Web Accessibility Policy

Approved by: The Board of Trustees
History: Approved September 20, 2017
Next Review Date: On or before August 14, 2020
Related policies: IT Product Review Process; Contract Review Guidelines
Responsible Office/Official: Web Accessibility Coordinator; Web Accessibility Committee
  1. Statement of Policy
    In accordance with federal and state law, Western Michigan University (WMU or University) strives to provide equal opportunity in all educational and administrative services, programs and activities. Facilitating equal and effective access is the responsibility of all University staff and faculty. That responsibility includes ensuring that websites and web services provided or utilized by WMU are consistent with the law and the University’s commitment to accessibility.
  2. Purpose of Policy
    The purpose of this Policy is to facilitate and verify that information provided through the University's websites (Online Content) is accessible to students, prospective students, employees, guests, and visitors with disabilities, particularly those with visual, hearing or manual impairments or who otherwise require the use of assistive technology to access information.
  3. For whom Policy is most applicable
    This Policy applies to all staff, faculty and student employees at the University, including—but not limited to—Development and Alumni Relations, Auxiliary Enterprises and Athletics. However, it is most applicable to the following: Office of University Relations; Office of Information Technology (OIT); University Libraries; Extended University Programs; and any staff, faculty or student employee who creates, edits, posts or maintains Online Content as part of his or her official University functions.
  4. Key definitions
    • Accessible: A person with a disability is afforded the opportunity to acquire the same information, engage in the same interactions and enjoy the same services as a person without a disability in an equally effective and equally integrated manner, with substantially equivalent ease of use. A person with a disability must be able to obtain the information as fully, equally and independently as a person without a disability. Although this might not result in identical ease of use compared to that of persons without disabilities, it still must ensure equal opportunity to the educational benefits and opportunities afforded by the technology and equal treatment in the use of such technology.
    • Disability: A physical or mental impairment that substantially limits one or more major life activities.
    • Online Content: Any information or service that may be accessed via a web browser, including—but not limited to—internet websites, images, audio, video, search engines and locally or remotely hosted (e.g., “cloud”) software systems.
    • Web Accessibility Committee: A group consisting of representatives from across the University who assist, support, and advise the Web Accessibility Coordinator.
    • Web Accessibility Coordinator: The WMU employee(s) charged with primary responsibility for coordinating and implementing this Policy.
    • Web Accessibility Standards: The technical standards for web accessibility compliance adopted by the University.
    • Web Content Accessibility Guidelines (WCAG): A set of web accessibility guidelines published by the W3C. As of the drafting of this Policy, the most current version of these guidelines is WCAG 2.0. These guidelines may change as technology advances.
    • Web content management system (CMS): A software system that provides tools for creating, modifying and publishing web pages.
    • World Wide Web Consortium (W3C): The main international standards organization for the web.
  5. Policy
    The following provisions apply to all Online Content acquired, published or hosted by the University or used to conduct University business or activities. Online Content includes content provided or developed by third parties (e.g. vendors, video-sharing websites such as YouTube, Vimeo, software-as-a-service providers, and other open sources) that the University chooses to make available via the web.
    • 5.1. Web Accessibility Standards
      • 5.1.1. WCAG 2.0 Level AA conformance shall be the technical standard for evaluating the accessibility of Online Content at Western Michigan University.
      • 5.1.2. As technologies advance, the University will continue to consider, and may adopt, additional standards at the recommendation of the Web Accessibility Committee; however, in no case should any additional standards be interpreted as diminishing or negating the existing technical standard.
    • 5.2. Implementation
      • 5.2.1. The Web Accessibility Coordinator will:
        1. Have sufficient knowledge, skill and experience to understand and employ the University’s Web Accessibility Standards;
        2. Be housed in the Office of University Relations;
        3. Chair the Web Accessibility Committee;
        4. Conduct regular audits to measure the University’s Online Content against the Web Accessibility Standards;
        5. Document and evaluate all problems identified through audits; and
        6. Ensure that all Web Accessibility Standards adopted by the University are documented on WMU’s website.
      • 5.2.2. Web Accessibility Coordinator contact information:

        Cara Barnes
        Assistant Director of Electronic Communication Quality Assurance
        Office of University Relations
        300 E Walwood Hall, Kalamazoo, MI 49008-5433
        (269) 387-8435
      • 5.2.3. The Web Accessibility Committee will:
        1. Consist of (at a minimum) a participant from each of the following offices or organizations: OIT; Office of the General Counsel (OGC); Office of University Relations; Disability Services for Students; Office of Institutional Equity (OIE); and Faculty Senate.
