The University of Iowa - CIO Office

TITLE: Accessibility Standards for Web Resources V1.3

IT - STANDARD: 01

DATE DRAFTED: 10/29/02

REVISION DATE: 11/01/02, 02/03/03

BRIEF DESCRIPTION: Web sites are required to structure their design, content and underlying technologies to be accessible to people with disabilities.

Purpose:

The University of Iowa is committed to providing equal access to information, programs, and activities through its technologies, web pages, services and resources. Fulfilling this promise is critical because the Internet is fast becoming the central nervous system of university life. When properly designed, web pages facilitate an inclusive environment and culture, and enhance learning, teaching, research, scholarship, creativity, and public service and outreach. When improperly designed, without regard for the needs and abilities of our diverse community, web pages may become barriers that can block our educational commitment.

A comprehensive, formal web accessibility policy is the key to ensuring that web resources are accessible, usable, understandable, and navigable. Such a policy signifies that the University of Iowa values all of its members and provides tangible proof of the University's commitment to empowering people and promoting their independence. This policy establishes minimum standards for achieving these goals in a manner that preserves the freedom of designers and developers to create cutting-edge, state-of-the-art, well-designed pages, resources, and services.

Scope:

This policy applies to all new and legacy web resources published by or hosted by the University of Iowa.

Statement:

Standards for Web Resources

University web resources are to be created and maintained with a focus on performance, ease of navigation, visual appeal, accessibility, and understandability according to the standards as set forth at http://www.its.uiowa.edu/its/accessibility/508_guidelines/index.html. These standards are the minimum standards. Departments are encouraged to deploy and redesign web pages, resources, and services that provide for greater accessibility and ease of use than is required by this policy. Exceptions to the policy standards are described in section (5) below.
New Web Resources

New web resources should meet or exceed policy standards at the time of their publication.
Updating Existing Web Resources

Each department or unit is to establish priorities and timetables for updating its legacy (existing) web resources to meet or exceed policy standards. Legacy web resources should be updated according to the following priorities:
- Specific web resources that an individual has requested be made accessible. The department or unit responsible for the creation of the content is responsible for honoring the request in a timely manner by:
  1. Revising the resource to make content accessible, or
  2. Providing the content in an effective alternative format.
- Web resources that prominently represent the University and key public entry points, including, for example:
  1. University and departmental home pages
  2. Admissions
  3. Catalogs
  4. Registration
  5. Course work
  6. Library resources and services
  7. Human resources
  8. Administration
  9. Advising
  10. Student services
- Web resources that are not commonly available through another means. Care should be taken to make sure web resources are accessible before paper-based or other legacy systems are eliminated. Such resources may include, but are not limited to:
  1. Enrollment for employee benefits
  2. Student registration
  3. Library holdings
  4. Web access to email
- The top 20% of web resources most frequently used (those that receive the largest number of hits).
- Web resources required for participation, funding, disability-related services, and other key pages needed by people with disabilities, if those pages are not among the top 20%.
- Web resources in archive status (e.g., no longer in use but subject to records retention plans) containing core administrative or academic information, official records, and similar information.
Contact Information

All University web resources must contain a statement referring to accessibility, and an accessible link a visitor can use to contact a person, preferably the web page developer, with questions, comments, and accessibility concerns. For example:
“The [name of department or unit] is committed to making its websites accessible to all users and welcomes comments or suggestions on access improvements. Please send comments or suggestions on accessibility to [name of person to contact],”
Each of these pages should also include the date the resource was published and updated.
Exceptions to the Policy Standards
- There will be times when departments and units are unable to meet or comply with policy standards. Exceptions to the policy are permitted only when full compliance would impose an “undue burden.”
- In determining whether full compliance poses an undue burden, a department or unit must consider all resources available to it as well as the technical difficulty involved in complying with policy standards.
- A department or unit can depart from the policy only when it determines and documents that an undue burden exists that precludes full compliance; however, it must provide the content through comparable alternative means of access.
Alternative Means of Access
- When full compliance with this policy is excused because of an undue burden, the department or unit must provide a comparable alternative means of access that is equally effective.
- Text-only pages are to be used only when compliance cannot be accomplished in any other way. Alternative means may include, but are not limited to:
  1. Voice
  2. Fax
  3. Relay service
  4. TTY
  5. Captioning
  6. Text-to-speech synthesis
  7. Audio description
  8. Internet posting and hard copy
- Information may also be provided in alternate formats, depending on the needs, abilities and preferences of the person with a disability. Such alternate formats may include:
  1. Braille
  2. ASCII text
  3. Large Print
  4. Recorded audio
  5. Other electronic formats that comply with this policy
Faculty Notice to Students

