Policy 7.2 Electronic Information Resources Accessibility
SCOPE: FACULTY, STAFF, STUDENTS, AND GUESTS
1. POLICY STATEMENTS
Lamar Institute of Technology (LIT) strives to provide everyone equal access. The use of electronic and information resources (EIR) supports the overall operation and mission of LIT. Ensuring these resources are accessible is required by state and federal laws.
2. GENERAL GUIDELINES AND PRINCIPLES
2.1. Applicability
2.1.1. This policy applies to EIR products and services (including web pages) developed, procured, or materially changed by an LIT employee or third party acting as an agent of or on behalf of LIT, through a procured services contract, or through hosted or managed service contracts.
2.1.2. This policy does not apply to the following:
2.1.2.1. EIR that have been exempted by the Texas Department of Information Resources (DIR). A list of exempt EIR are posted under the Accessibility section of the Texas DIR website.
2.1.2.2. Products that contain embedded information resources that are used as an integral part of the product, but the principal function of which is not the acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of information, including thermostats or temperature control devices or other heating, ventilation, and air conditioning equipment.
2.1.2.3. Medical equipment in which EIR is integral to its operation.
2.1.3. Some of all of this policy may not apply to EIR that have received an exception pursuant to the exception process referenced in this policy.
2.2. Roles and Responsibilities
2.2.1. Institution of Higher Education President – The LIT President has the following responsibilities, which may be delegated unless otherwise indicated:
2.2.1.1. Designate an EIR Accessibility Coordinator.
2.2.1.2. Inform the Texas DIR within 30 days whenever the EIR Accessibility Coordinator position is vacant, or a new/replacement EIR Accessibility Coordinator is designated.
2.2.1.3. Approve exception requests, following the process described in this policy. This responsibility may not be delegated.
2.2.1.4. Ensure appropriate staff receives training necessary to meet EIR accessibility-related requirements.
2.2.2. EIR Accessibility Coordinator (EIRAC) – The Director of Information Technology is LIT’s EIRAC. The EIRAC is the central point of contact concerning accessibility issues and solutions for LIT’s EIR. The EIRAC serves in a coordinating and facilitating role, with responsibilities that include the following:
2.2.2.1. Develop, support, and maintain EIR accessibility policies, standards, and procedures.
2.2.2.2. Facilitate a response to concerns, complaints, reported issues, and Texas DIR surveys.
2.2.2.3. Process EIR accessibility exception requests and maintain records of approved exceptions.
2.2.2.4. Develop and support a plan by which EIR (including websites) will be brought into compliance. The plan shall include a process for corrective actions to remediate non-compliant items.
2.2.2.5. Establish goals for making its EIR accessible, which includes progress measurements towards meeting those goals.
2.2.2.6. Maintain a listing of LIT’s Key Public Entry Points.
2.2.2.7. Provide or arrange consulting services on matters related to accessibility.
2.2.2.8. Facilitate the development or acquisition of training solutions necessary to meet EIR accessibility-related requirements.
2.2.2.9. Work with staff in colleges and business areas responsible for LIT’s EIR. 2.2.3. Unit Head – Each administrative and academic unit head is responsible for the following:
2.2.3.1. Designation of an EIR Accessibility Liaison.
2.2.3.2. Ensuring that EIR owned and/or operationally supported by the unit comply with this policy. Operational responsibility for compliance with this policy may be delegated to the appropriate personnel within the unit.
2.2.4. EIR Accessibility Liaison
2.2.4.1. Collaborate with the EIRAC as needed.
2.2.4.2. Help appropriate staff in their area develop and maintain the knowledge and skills necessary to comply with EIR accessibility requirements.
2.2.5. Webmaster
2.2.5.1. Perform periodic (at least quarterly) website scanning with an appropriate validation tool.
2.2.5.2. Distribute validation reports to unit heads that indicate the accessibility level of pages for which they have responsibility for design and/or content. Copies of reports shall also be provided to the EIRAC.
2.3. Accessibility Standards – LIT maintains a list of Accessibility Standards compliant with 1 TAC 213 in Appendix A. These standards encompass the following topics:
2.3.1. Software Applications and Operating Systems
2.3.2. Telecommunications Products
2.3.3. Video and Multimedia Products
2.3.4. Self-Contained, Closed Products
2.3.5. Desktop and Portable Computers
2.3.6. Functional Performance Criteria
2.3.7. Information, Documentation, and Support
2.3.8. Web-Based Intranet and Internet Information Applications
2.4. Exceptions
2.4.1. An exception from this policy may be granted under certain circumstances, including significant difficulty or expense. Exception requests for EIR and websites that do not comply with accessibility requirements shall be submitted to the EIRAC by the Unit Head that owns or operationally supports the EIR. Exception requests shall contain the following information:
2.4.1.1. a date of expiration or duration of the exception;
2.4.1.2. a plan for alternate means of access for persons with disabilities;
2.4.1.3. justification for the exception including technical barriers, cost of remediation, fiscal impact for bringing the EIR into compliance, and other identified risks; and
2.4.2. Approval – Exception requests must be approved in writing. LIT shall retain documentation for approved exceptions. Documentation shall consist of the exception request and documentation of how the institution of higher education considered all institution resources available to the program or program component for which the product is being developed, procured, maintained, or used.
2.5. Procurement
2.5.1. Procurement of all EIR shall be coordinated with the EIRAC.
2.5.2. LIT personnel who acquire EIR shall require vendors to provide accessibility information for EIR products or services through one of the following methods:
2.5.2.1. Voluntary Product Accessibility Template (VPAT) or equivalent reporting template.
2.5.2.2. Credible evidence of the vendor’s capability or ability to produce accessible EIR products and services. Such evidence may include, but is not limited to, a vendor's internal accessibility policy documents, contractual warranties for accessibility, accessibility testing documents, and examples of prior work results.
2.5.3. VPATs and/or other documented evidence of accessibility shall be retained by the procurement office.
2.6. Accessibility Testing and Validation
2.6.1. Accessibility testing shall be coordinated with the EIRAC.
2.6.2. Accessibility testing validation procedures and results shall be documented and a copy provided to the EIRAC in a timely manner.
2.7. Web Accessibility
2.7.1. All new or modified Web pages must comply with the requirements of this policy.
2.7.2. All Web pages shall avoid vendor specific, “non-standard” extensions and shall comply with applicable internet standards.
2.7.3. New and modified Web pages are to be tested by the Web page owners using one or more Section 508, or equivalent, validation tools in conjunction with manual procedures to validate compliance with accessibility requirements.
2.7.4. An alternative version page, with equivalent information or functionality, must be provided when compliance cannot be accomplished in any other way. The content of the alternative page must be updated whenever the primary page changes.
2.8. The LIT home page and all LIT key public entry points must include an Accessibility link to a web page that contains LIT’s accessibility policy, site validation standard, contact information for LIT’s web accessibility coordinator, and a link to the Governor’s Committee on People with Disabilities web site
3. AUTHORITY AND RESPONSIBILITY
Questions related to this policy should be addressed to the IRM at irm@lit.edu.
4. RELATED POLICIES
4.1. 1 TAC 206.70 – Institution of Higher Education Websites - Accessibility
4.2. 1 TAC 213 – Electronic and Information Resources - Accessibility Standards for Institutions of Higher Education
4.3. Texas Government Code § 2054.457, Access to Electronic and Information Resources by Other Individuals with Disabilities
4.4. Texas Government Code § 2054.460, Exception for Significant Difficulty or Expense; Alternate Methods
4.5. Section 508 Standards for Electronic and Information Technology