This discusses the basic issues and assumptions that the Subcommittee on Policies and Procedures will make when we write the Policy on Web Accessibility. It is important to realize that this policy, like the Security Policy is one of physical access. It does not govern conceptual content in any way.
This policy delineates the functional requirements for all web sites that are used to advertise or announce University related activities, provide or collect University related information, support campus services, train staff or teach students. In short, any web site that provides university or university related services must meet the requirements set down in this policy. The policy will not specify how these requirement are to be met, that will be described in a companion implementation document.
Here is an example of a rule that could be found in the document.
Policy Rule: Any information that is made available to one group of qualified individuals on a 24/7 basis shall be available on a 24/7 basis to all qualified individuals who require that information.
Implementation may admit more than one choice:
(1) The site developer creates XHTML 1.0 Strict markup that satisfies the Web Content Accessibility Guidelines 1.0 at conformance level Triple-A.
(2) The site manager provides 24/7 phone operator service to provide the information from the site for qualified individuals with print disabilities.
The policy doesn't care how a functionality requirement is met, a well coded web site is one way but 24/7 employee service could also do the job.
The implementation document will care about the "how question". Keeping information operators on duty 24/7 for each web site to provide information for individuals with print disabilities will probably cost too much. Programming the site correctly will probably be more cost effective.
The policy does not constrain the semantics of any web document. So, issues like academic freedom and intellectual property are not considered in this policy. This policy only governs functional behavior.
This policy will govern functionality for the web presence of any official University entity that possesses a web presence. These entities include administrative units, academic units, or auxiliary organizations. Academic personnel, staff and students are also included in this list whenever they possess a public web presence that contains information needed for participation in some university related activity. Specifically, all faculty web sites or documents referenced from faculty web sites must be accessible if they are used for instructionally related activities. The policy will govern any proprietary file formats and active contents that are referenced by web sites of official campus entities. Such file formats must meet all the functionality requirements expected of a simple web site.
Procurement of any product that generates web content for public use used by any official university entity shall only be permitted for products that generate web content satisfying the functional requirements of this policy. Procurement includes purchasing and free acquisitions.
The policy will set reasonable guidelines for a transition from our current environment to a fully accessible web environment. This will be done in consultation with representatives of several stake holders.
The policy will ultimately set deadlines for compliance and define a minimum review cycle. It will also define the campus agents responsible for each level of accessibility and review together with their responsibilities.
The policy shall define a set of consequences for campus agents who do not comply with the functional requirements. Ultimately sites that do not comply will be denied access to campus web servers. Off campus web sites that represent official campus entities will also be required to meet campus accessibility rules. Ultimately, official campus entities who ignore accessibility standards may lose their official standing on campus and all rights an privileges pertaining to that status.
Section 504, called the Disability Bill of Rights, is the section of the 1973 Rehabilitation Act that establishes equal access for individuals with disabilities to the services and facilities of organizations that receive federal funding. This law states that an individual who is otherwise qualified to use a service of and organization receiving federal funding shall not be denied service based on disability, and that such an organization must make reasonable accommodations to remove barriers to such an individual's participation in the organization. Although there is a qualification that states an organization may be exempt from providing accommodation based on a claim of undue hardship, organizations rarely win law suits based on the claim of undue hardship.
The Americans with Disabilities Act (ADA) extends Section 504 to organizations that do not receive federal funding. The ADA does have some less stringent requirements for organizations that receive no federal funding. The rule of thumb is this, if ADA requires it and you get any federal money, then 504 covers it, but 504 covers more. Both ADA and 504 apply fully to public comprehensive universities in the US.
Section 508 of the Rehabilitation Act specifically describes accessibility requirements for electronic information technology. Section 508 simply delineates what accommodation means in the context of IT accessibility. Section 508 is corollary to Section 504.
The World Wide Web Consortium (W3C) is composed of 400 business, governmental and non-governmental organizations. It has established consensus guidelines to govern web communications. These govern the organization and behavior of web languages, protocols, user agents and authoring tools. Their acceptance has been so universal that they are now referred to as standards.
These standards include, web accessibility guidelines as well as language, program interface and architectural technical specifications. The specific standards that relate to accessibility for individuals with disabilities are the Web Content Accessibility Guidelines, the Authoring Tools Accessibility Guidelines and the User Agent Accessibility Guidelines. The technical guidelines most relevant to this policy are those relating to the interoperability of content.
The committee will conduct an accessibility gap analysis. We will start with the results from our previous audits, and our response to those findings. From there we will perform a division by division analysis of accessibility. This will be done in collaboration with the Human Factors Subcommittee. We suggest soliciting the help of the campus internal auditor.
The committee is also conducting a survey of existing policies, laws, guidelines and standards. We will take as a minimum the W3C guidelines for content, user agents and authoring tools, as they apply to the functionality required by web technologies on this campus. Whenever there is a difference in requirement between W3C, Section 504, Section 508 or the ADA we will always choose the strictest interpretation.
The studies above will be conducted in parallel so that the subcommittee can complete a first draft by June 5, 2006. This should give the full Campus Information Technology Committee time to review and edit the policy so it can be sent to the, Campus Goals Committee, the Staff Council, the Senate Executive Committee and the President for approval prior to the start of classes in Fall of 2006.