used in this policy.AccessibleWhen a person with a disability is afforded the opportunity to acquirethe same information, engage in the same interactions, and enjoy thesame services as a person without a disability in an equally effectiveand equally integrated manner, within the same timeframes, and withsubstantially equivalent ease of use. If content and functionalitycannot reasonably be made accessible through the website, equallyeffective alternate access must be provided in an expedient manner.University Web page, Websiteor Web ApplicationAny web page, website, or web application created or procured by aunit for or in support of the activities carried out under the auspices ofthe university.UnitA college, department, program, office, research center, institute,laboratory, business service center, or other university unit.WCAG 2.0 Level AAThe Web Content Accessibility Guidelines, version 2.0, Level AA,which is a standard promulgated by the World Wide Web Consortium(W3C) Web Accessibility Initiative (WAI).Web ContentThe information contained on a web page or presented through a webapplication, including text, images, PDFs, video, audio, and code ormarkup that defines structure, presentation, etc.Web FunctionalityAn interactive part of a web page, website or web application.Including, but not limited to, maps, photo galleries, video galleries,online forms, etc.6University Policy Officewww.policy.cornell.edu

Cornell Policy LibraryVolume: 5, InformationTechnologiesResponsible Executive: VicePresident for InformationTechnology and ChiefInformation OfficerResponsible Office:CornellInformation TechnologiesOriginally Issued: October 12,2018Last Full Review: May 2, 2019Last Updated: May 2, 2019POLICY 5.12Web Accessibility StandardsRESPONSIBILITIESThe major responsibilities each party has in connection with this policy are asfollows:Cornell InformationTechnologies, IthacaCampus, Cornell Tech, andWCMProvide documentation and resources to assist with web accessibilitycompliance.Identify both enterprise solution services and open-source services thatenable the scanning of web pages for compliance with the standard setby this policy.Consult with units, as appropriate.Advise and support the EITA coordinator, as appropriate.Electronic InformationTechnology Accessibility(EITA) CoordinatorFacilitate requests for accommodations and complaints of EITAviolations.Coordinate a method to address modified compliance requests, asappropriate.Record any modified compliance requests and their outcomes.Provide guidance to offices and individuals.Consult with units and Procurement on web accessibility.Provide training and/or coordinate on web accessibility.Act as liaison for the IT Governance Committee.At least annually, perform a review of this policy and implement anynecessary revisions.ITGCWith advice from the EITA coordinator, address requests for modifiedcompliance.Staff Member in College orUnitEnsure that all new Cornell University websites and web applications,including content or functionality added to existing Cornell Universitywebsites or web applications, are accessible to the standards set in thispolicy, and are monitored and maintained in an accessible state.Student Disability Servicesand the Department ofInclusion and WorkforceDiversityCollaborate with the EITA coordinator to resolve complaints about webaccessibility, including:Unit HeadAssume responsibility for the web accessibility of all new, newly added,or redesigned university web content, web pages, web functionality,websites, and web applications within the unit.Identification of effective alternatives and reasonable accommodations.Addressing modified compliance requests.Understand web accessibility compliance requirements set by this policy.Identify a unit web accessibility liaison.Unit Web AccessibilityLiaisonAct as the unit point of contact for any web accessibility resources,concerns, or issues.Partner and share information as needed with the Cornell EITAcoordinator.Within the respective unit, ensure that all persons developing, designing,or creating Cornell University web content, web pages, web functionality,websites and/or web applications receive information on accessibilitytraining and information on how to test and review their work.At least annually, review all respective unit websites with universityapproved tools, and examine reports to ensure compliance with thispolicy.7University Policy Officewww.policy.cornell.edu

Cornell Policy LibraryVolume: 5, InformationTechnologiesResponsible Executive: VicePresident for InformationTechnology and ChiefInformation OfficerResponsible Office:CornellInformation TechnologiesOriginally Issued: October 12,2018Last Full Review: May 2, 2019Last Updated: May 2, 2019POLICY 5.12Web Accessibility StandardsRESPONSIBILITIESUniversity ProcurementInclude the appropriate university web accessibility standards andrequirements in procurement agreements.8University Policy Officewww.policy.cornell.edu

