Accessibility of Digital Content and Materials Standard

Title

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

Introduction

Purpose

The mission of the University of North Carolina at Chapel Hill ("UNC-Chapel Hill" or "University") tells members of the campus community to "enhance access to learning" in order to foster  success and enhance quality of life.  

Digital Material and Information Technology Accessibility is a legal requirement as stated in the Americans with Disabilities Act and Section 508 of the Rehabilitation Act of 1973

This Standard sets the minimum requirements for creating and maintaining accessible digital content, resources, and technology ("digital materials"). These minimum requirements allow the University’s students,employees, and others to equitably access the University’s digital materials, . These requirements comply with all relevant laws and University policies and are consistent with the University’s mission. 

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

Scope

Everyone who distributes, hosts, or gets digital material for the University must follow this standard.

This standard applies to all University digital material whether it faces the public, or requires a log-in, examples include:

  • Websites;
  • Video and audio content;
  • Electronic documents;
  • Desktop, mobile, and cloud-based software applications;
  • Content and learning management systems;
  • Tools and platforms;
  • Email and calendars;
  • Library resources;
  • Social media;
  • Products for digital research; and
  • Digital content and materials used in a course.

    This Standard applies to all University digital material, internal or external, regardless of how it’s made or used. The Standard also applies to everyone who selects, gets, maintains, creates, or shares digital material for the University. 

    The following examples show the variety of materials and persons covered by this standard: 

  • Website developers build sites following Web Content Accessibility Guidelines. 
  • People provide alternative text on images posted to Social Media. 
  • Humans check captions for accuracy on department videos they post to video-sharing sites.  
  • Staff creating audio podcasts on media platforms check for accurate transcripts.  
  • Staff check department PDF meeting agendas for accessibility so that all faculty and staff can read them. 
  • People taking notes in an app use a descriptive or embedded link to share them with their team rather than sharing a whole (long) URL. 
  • A Professor checks all course materials for accessibility in the Learning Management System so that every student has access to the materials needed to learn. 
  • Staff providing financial applications for payroll time entry, travel, and other administration ensure they are accessible so that people don’t encounter obstacles to routine job activities. 
  • A researcher checks that the devices used in a research lab to take measurements of light frequencies that send data to a computer are built to be usable by anyone who may need to use them. 
  • Service owners for email and online calendars make sure that those are just as available to people who use assistive technology. 

Standard

Compliance Level 

This Standard sets the compliance level for the University to the Web Content Accessibility Guidelines (WCAG) 2.2 Level AA.  

New Digital Material Must be Accessible 

New Digital Material, provided by any unit, group, or employee of the University for University purposes, must meet minimum accessibility requirements as follows: 

All websites, applications, IT services, online content, digital documents, presentations, and online learning materials must meet Web Content Accessibility Guidelines (WCAG) 2.2 Level AA. 

  • All tools that support web content authoring like HTML editors, software for generating websites, multimedia authoring tools, wikis and blogs, and such must meet Authoring Tool Accessibility Guidelines (ATAG) 2.0  
  • Individuals responsible for digital materials are responsible for their accessibility. Any new website or IT service provided on an Internet domain or subdomain (such as example.unc.edu or bestuncresearch.org) must have a Digital Accessibility Assessment and written approval by the Digital Accessibility Office (DAO). 
    • This requirement applies to any site provided by a University unit, group, or employee on behalf of the University. 
    • Submit the site before publication and plan for an appropriate amount of time to allow that review to happen. A site review, depending on complexity can take up to one week. 
    • Fix any issues discovered during the site’s review and allow appropriate time for the DAO to reassess the site to confirm the issues have been addressed 
    • Once approved, those responsible for the site are also responsible for keeping it accessible in compliance with this Standard. 
    • The DAO may require a new review at any time. 

Existing Digital Materials 

Create and Follow an Action Plan for Digital Material that is Not Accessible 

All University units must identify and prioritize Existing Digital Material that is not accessible and create an action plan to make it accessible by April 24, 2026. This is because Title II of the Americans with Disabilities Act of 1990 (ADA) gives two years after April 24, 2024, to make all digital content accessible. 

Prioritize Accommodation Requests 

If the University unit gets a request for the content, that content must be quickly made accessible. In the event Existing Digital Material cannot be made accessible, the University unit must provide an Equally Effective Alternative. 

Equally Effective Alternatives 

Equally Effective Alternatives act as a temporary way of providing access to digital content that hasn’t or can’t be made accessible. Ways to ensure effective access include: 

  • Providing easy-to-find instructions on access features that provide Input or interaction. 
  • Documenting actions taken to address material that is inaccessible. 
  • Compensating any internal or third-party resources used to produce accessible digital materials is the University unit’s responsibility. 

Provide a Link to Accessibility Information at the University 

A link is required for access to information about accessibility at the University and to allow people to report trouble accessing material because it does not meet this Standard. 

University Units are Responsible for Ongoing Digital Accessibility 

As part of their ongoing accessibility efforts, University units must:  

  • Periodically evaluate digital material to ensure compliance with this Standard.  This means: 
    • Evaluating materials that have not been checked at the highest priority. 
    • Evaluating materials known to comply with current or prior versions on a recurring basis.  
      • At a minimum, check software and IT service accessibility status at the renewal of any license agreement or other contract for that material or not longer than every three years.  
      • Check other materials on a set schedule unless the materials have not changed and are known to be compliant with the current Standard. 
  • Assign the appropriate resources for accessibility assessment and compliance. This means: 
    • Have people in the unit who have taken training and been certified as Digital Accessibility Liaisons.  
    • Ensure that staff responsible for digital materials have taken Digital Accessibility Training appropriate for their role. 
    • Include costs and time in planning when new digital materials will be made available (captioning services and tools, scanning, time for DAO review, etc.) 
  • Bear the cost of bringing digital materials they provide into compliance with this Standard. 
  • Check links to external resources and make their best effort to ensure that resources accessed are accessible. 

