I. General Policy
As part of our commitment to diversity, equity, and inclusion, it is the policy of Rice University that all forms of Digital Information should be provided in a way that is accessible to all members of the Rice community, including those with disabilities.
The purpose of this policy is to provide the required Accessibility Standards for all publicly available web pages created, implemented, or modified after October 31, 2020. Additionally, this policy provides a framework to remediate existing publicly available web pages information in a timely manner.
Other Digital Information (such as internal web pages, Canvas, or applications) should be designed to maximize accessibility, and must meet the requirements of the Americans with Disabilities Act (ADA).
II. Roles and Responsibilities
American’s with Disabilities Act and Section 504 Coordinator (“ADA/504 Coordinator”) is responsible for monitoring compliance with this policy, and coordinating access requests and remediation. The ADA/504 Coordinator is the Director of the Disability Resource Center (https://drc.rice.edu/).
Content Creators and/or Administrators, are any individuals (i.e. faculty, staff, students, and third parties) who generate Digital Information for or on behalf of Rice University. Content Creators and/or Administrators must ensure that Digital Information is created and maintained in conformance with this policy.
Officer of Information Technology is responsible for designating a person(s) (herein referred to as the “Digital Information Accessibility Coordinator”) who will be responsible for providing training and resources to faculty and staff relative to Digital Information accessibility and for coordinating with departments on the implementation of this policy.
Digital Information Accessibility Steering Committee is a university-wide committee appointed by the Executive Compliance Committee; the committee should include, but not be limited to members of the Disability Resource Center, and the Offices of Information Technology, Public Affairs, General Counsel and Compliance. The role of this committee is to guide the implementation of this policy and review requests for exceptions to this policy (as discussed in IV.D). This committee will regularly report to the Executive Compliance Committee.
Public Affairs. Public Affairs will regularly review data related to web traffic and provide specific recommendations to schools or departments on which pages should be remediated and which portions of the page do not meet the Accessibility Standards. Content Creators and/or Administrators should make a good faith effort to remediate these pages in a timely manner.
Accessibility is the degree to which Digital Information and resources can be independently accessed and used by as many people as possible, including individuals with disabilities.
Accessibility Standard. For the purpose of this policy, publicly available web pages must meet the standard set by the Worldwide Web Consortium’s Web Content Accessibility Guidelines version 2.1, Level AA Conformance (WCAG 2.1 Level AA) (“the Standards”). All other Digital information should be designed to maximize accessibility, and must meet the requirements of the Americans with Disabilities Act (ADA).
Digital Information is intended to be construed broadly, to include (but not be limited to) websites, web-applications, electronic course materials and documents, multimedia (e.g. audio and video), blogs, software applications, and other digitally available information and communication technologies that are created or used by faculty, staff, or students at Rice University.
IV. Elaboration of Policy
A. New Publicly Available Websites or Web Pages
Publicly available websites or web pages created or implemented by Rice University after October 31, 2020 must meet the Accessibility Standards prior to being made available to the Rice community or the public.
Additionally, if a publicly available websites or webpages are substantially modified, they should be treated as “new” and modifications should include whatever is necessary to bring it to the level of the Accessibility Standards. For example, a “substantial modification” to a web page includes redesigning the layout or adding new subpages or features, but generally does not include updates to text or other minor edits.
B. Existing Publicly Available Websites or Web Pages
Content Creators and/or Administrators responsible for existing Digital Information should perform a periodic review of such Digital Information that is being used by or made available to the Rice community, and then make a good faith effort to bring it to a level where it meets the Accessibility Standards. Priority should be given to websites or web pages or other applications that receive the most traffic or that contain information that may impact the success, health, or compliance with Rice policies of faculty, staff, or students (e.g. a department’s homepage, procedural guidance, required lecture material, etc.).
Priority will also be given when a specific request for remediation has been made (See IV.F below).
C. Publicly Available Website Review and Remediation
Public Affairs may designate any website or web page as a “High Priority.” High Priority websites or web pages must be remediated as soon as possible (generally within 30 to 60 days after notice is given by Public Affairs, or within a timeline approved by the ADA/504 Coordinator).
If notice has been given, and a website or web page not been remediated after 60 days, the matter will be referred to the dean or senior leader responsible for that web page and the Chief Compliance Officer. High Priority websites and webpages that have not been remediated after 120 days may be taken offline (after notice has been given) and a fine issued to the responsible department.
D. Request for an Exception to this Policy
In those cases where the Accessibility Standards cannot be met, either because it is not technically feasible or because due to special circumstances meeting the Standard would require extraordinary measures, a request for an exception to this policy may be made to the Digital Information Accessibility Steering Committee. The request is made by email to firstname.lastname@example.org, and must include the following information:
The Committee will issue a written determination (generally within 10 business days). An appeal of the Committee’s decision may be made to the Vice President for International Operations and Information Technology.
The web address and a description of the page or application
The specific reason that the Accessibility Standards cannot be met.
The plan to make the content and functionality available to users upon request in an equally effective and accessible alternative manner
E. Procurement of Electronic Systems, Online Services, and Web-Applications
When contracting with vendors or third parties for information and communication technology, accessibility requirements must be addressed. Contracts for such services, software, or applications must include a clause that requires compliance with the American with Disabilities Act, and if the content is publicly available then it must meet the Accessibility Standards or their equivalent.
OIT will include accessibility as part of the technical review for application or software that will be integrated into Rice networks.
F. Request for Assistance or Information, Complaints, and Accommodation
Individuals in the Rice community or the public may request assistance, request information, or make a complaint related to accessibility by emailing email@example.com.
Individuals who need an accommodation should contact the ADA/504 Coordinator and follow Policy 402, Access and Accommodation for Individuals with Disabilities.
If an individual makes a specific request for information or makes a complaint because information on a particular web page is not accessible to them due to a disability, the matter will be coordinated by the ADA/504 Coordinator. When such a request is made, the Content Creator and/or Administrator is responsible for either 1) remediating the web page or application in a timely manner, or 2) providing the information in an equally effective alternate format. This should generally be completed within 30 days (unless the ADA/504 Coordinator approves a longer timeframe due to technical limitations or special circumstances).
V. Cross References to Related Policies
Policy 808. Protection of University Data and Information
Policy 832. Appropriate Use of Information Technology
VI. Responsible Official and Key Offices to Contact Regarding the Policy and its Implementation
Responsible Official: Vice President for International Operations and Information Technology
Other Key Offices: Disability Resource Center; Information Technology; Public Affairs
VII. Procedures and Forms
For forms, training, procurement clause templates, and other resources, please see https://www.rice.edu/web-accessibility
If you have questions or concerns, or would like to notify the ADA/504 Coordinator about a web page or application that does not meet the Accessibility Standard, please email firstname.lastname@example.org.
David W. Leebron, President
August 31, 2020