Accessibility of Digital Content, Resources, and Technology Standard

Title

University of North Carolina at Chapel Hill Standard on Accessibility of Digital Content, Resources, and Technology

Introduction

Purpose

The University of North Carolina at Chapel Hill is committed to providing a welcoming and equitable digital experience.

This Standard sets out the minimum requirements for creating accessible Digital Content, Resources, and Technology (“Digital Material”) to advance the University’s commitment to providing equitable access in compliance with the University Policy on Digital Accessibility.

Accessibility is a shared responsibility among those who maintain University Digital Material.

Scope of Applicability

This Standard applies to all University Constituents and third parties, under circumstances within the University’s control, who distribute, host, otherwise make available, or obtain Digital Material when conducting University Business.

This Standard applies to all University Digital Material regardless of audience or authentication required, including but not limited to:

  • Websites
  • Video and audio content
  • Electronic documents
  • Desktop, mobile, and cloud-based software applications
  • Content management systems and learning management systems
  • Interactive tools and platforms
  • Email and calendars
  • Library resources
  • Social media
  • Digital research products
  • Digital content and materials used in a course

Standard

New Digital Material provided by the University of North Carolina at Chapel Hill must be Accessible except where doing so would impose a Fundamental Alteration or Undue Burden.

New Digital Material must meet minimum accessibility requirements. The following requirements apply to specific types of content, resources, and technology:

  • Section 508 of the Rehabilitation Act of 1973, as amended
  • Web Content Accessibility Guidelines (WCAG) 2.0 Level AA
  • Authoring Tool Accessibility Guidelines (ATAG) 2.0 for tools that support web content authoring (e.g. HTML editors, software for generating websites, multimedia authoring tools, wikis and blogs, etc.)

These requirements serve as the basis for “Universal Design” principles. Use of these principles and compliance with the above requirements is intended to result in a welcoming and equitable digital experience for a wide range of people regardless of ability, disability, or use of assistive technology.

University units must identify and prioritize Existing Digital Material that is not Accessible and develop an action plan to make that Existing Digital Material Accessible. In addition, upon request, University units must make any Existing Digital Material Accessible in a timely manner. In the event Existing Digital Material cannot be made Accessible, the University unit must provide an Equally Effective Alternative.

If a user must interact with the Digital Material in an unexpected way, workarounds must be advertised or provided upon request. If features of the Digital Material’s accessibility may be reliant on user input, instructional materials/guides must be provided and users must be made aware.

If the Digital Material has a reasonable alternative method or format for a feature, the alternative method or format must be readily available and documented.

University units may use University Constituents or external contractors to make Digital Material Accessible. The expense of the work falls to the University unit responsible for the Digital Material.

Digital Material compliance activities may be prioritized based on available resources, audience scope, and amount or size of the request or content. When an accommodation request is received, the timeline for making the existing or archived Digital Material accessible must be expedited.

University units must provide contact information on or associated with all Digital Material for users who have trouble accessing the Digital Material. The contact information should be an accessible link on web sites, or an appropriate alternative in other contexts, that allows individuals to report an accessibility issue.

Ongoing Accessibility Evaluation

University units are responsible for evaluating their Digital Material to ensure ongoing compliance with this Standard. Resources must be allocated to this ongoing evaluation, including designation of an appropriate number of Digital Accessibility Liaisons. Upon request, the Digital Accessibility Office may provide consultation and training assistance as needed.

A variety of methods may be used to complete this evaluation. Methods may include automated testing, expert evaluation, manual testing, and user testing.

In addition to individual unit evaluations, the Digital Accessibility Office will oversee an ongoing, targeted evaluation process of high priority Digital Material.

Exceptions

1. Minimal Use

If Digital Material will be used by one individual or a small number of identified individual(s) (such as a small office or a research lab), and the responsible University unit confirms that the Digital Material is Accessible to the identified individuals, a de minimis exception applies to the procurement or development of such Digital Material. The Digital Material is not subject to the evaluation or remediation requirements of this Standard, and there is no requirement to provide an Equally Effective Alternative.This exception no longer applies when the Digital Material is used by individuals other than those originally identified when the Digital Material was developed or procured. Therefore, this exception shall not be used when Digital Material is intended for long-term use or by unknown future users. This exception also no longer applies when an individual notifies the University unit of an accessibility need related to the Digital Material. Once the exception no longer applies, the Digital Material is subject to all requirements of this Standard, including those related to identification and remediation of accessibility issues and to availability of an Equally Effective Alternative.