        2. Develop and define procedures to ensure that Online Content meets the University’s Web Accessibility Standards;
        3. Develop procedures to ensure that Online Content that does not meet the Web Accessibility Standards is evaluated and, if necessary, remediated within a reasonable period of time; and
        4. Develop procedures for evaluating and responding to exception requests submitted pursuant to Section 5.4, below.
      • 5.2.4. The Office of Information Technology will:
        1. Work with the Web Accessibility Coordinator to incorporate Web Accessibility Standards compliance validation into the IT Product Review Process; and
        2. Assist Web Accessibility Committee in developing methods for tracking compliance with training requirement(s).
      • 5.2.5. All units and programs will:
        1. Ensure that Online Content meets or exceeds the Web Accessibility Standards;
        2. Complete the IT Product Review Process before acquiring any third-party product or service that provides or hosts Online Content; and
        3. Cooperate with the Web Accessibility Coordinator to identify and remediate Online Content that does not meet the Web Accessibility Standards.
    • 5.3. Training
      • 5.3.1. The Web Accessibility Committee will:
        1. Develop an annual training program to educate staff, faculty and student employees who, as part of their official University functions, create, maintain, post or distribute information with Online Content to students, employees, guests, and visitors with disabilities;
        2. Verify that training is facilitated, in whole or in part, by an individual with sufficient knowledge, skill and experience to understand and employ the University’s Web Accessibility Standards;
        3. Develop a system for verifying that all of the individuals identified above complete the training requirements of this Policy; and
        4. Work with appropriate University entities to develop processes and procedures to make completion of annual training a condition of access to the University’s CMS and web hosting environment.
          • 5.3.1.1. The training must, at a minimum, explain the Web Accessibility Policy and discuss each individual’s role and responsibility to verify that web design, documents, and multimedia content are accessible.
          • 5.3.1.2. Prior to conducting or publishing such training, the Web Accessibility Coordinator and Committee should work with OGC to facilitate Department of Education, Office of Civil Rights (OCR), review and approval of the proposed training.
      • 5.3.2. All staff, faculty and student employees who create, maintain, post or distribute Online Content as part of their official University functions will:
        1. Complete the annual training requirements defined by the Web Accessibility Committee; and
        2. Inform the Web Accessibility Coordinator if/when they come across Online Content that may not be accessible.
    • 5.4. Exceptions
      • 5.4.1. Units and programs seeking an exception to this Policy will:
        1. Submit a written request to the Web Accessibility Coordinator explaining in detail why compliance is not feasible and how, if exempted from one or more provisions of this Policy, the Online Content in question will be made accessible to individuals with disabilities in an equally effective manner; and
        2. Recognize that the law requires equally effective access for individuals with disabilities. This includes the ability to access information with the same spontaneity and independence as others. For example, if the content in question is freely available on the web, then it is not sufficient to provide an alternative that restricts the time of day during which the information may be accessed or that requires an individual with a disability to request assistance. Likewise, offering accommodations for inaccessible Online Content on a case-by-case basis does not qualify as providing equally effective access.
      • 5.4.2. The Web Accessibility Coordinator will:
        1. Review each request for an exception to ensure that the proposed approach provides equal and effective access; and
        2. Submit a recommendation to the Web Accessibility Committee.
      • 5.4.3. The Web Accessibility Committee will:
        Consider each request and recommendation referred to it by the Web Accessibility Coordinator and approve or deny the request.
  6. Penalties
    • 6.1. Online content found to be in violation of this Policy should be referred to the Web Accessibility Coordinator, who will contact the responsible unit to begin remediation procedures. The University reserves the right to remove any non-compliant content if the violation is not addressed in a timely manner.
    • 6.2. Individuals found to be repeatedly posting or distributing Online Content in violation of this Policy may be required to complete additional training or repeat the annual training program described in section 5.3 of this Policy. Subsequent violations may result in suspension of access to create, edit, or publish online content on the University’s web systems and/or other disciplinary action in accordance with University Policy.
  7. FAQs
    • 7.1. Whom do I contact if I have a concern about web accessibility or need assistance with making my Online Content accessible? Contact the Web Accessibility Coordinator. See Section 5.2.2.
    • 7.2. How do I report inaccessible Online Content? Students, prospective students, employees, guests, and visitors may report violations of the University’s technical standard(s) by filing a formal complaint with OIE through its Section 504 and Title II grievance procedures (available at http://wmich.edu/equity/reporting-forms) and/or by contacting the Web Accessibility Coordinator. See Section 5.2.2.
    • 7.3. How do I know if third-party Online Content that I link to through my presentation/course materials complies with this Policy? Contact the Web Accessibility Coordinator to request an evaluation of the content. See Section 5.2.2.
    • 7.4. What if the Online Content I want to use is not, and cannot be made, accessible? Contact the Web Accessibility Coordinator for information on requesting an exception to this Policy. See Section 5.4.