Accessibility Standards for Procurement of Digital Content and Materials

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").

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 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.

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 Material.

Each of the three phases of procurement has ways to make sure what we procure is accessible.

The Search Process

When a unit begins searching for digital material, they must try to get a copy of the product’s Voluntary Product Accessibility Template (VPAT). The VPAT will help the University unit understand how well the product handles accessibility requirements. The University unit should request a VPAT from the vendor if it is not available publicly.

The Purchase and Contract Process

When purchasing any digital material, the customer University unit must show that the product or service will meet the Standard on Accessibility of Digital Material. The customer University unit must request a VPAT and Accessibility Roadmap if they have not already done that. If the vendor cannot show that the product or service will meet the Standard on Accessibility of Digital Material, the University must get an exception as described below in order to buy the Product or service.

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 for the current version of the product if asked. Request an updated VPAT for all major updates or changes to the product. 

The customer University 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, 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 policy or with the University's legal obligations, the customer University unit will be 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 and/or Accessibility Roadmap from the vendor.

Follow the same rules as for a new purchase, including contract terms, checking the VPAT, and getting exceptions.

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 are not accessible, any costs that result 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 policies, the responsible person who made the purchase may request that the vendor reply to the University within three (3) business days. The customer University unit and the vendor will create a plan to resolve the issues. This roadmap plan must be acceptable to the University. If the issues stay unresolved, see the University's Finance Procedure 1216.1 for instructions on filing a vendor complaint. 

Exceptions

1. 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 would not apply. (You must still try to get a VPAT from the provider.)

2. 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.
  • 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. Activity by student organizations is not University Business. 
  • Usability: How well people can use digital material to achieve their goals and are satisfied with the experience.

Related Requirements

External Regulations and Consequences

University Policies, Standards, and Procedures

Contact Information

Primary 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: 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: 131330
Created
Thu 4/8/21 9:06 PM
Modified
Thu 12/14/23 12:09 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.
12/13/2023 12:00 AM
Last Revised
Date on which the most recent changes to this document were approved.
12/17/2019 12:53 PM
Next Review
Date on which the next document review is due.
12/13/2026 12:00 AM
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

Related Articles (2)

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.
The University is committed to establishing a welcoming and equitable digital experience. This policy provides direction on creating an accessible experience that enhances usability for everyone. Implementing this policy will ensure that all individuals have access to Digital Content, Resources, and Technology (“Digital Material”) provided by or on behalf of the University.