Web Accessibility Policy

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

All new, newly-added, or modified online content and functionality published after the effective date of this policy must be accessible and conform to Web Content Accessibility Guidelines 2.0 Level AA and Web Accessibility Initiative – Accessible Rich Internet Applications Suite Guidelines, except where doing so would impose a fundamental alteration or undue burden as established through the Exceptions procedure contained in this policy.

Web accessibility guidelines include the following:

• Websites must have content that is accessible with a screen reader.
• Websites must include alternative text for any non-text content that conveys meaning (e.g., pictures, graphs).
• Websites must be able to be navigated through use of a keyboard, as an alternative to mouse navigation.
• Websites must not rely on color to convey meaning.
• Websites must provide captions or transcripts for all audio or video content.

Websites, forms, documents, videos, and other online content published prior to the date of this policy must be remediated by November 15, 2019 in accordance with UB’s Web Accessibility Policy Guidance.

Archived web content is not required to meet the web accessibility standards in this policy, 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.

Limited exceptions may be granted by EDI in specific instances where compliance is not possible or would constitute undue administrative or financial burdens, or where it would create a fundamental alteration. Departments requesting an exception must provide to EDI a description of the university resources available for use in the funding and operation of the service, program, or activity, accompanied by a written statement certifying the reasons for requesting an exception, including the cost of meeting the requirement and the available funding and other resources. In determining whether compliance would pose an undue administrative or financial burden, EDI will consider university-wide resources available for achieving compliance, and not limit consideration to departmental resources.

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 information technology (IT) 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.

• Vendors must describe how their IT products and services are accessible to users, including individuals who use assistive technology.
• Vendors must complete a Voluntary Product Accessibility Template Version 2.0 (VPAT).  The VPAT must contain sufficient detail and explanation to convey how the product meets accessibility requirements. The VPAT must be submitted to EDI for review and approval prior to purchase.

Individuals who believe that there is a violation of this policy should contact EDI. 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 university websites, with the exception of archived web content, whether they are created, designed, or maintained internally or by a vendor
• Expects that the university community will make reasonable efforts to ensure that online content 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.

Alternative Text

Also known as “alt text,” a word or phrase that can be inserted into an HTML document that tells viewers the nature or content of an image.

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.

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.

Screen Reader

Software that allows a computer to identify and convert text to speech.

Undue Administrative or Financial Burdens

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.

Voluntary Product Accessibility Template (VPAT)

A document which evaluates how accessible a particular product or service is. It is a self-disclosing document, produced by a vendor, which details each aspect of web accessibility requirements and how the product adheres to each criteria.

Web Accessibility Initiative – Accessible Rich Internet Applications Suite Guidelines (WAI-ARIA)

A series of standards developed by the World Wide Web Consortium (W3C), the primary international standards organization for the internet, that promotes ways to make web content and web applications more accessible to people with disabilities. WAI-ARIA focuses on dynamic content and advanced user interface controls developed with Ajax, HTML, JavaScript, and related technologies.

Web Content

The textual, visual, or aural content that is encountered as part of the user experience on websites. 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 W3C that promotes usability and best practices to ensure web access for individuals with disabilities.

• Ensure that web content in their areas complies with this policy.
• Ensure that any information technology products purchased to access university programs, services or activities are accessible by (1) requiring vendors to describe how their IT products and services are accessible to users, including individuals who use assistive technology; and (2) requiring vendors to submit a VPAT.

• Develop new and redesigned websites, forms, documents, videos, and other content on public facing university websites that are accessible and conform to WCAG 2.0 Level AA and WAI-ARIA.
• Test websites for accessibility prior to their launch or significant modification.
• Check existing websites for accessibility, and ensure that inaccessible web content, forms, documents, videos, and other online content published prior to the date of this policy are remediated or replaced by November 15, 2019.
• Provide reasonable accommodations to individuals who request access to inaccessible archived web content. This may include remediating inaccessible content or providing content in reasonably convenient and equally effective alternative accessible formats.  
• Ensure that any information technology products purchased to access university programs and activities are accessible by (1) requiring vendors to describe how their IT products and services are accessible to users, including individuals who use assistive technology; and (2) requiring vendors to submit a VPAT.

• Ensure that instructional materials are developed in conformance with WCAG 2.0 Level AA and WAI-ARIA.

• Ensure that websites or applications used in course instruction are accessible.
• Ensure that any information technology products purchased to access university programs, services or activities are accessible by (1) requiring vendors to describe how their IT products and services are accessible to users, including individuals who use assistive technology; and (2) requiring vendors to submit a VPAT.

• Design and plan for accessibility in information technology hardware, software, and systems, and remediate accessibility issues within these systems.
• Ensure that any information technology products purchased to access university programs, services or activities are accessible by (1) requiring vendors to describe how their IT products and services are accessible to users, including individuals who use assistive technology; and (2) requiring vendors to submit a VPAT to EDI for review.

• Investigate complaints of non-compliance with this policy.
• Consider and determine exception requests.
• Assist with identifying equally effective, alternative means of access when granting exceptions.
• Review and assess VPATs.