Faculty members need to discuss any accessibility issues related to courses that include web components with their students.
- Faculty should consider accessibility for registration materials, course descriptions, syllabi, and other course materials.
- They need to alert students if online course elements make use of inaccessible formats to communicate essential information. Such formats may include:
  1. Graphical user interfaces
  2. Interactive screens
  3. Visualization tools
  4. Audio material
- If a student with disabilities discovers that such elements are used, the student should consult with faculty member(s) teaching the course, his or her advisor, Student Disability Services, or others as soon as possible (even before the course begins whenever possible) to discuss his or her needs.
Disputes and Grievances

When a person with a disability cannot access online material, he or she should contact the person responsible for accessibility identified in section four (4). If the contact person does not provide a satisfactory response, the person with a disability can contact the department’s technology staff or the offices listed below. Information about filing grievances and complaints can be obtained at any time from:

Office of Student Disability Services	319-335-1462
Faculty & Staff Services	319-335-2085
Faculty & Staff Disability Services	319-335-0052 (voice)
Faculty & Staff Disability Services	319-335-3495 (TTY)
Office of Affirmative Action	319-335-0705 (voice)
Office of Affirmative Action	319-335-0697 (text)
University Ombudsperson	319-335-3608
Employee and Labor Relations	319-335-0052

Definitions:

Web resources include, but are not limited to, all Internet and Intranet web pages, services, sites, distance learning or education, and WebCT, Blackboard or other course management systems, whether current, active, or archived.

Accessible web resources are those that fully comply with the guidelines and standards listed in the attachment to this policy.

An alternative representation or alternative means is a format or publication of web content that communicates the same information or data in a timely manner.

Undue burden means significant difficulty or expense in creating, modifying or publishing web resources. In determining whether an action would result in an undue burden, a department or unit shall consider all available University resources available to it, as well as the technical difficulty involved in complying with the policy standards.

Legacy web resources are those pages, resources, or services created prior to the effective date of this policy. New web resources are those pages, resources, or services created after the effective date of this policy.

Related Policies, References and Attachments:

University of Iowa Information Technology policies and procedures contain acceptable use, security, networking, administrative, and academic policies that have been developed to supplement and clarify University of Iowa policy. They are incorporated by reference into the University of Iowa Operations Manual (http://www.uiowa.edu/~our/opmanual/index.html), in accordance with the Policy on Acceptable Use of Information Technology Resources (http://www.uiowa.edu/~our/opmanual/ii/19.htm).

University of Iowa

Accessibility Policy for Web Resources

Appendices/Attachments:

Web Development Guidelines

This section provides University standards and guidelines for developing web resources that are accessible and usable. The standards are listed below and are based on technical standards and criteria issued by the U.S. Access Board. Examples and explanations of a select group of these technical standards, as well as suggested solutions to common accessibility problems are available on-line (and linked to the electronic version of this policy) at http://www.uiowa.edu/~acadtech/accessibility/508_guidelines/#f. Functional performance criteria are described in Section 1194.31.

§ 1194.22 Web-based Intranet and Internet information and applications.

(a) A text equivalent for every non-text element shall be provided (e.g., via "alt", "longdesc", or in element content).
(b) Equivalent alternatives for any multimedia presentation shall be synchronized with the presentation.
(c) Web pages shall be designed so that all information conveyed with color is also available without color, for example from context or markup.
(d) Documents shall be organized so they are readable without requiring an associated style sheet.
(e) Redundant text links shall be provided for each active region of a server-side image map.
(f) Client-side image maps shall be provided instead of server-side image maps except where the regions cannot be defined with an available geometric shape.
(g) Row and column headers shall be identified for data tables.
(h) Markup shall be used to associate data cells and header cells for data tables that have two or more logical levels of row or column headers.
(i) Frames shall be titled with text that facilitates frame identification and navigation.
(j) Pages shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.
(k) A text-only page, with equivalent information or functionality, shall be provided to make a web site comply with the provisions of this part, when compliance cannot be accomplished in any other way. The content of the text-only page shall be updated whenever the primary page changes.
(l) When pages utilize scripting languages to display content, or to create interface elements, the information provided by the script shall be identified with functional text that can be read by assistive technology.
(m) When a web page requires that an applet, plug-in or other application be present on the client system to interpret page content, the page must provide a link to a plug-in or applet that complies with §1194.21(a) through (l).
(n) When electronic forms are designed to be completed on-line, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.
(o) A method shall be provided that permits users to skip repetitive navigation links.
(p) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.

