Information Technology Accessibility Policy

Type of Policy: 
Administrative
Effective Date: 
January 2016
Last Revised: 
January 2016
Review Date: 
January 2019
Policy Owners: 
Office of Compliance
Office of Information Technology
Contact Names: 
Denise Johnson-Marshall, ADA Coordinator, dmarshall@gatech.edu
Lori Sundal, Deputy Chief Information Officer-Service Delivery, lori.sundal@oit.gatech.edu
Reason for Policy: 

The Georgia Institute of Technology (“Institute”) is committed to providing equality of opportunity to persons with disabilities, including equal access to Institute programs, services and activities provided through Information Technology (IT). This policy establishes minimum standards and expectations regarding the design, acquisition or use of Information Technology.

Policy Statement: 
The Institute commits to ensuring equal access to all Institute programs, services and activities provided through Information Technology, whether provided directly by the Institute or by a vendor. As provided in Part VII, below, all Institute offices using vendor-provided Information Technology shall ensure that such IT complies with the Accessibility Standards contained in this policy. Unless an exemption applies, all schools, colleges, departments, offices and entities of the Institute shall adhere to the Institute’s Accessibility Standards, as defined below.
Scope: 

Incorporating principles of universal design in the development, acquisition, and implementation of IT and related resources helps the Institute ensure that these resources (documents, web pages, information, and services) are accessible to the broadest possible audience.

Individual web pages published by students, employees or non-Institute organizations that are hosted by the Institute and which do not conduct Institute-related business are encouraged to adopt the accessibility standards contained in this policy, but fall outside the jurisdiction of this policy.

Definitions:

Information Technology

“Information Technology” means any equipment or interconnected system or subsystem of equipment, that is used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. The term information technology includes computers, ancillary equipment, software, firmware and similar procedures, services (including support services), and related resources, including, but not limited to computers and ancillary equipment, instructional materials, software, videos, multimedia, telecommunications, or web-based content or products developed, procured, maintained, or used in carrying out Institute activities.

Institute Accessibility Standards

“Institute Accessibility Standards” means, at a minimum, the standards of the Web Content Accessibility Guidelines 2.0, Level AA, as created and published by the Web Accessibility Initiative of the World Wide Web Consortium, as well as the requirements of Sections 504 and 508 of the Rehabilitation Act of 1973 and their implementing regulations. “Institute Accessibility Standards” also means, more generally, those generally accepted principles of universal design which helps individuals with disabilities access the services, programs, and academic, extracurricular and research offerings of the Institute.

Legacy Web Pages

Legacy Documents

Legacy Multimedia

“Legacy Web Pages,” “Legacy Documents,” and “Legacy Multimedia”, mean web pages, electronic documents, and multimedia created before January 1, 2013.

Revised Web Page “Revised Web Page” means any web page where a significant alteration or update is made to the visual design of the page or a major revision of the content of the page is made.
Universal Design “Universal Design” means a concept or philosophy for designing and delivering products and services that are usable by people with the widest possible range of functional capabilities, which include products and services that are directly accessible (without requiring assistive technologies) and products and services that are interoperable with assistive technologies.

Applicability:

This policy applies to all IT resources that are acquired, developed, distributed, used, purchased or implemented by or for any Institute unit and used to provide Institute programs, services, or activities, including but not limited to:

1. Web Pages

a. All new web pages and Revised Web Pages, website templates, and website themes must comply with the Institute’s Accessibility Standards.
b. All new and Revised Web Pages must indicate in plain text a method for users having trouble accessing the page to report that inaccessibility.
c. Legacy Pages determined by the publishing department or unit to be of the highest priority in providing Institute services online (core institutional information) shall comply with the Institute’s Accessibility Standards.
d. Unless an exception applies and is appropriately documented, for any Legacy Web Page or any other web page that for any reason does not comply with the Institute’s Accessibility Standards, the Institute will, upon request, convert or render the non-compliant web page so as to meet the Institute’s Accessibility Standards or will provide to the requestor access to the web page’s information in manner that is equally effective as the original page.

2. Electronic Documents

This policy and the Institute Accessibility Standards apply to all electronic documents.

3. Multimedia

This policy and the Institute Accessibility Standards apply to all multimedia.
 

Exemptions:

1. Legacy Web Pages, Legacy Documents, and Legacy Multimedia are not required to comply with Institute’s Accessibility Standards unless

  • specifically requested by an individual with a disability (though units are encouraged to identify and improve the accessibility of Legacy Pages even in the absence of specific requests),
  • significant and substantial revisions to the web pages, documents, or multimedia are undertaken after the creation of the original, or
  • the nature or function of the web page, document, or multimedia is determined by the creating department to be essential to the purpose of the department or program.

2. Undue burden and non-availability may qualify as an exemption from this policy when compliance is not technically possible, or is unreasonably burdensome in that it would require extraordinary measures due to the nature of the IT or would alter the purpose of a web page. The conclusion of undue burden or non-availability is an institutional decision to be made by the Institute’s Office of Compliance Programs in consultation with the affected unit(s) and others with relevant perspective or expertise. Notwithstanding the foregoing, an individual in need of an accommodation to access the program, service or activity shall request the same of the Institute’s ADA Coordinator or IT Accessibility Coordinator.

3. IT resources specific to a research or development process in which no member of the research or development team requires accessibility accommodations may be exempt. In such cases, the lead investigator must document that, upon inquiry, no member of the research or development team identified as requiring an accommodation.
 

Purchasing:

In order to ensure accessibility of IT products, Institute officials responsible for making decisions about which products to procure must consider accessibility as one of the criteria for acquisition. This is especially critical for enterprise-level systems or technologies that affect a large number of students, faculty, and/or staff. Considering accessibility in procurement involves the following steps:

  1. Vendors must be asked to provide information about the accessibility of their products as required by the Institute’s Computer Technology Request (CTR) process.
  2. The information provided by vendors must be valid and measured using a method that is reliable and objective.
  3. Those making procurement decisions must be able to objectively evaluate the accessibility of products and to scrutinize the information provided by vendors.

Assistance with ensuring that appropriate contractual language is included in all IT purchasing documents may be obtained through the Institute’s Purchasing Office.
 

Compliance:

The Institute’s ADA Coordinator is responsible for overseeing compliance with regard to state and federal laws and regulations that prohibit discrimination on the basis of disability and require reasonable accommodation. Questions or concerns regarding compliance with this policy, or complaints of discrimination, should be directed to the ADA Coordinator, who contact information is contained below.

Questions regarding the Institute’s Accessibility Standards, resources, and other technical matters may be addressed to the Institute’s IT Accessibility Coordinator, who contact information is below.

To report an accessibility issue or non-compliance with this policy, please email gtaccessibility@gatech.edu.

Enforcement: 

To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, and read more about the EthicsPoint Portal.

Contacts

Institute ADA Coordinator:

Denise Johnson-Marshall
ADA Coordinator
dmarshall@gatech.edu
(404) 385-5151

IT Accessibility Coordinator:

Lori Sundal
Deputy CIO – IT Service Delivery
lori.sundal@oit.gatech.edu
(404) 894-5348

Assistance with IT Purchasing:

Purchasing Office
purchasing.ask@business.gatech.edu
(404) 894-5000

Policy History: 
Revision Date Author Description
1/15/2016 Compliance Programs and OIT New Policy
     

 

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