2. Fundamental Alteration or Undue Burden

If an Equally Effective Alternative cannot be provided because doing so would impose a Fundamental Alteration or an Undue Burden, or if another requirement of this Standard cannot be met, the University unit responsible for the Digital Material must use the following process to request an exception to this Standard:

  1. Obtain approval from the applicable University unit head to submit the request.
  2. Submit an exception request via help.unc.edu that contains detailed information about efforts to make Accessible the Digital Material and to provide an Equally Effective Alternative. Include information about why it is not possible to make Accessible the Digital Material and why providing an Equally Effective Alternative would impose a Fundamental Alteration or Undue Burden. The Digital Accessibility Office will collect all requests and begin the review process.
  3. Reviews will be conducted by representatives from the Digital Accessibility Office, the Office of University Counsel, the Digital Accessibility Advisory Team, and/or the Digital Accessibility Liaison program. Following appropriate review, the Digital Accessibility Office will notify the unit about whether the exception is approved in as timely a manner as possible.

If the exception request is not approved, the Digital Accessibility Office may assist the University unit in creating an action plan including researching other vendors with similar products or identifying alternative methods to achieve the same functional goals.

A written explanation for an exception will be tracked within the help.unc.edu system and be available upon request. All decisions are final.

Definitions

  • Accessible: Able to be used by all individuals, including individuals with disabilities, with or without assistive technology.
  • Digital Content, Resources, and/or Technology: (also referred to as “Digital Material”) Information, products, and services available for download or distribution in an electronic format or presented on a web page or through a web or other computer application.
  • Equally Effective Alternative: Format or medium that communicates the same information and provides the equivalent functions in as timely a manner as does the original content or resource.
  • Existing Digital Material: Includes all Digital Content, Resources, and Technology developed or procured prior to the effective date of this Standard, including Digital Content, Resources, or Technology that is archived.
  • Fundamental Alteration: A change so significant that it affects the essential nature of the instruction, program or activity provided.
  • New Digital Material: Includes all Digital Content, Resources, and Technology developed or procured after the effective date of this Standard.
  • Undue Burden: A significant disruption, expense, or difficulty that may result by the provision of accessible Digital Content, Resources, or Technology.
  • University Business: Activities carried out on behalf of UNC-Chapel Hill. University Business does not include activities organized or conducted by students when not designated to act on behalf of the University or by student organizations.
  • University Constituents: UNC-Chapel Hill faculty, staff, students, retirees and other affiliates, contractors, distance learners, visiting scholars and others who use or access UNC-Chapel Hill resources.
  • Usability: Refers to how easily, effectively, and efficiently individuals can use digital content, resources, or technology to achieve their goals, as well as their satisfaction with the quality of the experience.

Related Requirements

External Regulations and Consequences

University Policies, Standards, and Procedures

Contact Information

Policy Contacts

ITS Policy Office

  • Unit: Office of the Vice Chancellor for IT and CIO
  • Email: IT_Policies@unc.edu
  • Online: help.unc.edu (service request)

Digital Accessibility Office

  • Unit: Office of the Vice Chancellor for IT and CIO
  • Email: digitalaccessibility@unc.edu
  • Online: help.unc.edu (service request)

Other Contacts

To report a concern with any University Digital Material, please visit the UNC Digital Accessibility Office's "Report a Digital Accessibility Issue" webpage or call 919-962-HELP.

Details

Article ID: 131329
Created
Thu 4/8/21 9:06 PM
Modified
Fri 7/23/21 12:57 PM
Effective Date
If the date on which this document became/becomes enforceable differs from the Origination or Last Revision, this attribute reflects the date on which it is/was enforcable.
12/07/2020 2:14 PM
Issuing Officer
Name of the document Issuing Officer. This is the individual whose organizational authority covers the policy scope and who is primarily responsible for the policy.
Issuing Officer Title
Title of the person who is primarily responsible for issuing this policy.
Vice Chancellor for Information Technology and Chief Information Officer
Last Review
Date on which the most recent document review was completed.
12/07/2020 2:14 PM
Last Revised
Date on which the most recent changes to this document were approved.
12/17/2019 12:53 PM
Origination
Date on which the original version of this document was first made official.
12/17/2019 12:53 PM
Responsible Unit
School, Department, or other organizational unit issuing this document.
Digital Accessibility Office