Electronic and Information Technology Accessibility Policy

The University at Buffalo (UB, university) is committed to ensuring equal access to information that is presented electronically. As part of this commitment, digital content must be accessible to everyone, including individuals with physical, sensory or cognitive impairments, with or without the use of assistive technology.

The university must designate an individual to serve as Electronic and Information Technology (EIT) Accessibility Officer. The EIT Accessibility Officer coordinates the university’s efforts to ensure accessible EIT and to remediate inaccessible digital content. Individual schools and administrative areas must designate one or more individuals to serve as Web Accessibility Liaisons to coordinate EIT accessibility efforts in their respective areas.

All EIT must conform to the requirements of the Electronic and Information Technology Accessibility Policy Guidance, except where doing so would impose a fundamental alteration or undue burden as established through the Exceptions section of this policy. This includes, but is not limited to, EIT that is created by UB or procured through vendors. It also includes external websites, services, and digital content required to access UB programs and activities. Accessibility standards include the following:

• Minimum standards developed by the State University of New York as follows:
  • Web Accessibility Standards
  • Digital Content Accessibility Standards
    
  • Classroom Accessibility Standards
    
  • Library Accessibility Guidelines
    
  • Procurement Accessibility Standards
    
• Web Content Accessibility Guidelines (WCAG)
  
• Standards for hardware accessibility (e.g., printer kiosks, ATMs, vending machines)
  

Archived electronic and digital content is not required to meet accessibility standards, but the university will provide an accessible version of archived web content or an equally effective, alternative means of accessing the content upon request. Individuals who wish to access inaccessible archived web content must contact Equity, Diversity and Inclusion (EDI). An EDI representative will process the request to access archived materials within five business days. EDI will either provide an accessible version of the archived materials or reasonable accommodations that will afford equally effective, alternative access to its content.

EDI serves as the President’s designee for considering exceptions to this policy. Limited exceptions may be granted by EDI in specific instances where compliance is not possible or would constitute an undue administrative or financial burden, or where it would create a fundamental alteration. Departments requesting an exception must provide equally effective, alternative access to ensure that, to the maximum extent possible, individuals with disabilities receive the same benefits or services as their nondisabled peers. Exception requests must be accompanied by a written statement describing how the department will provide equally effective, alternative access.

Any hardware, software, programs, or other EIT procured from vendors must be accessible when the information technology will be used by members of the university community to access university programs, services, or activities.

The university will review purchases and renewals of EIT in accordance with the Procuring Technology Requirements.

Individuals who believe that there is a violation of this policy should contact EDI, which will investigate the complaint. An individual who files a complaint will be protected against retaliation.

This policy is in accordance with federal and state laws, regulations, and policies requiring accessibility and equal access for individuals with disabilities. These laws and policies include the Americans with Disabilities Act (ADA), Section 504 of the Rehabilitation Act of 1973, and the New York State Human Rights Law.

This policy:

• Applies to all university units
• Applies to all EIT, including online content, electronic documents, software, and hardware, whether created internally or procured through a vendor
• Expects that the university community will make reasonable efforts to ensure that EIT is accessible to everyone

This policy does not apply to individual web pages published by students, employees, or non-university organizations that are not hosted by the university and do not conduct university-related business. Individuals and organizations responsible for these web pages are encouraged to adopt the university’s accessibility standards.

Accessible

Able to be used by all individuals, including individuals with disabilities, with or without assistive technology.

Archived Web Content

Web content that: (1) is at a minimum five years old; (2) is maintained exclusively for reference, research, or recordkeeping; (3) is not altered or updated after the date of archiving; and (4) is organized and stored in a dedicated area or areas clearly identified as being archived.

Assistive Technology

Any software or hardware that allows access to information or content for individuals with disabilities. Examples include special input devices (e.g., head or foot mouse, speech recognition), screen-reading software, and screen magnifiers.

Electronic and Information Technology (EIT)

Information technology and any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information. EIT includes, but is not limited to, information resources such as internet and intranet websites, content delivered in digital form, search engines and databases, learning management systems, classroom technologies; web, computer and mobile-based applications allowing for interaction between software and users; and services employing information technology and telecommunications equipment.

Equally Effective Alternative Access

An alternative format or medium that communicates the same information in as timely and effective a fashion as does the original format or medium. For interactive or service pages, equally effective means the end result is accomplished in a comparable time and with comparable effort on the part of the requestor. To provide equally effective alternative access, alternatives are not required to produce the identical result or level of achievement for persons with and without disabilities, but must afford persons with disabilities equal opportunity to obtain the same result, to gain the same benefit, or to reach the same level of achievement, in the most integrated setting appropriate to the person’s needs.

Fundamental Alteration

A change so significant that it affects the essential nature of the instruction, program, or activity provided.

Undue Administrative or Financial Burden

A significant disruption, expense, or difficulty posed by the provision of accessible information technology. When a department is concerned that the provision of accessible information technology will pose undue financial or administrative burdens, it must proceed according to the Exception procedure in this policy.

Web Accessibility Liaison

University personnel who have received training in web accessibility and serve as unit-level contacts to coordinate accessibility efforts in their respective areas.

Web and Digital Content

The textual, visual, or aural content that is encountered as part of the user experience on websites, applications, software, email, social media, etc. It may include, among other things, text, images, sounds, videos, and animations. For purposes of this policy, web content also includes forms and documents accessible through UB websites.

Web Content Accessibility Guidelines (WCAG)

A series of standards developed by the World Wide Web Consortium (W3C) that promotes usability and best practices to ensure web access for individuals with disabilities. WCAG provides a common definition for accessible content.

• Ensure that EIT in their areas complies with the university’s Accessibility Standards.
• Follow the university’s Procuring Technology Requirements when purchasing EIT.
• Designate one or more Web Accessibility Liaisons.

• Develop new and redesigned websites, forms, documents, videos, and other content on public-facing university websites that are accessible and conform to the university’s Accessibility Standards.
• Test websites for accessibility prior to their launch or significant modification.
• Test existing websites for accessibility, and ensure that inaccessible web/digital content, forms, documents, videos and other online content published prior to the date of this policy are remediated or replaced.
• Provide reasonable accommodations to individuals who request access to inaccessible archived web/digital content. This may include remediating inaccessible content or providing content in reasonably convenient and equally effective alternative accessible formats. 
• Follow the university’s Procuring Technology Requirements when purchasing EIT.

• Ensure that instructional materials are developed in conformance with the university's Accessibility Standards.

• Ensure that websites or applications used in course instruction meet the university’s Accessibility Standards.
• Follow the university’s Procuring Technology Requirements when purchasing EIT.

• Design and plan for accessibility in information technology hardware, software, and systems, and remediate accessibility issues within these systems.
• Follow the university’s Procuring Technology Requirements when purchasing EIT.

• Investigate complaints of non-compliance with this policy.
• Consider and determine exception requests.
• Consider exceptions as the President's designee.
• Assist with identifying equally effective, alternative means of access when granting exceptions.
• Manage the university’s Procurement Accessibility Review Process.
  

• Coordinate the university’s efforts to ensure accessible EIT and to remediate inaccessible digital content.
• Communicate EIT accessibility information, policies, and initiatives across university divisions and departments.
• Monitor compliance with standards.
• Collaborate with Web Accessibility Liaisons to ensure accessibility of digital content.
• Provide training and educational resources to university personnel.

• Serve as unit-level contacts for the EIT Accessibility Officer.
• Coordinate accessibility efforts for their area.