Policy on Web Accessibility

I. SCOPE

This Policy Applies to:

  • All organizational units of the College.
  • All new and existing College websites, including those created, designed, or maintained by a vendor.

This policy does not apply to:

  • Archived web content that has not been modified since the effective date of this policy.
  • Individual web pages published by students, employees, or non-College organizations that are hosted by the College and do not conduct College-related business. Individuals and organizations responsible for these pages are encouraged to adopt the College's policy and web standards.

II. POLICY STATEMENT

SUNY Geneseo is committed to providing equality of opportunity to persons with disabilities. In keeping with this commitment, the College requires its web content and functionality to be accessible to everyone, including people with physical, sensory, or cognitive impairments, with or without the use of assistive technology.

III. POLICY

A. Web Standards

  1. All new or modified online content and functionality published or implemented after the effective date of this policy must conform to Web Content Accessibility Guidelines 2.0 Level AA (WCAG 2.0 AA), except where doing so would constitute a fundamental alteration or impose an undue burden as outlined in section III(D). The content accessibility guidelines include (but are not limited to) the following essential standards:
    • Web content must be accessible to users employing screen reader technology. 
    • Alternative text must be provided for visual content when necessary to convey meaning.
    • Website must be navigable by keyboard as an alternative to mouse navigation.
    • Websites must not rely on color alone to convey meaning. 
    • Websites must provide captions and/or transcripts for all audio or video content
  2. Websites, forms, documents, videos, and other online content published prior to the date of the policy must be remediated by [September 15th, 2019].
  3. Archived web content is not required to meet accessibility guidelines. If an individual with an impairment requires an accommodation to access archived content, the college will provide reasonable accommodations. In most cases, this will mean that the content will be provided in an accessible format within three (3) business days.

B. Procurement

  1. All hardware, software, programs, and other information, technology (IT) procured from vendors must be accessible if the IT will be used to access college programs, services, or activities.
    • Any person or unit responsible for the procurement of IT used to access College programs, services, or activities must obtain the following information from vendors:
      1. A description of how the IT product or service is accessible to users, including individuals who use assistive technology; and
      2. A fully-completed Voluntary Product Accessibility Template (VPAT). Any aspect of a product described in a VPAT as out of compliance must be accompanied by an accessibility roadmap detailing how and when the vendor will bring the product to full compliance.

C. Responsibility

  1. President, provost, vice presidents, deans, directors, department heads, managers, and supervisors are responsible for:
    • Ensuring web content in their areas comply with this policy.
    • Ensuring vendor-provided, web-based IT products that facilitate access to programs, services, and activities are accessible by obtaining the required information from vendors in advance of procuring the IT.
  2. Unit website administrators are responsible for:
    • Ensuring that new and updated web pages, forms, documents, videos, and other content on public-facing pages of their unit website conform to WCAG 2.0 AA guidelines.
    • Providing reasonable accommodations to individuals who request access to inaccessible archived web content.
    • Interfacing with third party web service vendors used by their unit to identify and remediate any accessibility concerns and to provide equally effective alternative means of access if accessibility concerns can not be remediated.
  3. Course instructors are responsible for:
    • Ensuring that third party websites or applications which haven't already been vetted by the college and are used in course instruction are accessible by obtaining the required accessibility information from the vendors.
    • Providing timely and effective alternative means of course access and completion if third party webstites and/or applications are inaccessible and cannot be remediated.
  4. The chief information officer is responsible for:
    • Planning for accessibility across all information technology hardware, software, and systems at the college.
  5. The chief diversity officer is responsible for:
    • Investigating complaints and non-compliance with this policy.
    • Considering and ruling on exception of requests.

D. Exceptions

  1. In consultation with the chief information officer, limited exceptions may be granted by the Office od Diversity and Equity in instances where compliance is not possible because one or both of the following conditions apply:
    • Compliance would constitute a fundamental alteration of the nature of the web, content, or service; or
    • Compliance would impose an undue administrative or financial burden.
  2. Organizational units requesting an exception must provide equally effective alternative access to ensure that, to the maximum extent possible, individuals with disabilities have the same access to the program, service or activity as their nondisabled peers.
  3. Organization untits requesting an exception must provide a written statement detailing the following:
    • Reasons for requesting an exception, including the cost of meeting the requirement and available funding and resources.
    • Description of how alternate access will be provided.

E. Complaints

  1. Individuals who believe there is a violation of this policy should contact the Chief Diversity Officer. An individual who files a complaint will be protected against retaliation.