Electronic Information and Technology Accessibility Procedure

Procedure For: Electronic Information and Technology Accessibility

Policy this Procedure Applies to: Electronic Information and Technology Accessibility Policy

Purpose for this Procedure: This procedure establishes requirements for implementation of the Electronic Information and Technology (EIT) Accessibility Policy. These procedures are to ensure that all EIT will permit all members of the College Community with disabilities to acquire the same information, engage in the same interactions, and enjoy the same services with equivalent ease of use as those without disabilities.

As stated in the EIT Accessibility Policy, all EIT must be accessible to the College Community and follow the College’s accessibility standards.

The Cabinet member responsible for ITS or their designee, working in conjunction with the Web Accessibility Coordinator (WAC) and Vice President of Academic Affairs (VPAA), is responsible for implementation, review and oversight of the EIT Accessibility procedures. The individuals and offices providing the EIT are responsible for maintaining and providing accessible EIT. All information obtained through online content provided or developed by third parties shall be accessible, or an acceptable alternative of equal value will be provided through Assisted Learning Services (ALS).

Definitions:

College Community “includes all HFC Board of Trustees, all faculty, staff, employees, students, prospective students, vendors/contractors, guests and visitors, including visitors to the College’s website”.

Electronic Information and Technology (EIT) is defined in the policy as including “HFC web content, including web pages, media and documents provided on all College websites and official social media platforms, as well as any linked information from 3rd party websites that are not maintained by the College; online learning content, including learning management systems, e-learning tools, and any electronically delivered media, communications and documents”.

Content Editors are all faculty, and staff that create any EIT for use or distribution to the College Community.

Electronic Technology: Electronic Technology (ET) is a sub-category of EIT, which includes computer software, custom applications, learning management systems and e-learning tools. ET it does not include Assistive Technology.

The Web Accessibility Coordinator will evaluate and document any existing ET provided for use by the College Community. If non-compliant ET is discovered, the responsible individuals and offices will be notified, and they must pursue a resolution immediately.

All new ET for the College Community must be determined to be accessible and documented. Sufficient documentation will be to complete a Voluntary Product Accessibility Template (VPAT 2.1), or the HFC Accessibility Checklist, along with a roadmap for meeting accessibility requirements. Both documents need to be submitted during the purchasing process. Each department, school, administrative office, or task force who engages in researching potential applications is responsible for ensuring the ET adheres to the EIT Accessibility Policy.

Electronic Information:
Electronic Information (EI) is a sub-category of EIT that does not include Electronic Technology. EI includes web content, any electronically delivered media, communications and documents, including academic information posted in learning management systems or distributed electronically to students.

If existing EI provided by or linked to any official College websites, or other communication platforms is reported to not comply with the EIT Accessibility Policy, the responsible parties will be notified and must pursue a resolution immediately.

If assistance is required, the Content Editor should seek assistance from the Web Accessibility Coordinator (WAC), E-Learning or their department designee according to established procedures.

The Content Editor is responsible for completing training and ensuring the created EI adheres to the EIT Accessibility Policy prior to implementation or distribution.

Assistive Technology:
Assistive Technology (AT) are products, equipment, and systems that enhance learning, working, and daily living for persons with disabilities (Assistive Technology Industry Association - ATIA).

Assisted Learning Services (ALS) will evaluate all AT and report to the WAC the available assistive technology, accessible technology facilities including labs and classrooms, and procedures for acquiring assistive technology. ALS with the AC will conduct the evaluation and develop a timeline for implementation of additional assistive technology if the evaluation of current resources is found to be insufficient for the needs of the College Community in accordance with the policy.

Designation and Responsibilities of WAC:
The Cabinet member responsible for ITS shall appoint a WAC, whose duties include:

• Providing direction and guidance on the appropriate standards to be followed for accessibility of all EIT utilized by the College.
• Developing, implementing and maintaining compliance standards for EIT accessibility, including communicating this information to the College Community.
• Working with the Office of Academic Affairs to develop a schedule to conduct internal audits of compliance with the EIT Accessibility Policy; if there is evidence of non-compliance, the WAC will identify the problem(s) and assign a reasonable time frame for correction of the problems.
• Responsibility to ensure that reporting requirements and documentation to the Office of Civil Rights are submitted in a timely and complete manner.
• Upon request, the WAC will assist E-Learning to train Content Editors from departments within the College to enable them to create accessible content that complies with the College’s accessibility standards.
• Responsibility to ensure that accessibility complaints are addressed and resolved in a timely manner according to College policies and procedures.

