Web Accessibility Policy

Purpose

In keeping with the University of Dayton’s commitment to the dignity of every person, this policy memorializes the University’s commitment to ensuring that information provided through the University’s websites is accessible to students, prospective students, faculty, staff, guests, and visitors with disabilities.

Scope

University students, prospective students, faculty, staff, visitors, guests, and vendors/suppliers.

Policy History

Effective Date:  June 3, 2019

Approval:  June 3, 2019

Policy History: 

• Approved in Original Form:  June 3, 2019

Maintenance of Policy:  University of Dayton Information Technology (UDit)

Definitions

(a)  Accessibility – for purposes of this policy means that a person with a disability is afforded the opportunity to acquire the same information, engage in equivalent interactions, and enjoy the same services as a person without a disability in an equally effective manner, with substantially equivalent ease of use.  Although this might not result in identical ease of use compared to that of persons without disabilities, it still must ensure equal opportunity to the educational benefits and opportunities afforded by University websites and equal treatment in the use of such websites.

(b)  Content Management System – refers to the approved, templated content management system the University uses for publishing online content on behalf of the University.

(c)  Content contributors ­­─ are individuals who have been trained in the use of the University’s content management systems and web style guidelines and standards and have been granted access by WebMAT (or persons authorized to grant access to University resources) to create and edit but not publish Website content.

(d)  Content managers ─ are individuals who have been trained in the use of the University’s content management systems and web style guidelines and standards and have been granted access by WebMAT (or persons authorized to grant access to University resources) to create, edit and publish Website content.

(e)  Equally effective ─ for purposes of this policy refers to web content that was developed and published prior to the effective date of this policy.

(f)  Legacy content ─ for purposes of this policy refers to web content that was developed and published prior to the effective date of this policy.

(g)  Technical standard ─ for purposes of this policy refers to the standard the University uses to determine the accessibility of online content.  Unless a different standard is listed in the Appendix to this policy, the Technical Standard is the set of standards established in the World Wide Web Consortium (W3C) Web Content Accessibility Guidelines document, version 2.0 (WCAG).

(h)  Web Management and Advisory Team (WebMAT) ─ refers to the University’s digital content governance group, which provides support to content contributors, content managers and units to assist in compliance with the University's web strategy and this policy.

(i)  Website (sometimes referred to as “University’s website(s)”) ─ for purposes of this policy refers to the collection of webpages that the University of Dayton or University units make available online for purposes of conducting official University business, using the University’s content management system.  “Website” for purposes of this policy does not include unofficial or non-University websites published by University employees, students or by any organization not sponsored or controlled by the University.

Policy

In fulfillment of its nondiscrimination obligations under Section 504 of the Rehabilitation Act of 1973, as amended, and its implementing regulations at 34 C.F.R. Part 104, the University has developed this policy to help ensure that individuals with disabilities are able to acquire information and perform online tasks through the use of the University’s websites.  The University is committed to ensuring that information provided through University websites is accessible to students, prospective students, faculty, staff, guests, and visitors with disabilities, in as effective a manner as such information is accessible to individuals without disabilities.  All University personnel who are involved in the preparation, maintenance and/or procurement of University websites and web-based applications are expected to adopt the University’s commitment to web accessibility, with the assistance of campus resources dedicated to supporting web accessibility.

Accessibility Standard

University websites published after the effective date of this policy, and information provided through its websites after the effective date of this policy, should conform to the University’s technical standard. 

The University will assess legacy content on a periodic basis to determine compliance with the technical standard.  The University will modify legacy content on a prioritized basis.  Individuals can request that legacy content be made available when content is inaccessible using the Request procedures set forth in the Appendix.  Priority will be given to such requests on a first-come first-served basis.

Website Accessibility Coordinator

The University of Dayton has designated a Website Accessibility Coordinator to coordinate and implement this policy.  The Website Accessibility Coordinator’s responsibilities and authority include but are not limited to:

• Serving as a resource for content contributors, content managers and other University constituents regarding how to create and manage web content in compliance with this policy;
• Development, implementation and oversight of annual training for content managers and content contributors regarding the requirements of this policy and their roles and responsibilities for ensuring that web design, documents and multimedia content are accessible;
• Development and implementation of a plan to regularly audit (with appropriate documentation) University websites and information accessible through University websites for adherence to this policy (each such audit known as a “web accessibility audit”);
• Evaluation and remediation, within a reasonable period of time, of any issues identified in a web accessibility audit;
• Evaluation, management and determination of exceptions to the accessibility standards in this policy (in consultation with WebMAT, if and when appropriate);
• Authorization to request corrective action by a University unit (and responsible content manager) for webpages that are not in compliance with this policy;
• When warranted (i.e., unjustified refusal to take or prolonged delay in implementing corrective action as requested, or non-compliant content on a particularly well-traveled or prominent webpage), the authority to unpublish webpages that are not in compliance with this policy;
• Note that WebMAT, University Marketing & Communications, and UDit also have this authority.
• Regular monitoring of best practices for web accessibility, including what technical standard the University should adopt for purposes of fulfilling its commitment to accessibility;
• Authorization to recommend to WebMAT that a content contributor’s or manager’s rights be revoked, for repeated violations of this policy;
• Any other authorization necessary to implement this policy.

The identity of and contact information for the Website Accessibility Coordinator is listed in the Appendix of this policy. 

Request and Complaint Procedures

In furtherance of its commitment to accessibility, the University has established procedures for students, prospective students, faculty, staff, guests, and visitors with disabilities who encounter a barrier related to University web content to seek technical assistance, to file a complaint, to request accommodations, and/or to request access to legacy content.  These procedures are set forth in the Appendix.

Procurement Procedures

In furtherance of its commitment to accessibility, the University has established procedures to help ensure that information provided through its website that is developed by third party providers is accessible.  This procedure is set forth in the Appendix to this policy.  University personnel in UDit, Procurement & Payable Services, the Office of Legal Affairs, Marketing & Communications, and any other individuals involved in securing third-party web content or services on behalf of the University should be familiar with these procedures and incorporate them into their work when applicable.    

Monitoring

Under the oversight of the Website Accessibility Coordinator, the University will conduct accessibility audits at regular intervals to determine the extent to which its websites (and information provided through its websites) complies with the technical standard.  Any problems identified through such audits will be documented, evaluated and, if necessary, a plan developed for remediation within a reasonable period of time. 

Exceptions

In certain circumstances, exceptions to this policy may be granted.  This policy does not require adherence to the technical standard when compliance is not possible, would constitute an undue administrative burden, would result in a fundamental alteration or would otherwise require extraordinary measures.  Individual content contributors or content managers may request exceptions to this policy by contacting the Website Accessibility Coordinator and making such a request in writing, being sure to include the justification(s) for the exception and also indicating how content might otherwise be available upon request.  Requests for exceptions will be considered on a case-by-case basis by the Website Accessibility Coordinator in consultation with WebMAT, if and when appropriate.  Requests will be granted or denied in writing.

Reference Documents

1. Appendix A:  Procedures
2. University of Dayton Nondiscrimination & Anti-Harrassment Policy
3. Section 504 of the Rehabilitation Act of 1973, as amended
4. 34 C.F.R. Part 104