Cornell Policy LibraryVolume: 5, InformationTechnologiesResponsible Executive: VicePresident for InformationTechnology and ChiefInformation OfficerResponsible Office:CornellInformation TechnologiesOriginally Issued: October 12,2018Last Full Review: May 2, 2019Last Updated: May 2, 2019POLICY 5.12Web Accessibility StandardsPRINCIPLESIntroductionCornell University is dedicated to providing an inclusive environment forindividuals with disabilities. In keeping with this principle, Cornell has adopted theWCAG 2.0 Level AA standards for all new, newly added, or redesigned universityweb content, web pages, web functionality, websites, and web applications (seeRelated Resources). Furthermore, the university will strive to purchase only thoseweb products and services that operate in accordance with the WCAG 2.0 Level AAstandard. Individuals seeking assistance or having difficulty with websiteaccessibility should contact the EITA coordinator for assistance.Scope of this PolicyAll new, newly added or redesigned university web content, web pages, webfunctionality, websites and web applications published or procured by any unit arecovered by this policy.Role of the EITACoordinatorThe Electronic Information Technology Accessibility (EITA) coordinator has theauthority to report any EITA issue to the IT Governance Committee, for reasonsrelated to this policy, when necessary.Additional responsibilities include, but are not limited to, the following: Developing and implementing outreach and training on principles, tools, andtechniques for members of the university community who maintain websitesand web applications or use the web to deliver instructional materials. Being actively involved in the procurement process for websites and webapplications, to help ensure that accessibility requirements are made part ofcontractual agreements and contractors fulfill their obligations to deliveraccessible websites and web applications. Leading accessibility reviews of key institutional websites and webapplications. Developing and maintaining a web accessibility website or a robust resourcesection under the Cornell accessibility website. Organizing and responding to requests for assistance from site users to makewebsite or web application content accessible. Facilitating review of modified compliance requests.9University Policy Officewww.policy.cornell.edu

Cornell Policy LibraryVolume: 5, InformationTechnologiesResponsible Executive: VicePresident for InformationTechnology and ChiefInformation OfficerResponsible Office:CornellInformation TechnologiesOriginally Issued: October 12,2018Last Full Review: May 2, 2019Last Updated: May 2, 2019POLICY 5.12Web Accessibility StandardsPROCEDURESRequired WebsiteFooter InformationEach university website and web application, including legacy pages, must provide auser-friendly way for individuals to request assistance with accessibility issues.Examples of acceptable footer language are below.Web Accessibility Assistance LinkThis is a link in the footer that goes to a page on their website explaining who tocontact (the email address) and possibly the full text:Cornell University is committed to making its websites accessible to everyone,including individuals with disabilities. To report a problem or to request anaccommodation to access online materials, information, resources, and/or services,please contact web-accessibility@cornell.edu. In your message, include the websiteaddress or URL and the specific problems you have encountered. You will receive areply as soon as possible.Text in the FooterIf you have a disability and are having trouble accessing information on this websiteor need materials in an alternate format, contact web-accessibility@cornell.edu forassistance.Procuring AccessibleITThe university strives to ensure that university web pages, web content, webfunctionality, websites, and web applications purchased by, or used at the universityare accessible to all faculty, students, and staff members, including those withdisabilities. To reach this goal, those responsible for making decisions about whichproducts or services to procure must consider accessibility as one of the criteria foracquisition. This is especially critical for enterprise-level web applications and otherkey websites that affect a large number of students, faculty, patients, or staffmembers. For more information contact Procurement Services.Addressing ConcernsDirect any concerns regarding accessibility of university web pages, websites, or webapplications to the EITA coordinator for prompt resolution.Alternative AccessIf you believe compliance with Web Content Accessibility Guidelines (WCAG) 2.0Level AA would result in a fundamental alteration in the nature of a service,program, or activity or in undue financial and administrative burdens due to thenature of the information and/or the intent of the web page, you may submit awritten request for consideration to the EITA coordinator, who will, in consultationwith the IT Governance Committee, work with you to address your concerns.10University Policy Officewww.policy.cornell.edu

Cornell Policy LibraryVolume: 5, InformationTechnologiesResponsible Executive: VicePresident for InformationTechnology and ChiefInformation OfficerResponsible Office:CornellInformation TechnologiesOriginally Issued: October 12,2018Last Full Review: May 2, 2019Last Updated: May 2, 2019POLICY 5.12Web Accessibility StandardsPROCEDURES, continuedRequests for consideration must be as narrowly tailored as possible, be based onissues other than cost alone, and must include information regarding equallyeffective alternative means of access that would be provided so that, to the maximumextent possible, individuals with disabilities receive the benefits and services beingprovided.TrainingCourses on web accessibility and other resources can be found in CULearn and/orunder the IT@Cornell website.11University Policy Officewww.policy.cornell.edu

web content, web pages, web functionality, websites, and web applications must be made accessible to people with disabilities to the standard prescribed by the Web Content Accessibility Guidelines (WCAG) 2.0 Level AA, except where doing so would result in a fundamental alteration in the nature of a service, program, or

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