Title
University of North Carolina at Chapel Hill Standards for Procurement of Digital Content, Resources, and Technology
Introduction
Purpose
Providing a welcoming and fair digital experience is important to the University of North Carolina at Chapel Hill ("UNC-Chapel Hill" or "University").
This Standard explains the requirements for obtaining accessible digital content, resources, and technology ("digital materials") by any University unit, group, or employee from a third party for University use. .
Following this Standard and the Policy on Digital Accessibility helps the University and each of us to follow the law and give everyone access to Digital Material purchased by or on behalf of the University.
Scope
This Standard applies to everyone at UNC-Chapel Hill who procures digital material used for University business. This includes third parties, when a situation is in the University’s control. This Standard applies to all University digital material examples including:
- 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.
Standard
All digital material procured by or on behalf of the University after this standard went into effect must adhere to the Standard on Accessibility of Digital Content, Resources, and Technology.
Training
All people who select and participate in purchasing Digital materials on behalf of the University must take the Procuring Accessible Digital Content, Resources and Technology training from the Digital Accessibility Office before they enter into the Search Process for procurement.
The Search Process
When a University unit begins searching for digital material, they must try to get a copy of the product’s Voluntary Product Accessibility Template (VPAT), Accessibility Conformance Report (ACR), or Higher Education Community Vendor Assessment Toolkit 3.05 or newer (HECVAT). These documents will help the University unit understand how well the product handles accessibility requirements. The University unit should request this information from the vendor if it is not available publicly. If the vendor does not produce this information, the unit must reach out to the Digital Accessibility Office for assistance in deciding the next steps to take with the vendor.
The Purchase and Contract Process
When purchasing any digital material, the customer University unit (not UNC Procurement Services) is responsible for ensuring that the product or service will meet the Standard on Accessibility of Digital Material. The responsible unit must request accessibility documentation (VPAT, ACR, or HECVAT) and an Accessibility Roadmap if they have not already done that. If the vendor cannot show that the product or service will meet the University requirements represented in the Standard on Accessibility of Digital Material, the responsible unit must reach out to the Digital Accessibility Office for assistance and to determine if an exception as described below is suitable.
If the purchase is greater than or equal to $5,000 and the intended user base is greater than 100 people, you must include accessibility terms in the contract or other agreement. The terms must guarantee continued accessibility as the product is updated and new releases become available. The contract must guarantee that the vendor can and will provide a VPAT, ACR, or HECVAT for the current version of the product if asked. Request an updated VPAT, ACR, or HECVAT for all major updates or changes to the product.
The responsible unit must evaluate and confirm that all digital material they procure complies with the University's Standard on Accessibility of Digital Content, Resources and Technology. This includes evaluating the VPAT, ACR, or HECVAT, any Digital Accessibility Roadmap, and other information available about the product. For purchases over $5,000, the customer University unit must document that this evaluation was done.
Any digital materials may need to be reviewed to be sure that they are accessible. If something turns out not to be compliant with University standards or with the University's legal obligations, the customer University unit is responsible for any costs involved.
The Renewal Process
Contract renewals offer a chance to address or re-address accessibility. When renewing a contract for digital materials, a customer unit must make sure the product or service meets the Standard on Accessibility of Digital Material. Request an updated VPAT, ACR, or HECVAT and/or Accessibility Roadmap from the vendor.
Follow the same rules as for a new purchase, including contract terms, checking the VPAT, ACR, or HECVAT, and requesting assistance from the Digital Accessibility Office when needed.
It may be necessary to pause a contract renewal to be sure that accessibility issues are resolved or that the vendor is making acceptable progress. If a unit has gotten digital materials that were not accessible in the past and seeks to renew an agreement for them, any costs that result from those accessibility issues are the unit’s responsibility.
Vendor Non-Compliance Issues
If you find issues with your vendor’s compliance with federal or state accessibility or disability law, or University standards:
- The responsible person who made the purchase may request that the vendor reply to the University within three (3) business days
- Unresolved issues report the situation to the Digital Accessibility Office
Create a plan to resolve the issues
The customer University unit and the vendor will create a plan to resolve the issues. This roadmap plan must be acceptable to the University, based on review by the Digital Accessibility Office.
Issues remaining unresolved
See the University's Finance Procedure 1216.1 for instructions on filing a vendor complaint.
Exceptions
Any exception request must be submitted to the Digital Accessibility Office for approval including for renewals.
Minimal Use
If the digital material meets the Minimal Use exception in the Accessibility of Digital Content and Materials Standard, then the Purchase and Contract and Renewal requirements do not apply. (You must still try to get accessibility documentation from the provider.)
Fundamental Alteration or Undue Burden
If a Fundamental Alteration or Undue Burden exception to the Accessibility of Digital Content Resources, and Technology Standard is given for the digital material, then the material may be purchased according to the conditions of that exception.
Definitions
- Accessible: Able to be used by anyone, including people with disabilities, with or without assistive technology.
- Accessibility Roadmap: Timeline for adding features and fixes to improve accessibility.
- Alternative Format: Content similar or identical to the Digital Content and Materials, but in a format that produces a different user experience to address accessibility needs.
- Customer Unit: University unit that starts a purchase. This unit is responsible for accessibility of digital material they get.
- Digital Accessibility Roadmap: Document describing plans to improve accessibility of some Digital Material.
- 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.
- Product: Digital content and materials being considered for purchase.
- Undue Burden: an action that is excessively costly, extensive, and would fundamentally alter the product or service
- 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
Primary Contacts
ITS Policy Office
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