§ 1194.31 Functional performance criteria

(a) At least one mode of operation and information retrieval that does not require user vision shall be provided, or support for assistive technology used by people who are blind or visually impaired shall be provided.
(b) At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently, or support for assistive technology used by people who are visually impaired shall be provided.
(c) At least one mode of operation and information retrieval that does not require user hearing shall be provided, or support for assistive technology used by people who are deaf or hard of hearing shall be provided.
(d) Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion, or support for assistive hearing devices shall be provided.
(e) At least one mode of operation and information retrieval that does not require user speech shall be provided, or support for assistive technology used by people with disabilities shall be provided.
(f) At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided.

Recommended Practices:

Know and learn the University of Iowa Accessibility Policy for Web Resources.
Become familiar with the policy’s technical standards and functional performance criteria.
Check your department/unit website and resources.
Be resourceful, use your judgment, educate and train yourself and others.
Adopt or adapt these practices and tips:
1. Provide an accessible link entitled “accessibility and web site appearance” in the top left hand corner of each page or site that furnishes users with information about site architecture, site viewing tips, screen resolutions, web browsers, third-party software (such as Adobe Acrobat Reader), cascading style sheets, and accessibility features such as large text, high contrast, etc.
2. Simple web sites that emphasize text, content, and meaning over stylistic visual elements tend to be more accessible by their very nature. Content providers can generally minimize the effort required to make a site accessible by keeping the design simple. This may be especially useful for informal documents that need to be published quickly.
3. For the most part, nearly any design can be adapted to comply with Section 508 standards without sacrificing the aesthetics or advanced features of the design. Content providers who feel they need to make design changes to the site in order to make it accessible should contact one of the resources listed under “University Contacts” for consultation and advice.
4. Individual web content providers should use their best judgment on how to implement this policy for their own situation.
5. Numerous tools are available for evaluating accessibility and compliance with Section 508 guidelines, including Web Aim’s Section 508 web accessibility checklists at http://www.webaim.org/standards/508/checklist. University of Wisconsin has excellent information for developers, designers, students, and faculty at http://wiscinfo.doit.wisc.edu/ltde/orfi/wds/modules/508guidelines.html.
6. Individuals, departments, colleges, and administrative units should use whichever tools best suit their environment. It is important to remember, however, that no tool is a substitute for informed judgment.
7. It is wise to use a variety of web browsing software (including text-only browsers), different workstations, with speeds of connection, a variety of navigation strategies (such as navigating through the site using only the keyboard), and evaluation tools to test access to web pages.
8. Keep records of the time, resources, and expenses involved in creating, designing, retrofitting, testing, and evaluating web resources. Such records can be used to assess the success and cost of University accessibility efforts. They are also important documents to have on hand when federal or state agencies conduct audits.
9. Subscribing to a web accessibility mailing list is a good way to stay informed about current and disability practices. Several mailing lists are available through the Trace Center at the University of Wisconsin, at http://www.trace.wisc.edu:8080/subscribe.html.
10. Because of the inherent difficulties in maintaining two equally effective sites, a universally accessible web site is always preferred over the creation of an alternative text-based site.

University Contacts:

Subject

Contact

E-mail or Web Site

Phone

Policy questions

Information Technology Services

Academic Technologies

http://www.its.uiowa.edu/its/

319-335-5194

Technical questions

Staff and Students

Faculty

ITS Help Desk

Academic Technologies

its-helpdesk@uiowa.edu

its-academic@uiowa.edu

clas-webmaster@uiowa.edu

clas-it@uiowa.edu for College IT needs

319-384-4357

319-335-5194

319-335-3554

Making web pages accessible and easy to use

Iowa Center for Assistive Technology Education & Resources (ICATER)

http://projects.education.uiowa.edu/icater/

319-335-5280

Disability services,

accommodations,

grievances and complaints

Affirmative Action

Faculty and Staff Disability Services

Student Disability Services

http://www.uiowa.edu/~oaa/

http://www.uiowa.edu/hr/fsds/

http://www.uiowa.edu/~sds/

319-335-0705 (voice)

319-335-0697 (text)

319-335-0052 (voice)

319-335-3495

(TTY)

319-335-1462