The VPTIS or VPAA may instruct the WAC to disable any EIT found to be in violation of the EIT accessibility standards if the accessibility violation cannot be resolved in a timely and complete manner.

The Web Accessibility Coordinator (WAC) appointed is:
Name: Rachel Ford
Title: Web Accessibility Manager
Contact Information: 313-347-1541 or raford3@hfcc.edu

If there is a change of the WAC, the contact information will be disseminated College wide and available on its public website.

Public Notice of Accessibility Standards:
Posting and publication of standards to be followed for EIT accessibility, including publication on the official College website for ADA accessibility, compliance and accommodation, shall be conducted under the direction of the WAC. The College Community shall be alerted to the posting and publication by the best available means of communication, including email notifications, written correspondence, and/or website notification.

Training:
The Cabinet member responsible for ITS working with the VPAA and/or their designee is responsible to ensure that annual training of the EIT Accessibility Policy and the College’s accessibility standards is conducted for faculty and staff. The Cabinet member responsible for ITS and the VPAA shall select qualified individuals in their areas with sufficient technical knowledge, skill, and experience to conduct the training.

The annual awareness training should educate all College employees to ensure understanding of the EIT Accessibility Policy and procedures. Additional training will be provided for Content Editors responsible for creating or distributing EIT to the College Community. Training will include the requirements, methods, and resources available for developing accessible content, and the roles and responsibilities of Content Editors developing online courses, or other EIT. There will be a three-month timeframe to complete this training. If there are those who do not complete training, a list of names will be given to HR, and HR will work with the supervisors.

Should any Content Editors submit documents that are not accessible, they will be advised of this and given a reasonable time to make the document(s) accessible. If the Content Editor(s) do not resubmit an accessible document(s), the document(s) will not be published or will be deleted. If the document(s) cannot be removed due to other compliance factors, the inaccessibility of the document(s) will be documented and reported to Cabinet.

Additional accessible content creation training is required for all Content Editors providing EIT and should be completed within a reasonable timeframe. Continuous training may be required. Faculty, including adjuncts, should complete such training prior to course start date.

Audit:
Annually, the WAC in coordination with the VPAA will conduct an accessibility audit in the fall and winter semesters to evaluate compliance with the requirements of the EIT Accessibility Policy. If non-compliant EIT is uncovered during the audit, each instance will be documented and communicated to the responsible parties and resolved in a timely and complete manner.

The WAC will compile and archive results from these audits to fulfill reporting requirements.

Complaint Process:
If a College Community member believes that the College is not complying with the EIT Accessibility Policy, they should contact the WAC for corrective action through written correspondence, or through the Accessibility Complaint form which can be found at (https://my.hfcc.edu/forms/accessibility-complaint) which goes directly to the WAC.

Once a complaint is received, the WAC should seek informal resolution by contacting the content editors or responsible parties who should correct the non-compliant EIT or provide an alternative solution. If an informal solution is not enough to resolve the complaint, the complaint should be escalated to a formal complaint following established procedures for complaints at the College.

General Standards for Technical Implementation:

General Standards for Technical Implementation of these Procedures will be developed to bring all EIT within the guidelines set forth in the Rehabilitation Act of 1973 and the Americans with Disabilities Act of 1990. College departments and responsible individuals will work together to conform with and maintain the College’s accessibility standards and to establish time frames to implement any necessary modifications. The General Standards are incorporated by reference into these procedures and may be modified as necessary based on technological or regulatory changes.

This procedure supersedes and replaces any and all procedures related to this subject
Adopted: July 16, 2020

Private: 
Public
Procedure Type: 
Adopted Date: 
Thursday, July 16, 2020
Procedure Name: 
Electronic Information and Technology Accessibility Procedure
Status: 
Department Approved