The DAO has an ongoing, targeted evaluation process for high-priority digital material. University Units: 

  • Must participate in ongoing site scanning for their public-facing websites, 
  • Must include any site or service as directed by the DAO, and 
  • Are encouraged to participate with their internal sites not available to the public. 

Digital Accessibility Training 

To build a solid foundation of accessible digital content for the University the following groups of individuals must take Digital Accessibility Training: 

  • University web and application developers, 
  • Content creators and editors, 
  • Those who procure digital technology, and 
  • Responsible Persons for IT Services. 

Minimum Required Training 

All individuals in the categories listed above must complete the “Accessibility Awareness” course. 

Recommended Training 

  • In addition to the required training, The University strongly recommends specialized classes relevant to specific roles 
  • The DAO may require these classes for those working on large or high-priority sites, services, or projects. 

Exceptions

Minimal Use

If a specific condition applies, an exception may be used to buy and use digital material that is not accessible according to this standard if: 

  • the material will be used by 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 those people.

The digital material would not need to be evaluated or fixed as this Standard would require otherwise. An Equally Effective Alternative (a way that communicates the same information and does the same things in a timely way) is not required. If the characteristics of the group of people who use the digital material changes in a way that would violate one these requirements, then this exception no longer applies. 

This exception does not apply: 

  • When digital material is intended for long-term use or by unknown future people 
  • If a person using the material tells the University unit about an accessibility need that must be fulfilled 

Fundamental Alteration or Undue Burden

If an Equally Effective Alternative cannot be provided because it would make a fundamental alteration or cause 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: 

  • Confirm the head of the University unit responsible for the material approves asking for an exception. 
  • Submit an exception request to the Digital Accessibility Office via help.unc.edu. The request must include detailed information about how you have tried to make the digital material accessible or to provide an Equally Effective Alternative. Include information about why it is not possible to make the digital material accessible and why providing an Equally Effective Alternative would impose a fundamental alteration or undue burden. The Digital Accessibility Office will review the requests. 
  • Representatives from the Digital Accessibility Office, , and/or Digital Accessibility Liaison program will conduct reviews. Afterwards, the Digital Accessibility Office will notify the unit about whether the exception is approved. 

Unapproved Exceptions 

If the exception is not approved, the Digital Accessibility Office may help the University unit to make a plan. The University unit may look for other vendors with similar products or try other methods to get the result they want. 

The request will be documented, and the decision will be explained in writing. It can be provided on request. Those decisions are final. 

Specific Use Exceptions 

If the Digital Accessibility Office identifies alternative means to meet the University’s obligations it may allow specific exceptions. For example, if Generative AI systems come up to acceptable levels for captioning, the DAO may certify specific applications that may be used instead of human checking of captions otherwise required by this Standard. 

Definitions

  • Accessible: Able to be used by anyone, including people with disabilities, with or without assistive technology.
  • Digital Accessibility Liaisons: advocate for accessibility in all aspects of campus life, acting as a main departmental contact for digital accessibility questions and answers. As a campus affinity group they promote digital accessibility by learning about, sharing, and supporting the work of the Digital Accessibility Office 
  • Digital Content and Materials (Digital Content, Resources, and/or Technology): Information, products, and services available for download or distribution electronically, or on a web page or computer application.
  • Equally Effective Alternative: A way that communicates the same information and does the same things in a timely a way.
  • Existing Digital Material: Includes all Digital Content and materials developed or bought before the effective date of this Standard, including any that is archived.
  • New Digital Material: Includes all Digital Content and materials developed or bought after the effective date of this Standard.
  • Universal Design Principles: the design of products and environments to be usable by all people, to the greatest extent possible, without adaptation or specialized design. 
  • University Business: Activities carried out on behalf of UNC-Chapel Hill. University Business does not include activities organized or done by students unless the University has asked them to act on behalf of the University.
  • Usability: How well people can use digital material to achieve their goals.

Related Requirements

External Regulations and Consequences

University Policies, Standards, and Procedures

Contact Information

Policy Contacts

ITS Policy Office

  • Unit: Information Technology Services
  • Email: IT_Policies@unc.edu 
  • Online: help.unc.edu (service request) 

Digital Accessibility Office

  • Unit: Information Technology Services
  • Email: digital_accessibility@unc.edu 
  • Online: help.unc.edu (service request) 

Other Contacts

  • UNC Digital Accessibility Office's "Report a Digital Accessibility Issue" webpage. 
  • 919-962-HELP. 
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Details

Article ID: 131329
Created
Thu 4/8/21 9:06 PM
Modified
Tue 9/3/24 3:17 PM
Responsible Unit
School, Department, or other organizational unit issuing this document.
Digital Accessibility Office
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
Next Review
Date on which the next document review is due.
09/03/2027 12:00 AM
Last Review
Date on which the most recent document review was completed.
09/03/2024 12:00 AM
Last Revised
Date on which the most recent changes to this document were approved.
09/03/2024 12:53 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
Origination
Date on which the original version of this document was first made official.
12/17/2019 12:53 PM
Flesch-Kincaid Reading Level
14.6

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