CSULB Accessible Electronic and Information Technology Policy
(Campus Information Technology Committee Draft: May 4, 2006)
This policy describes an accountability framework to maintain accessible information technology at California State University, Long Beach, and all affiliated agencies of the University. Specifically, it establishes a reporting system to ensure that no qualified individual shall be denied access to information technology solely on the basis of disability. That means that every individual who is qualified to use an information technology resource shall be able to perceive the data; operate the controls; understand the user interface, and to use the technology through a robust range of access devices.
This policy applies to every student, faculty member, staff member or volunteer of the University and its auxiliary organizations who provides information using technologies as part of their operations. It applies to all information technology required for any activity, program or service that is provided by or sponsored by the University or its auxiliary organizations, including but not limited to, teaching or learning activities, application for and duties of employment, recruitment, recreational functions, personal/professional development and emergency notifications.
The policy only governs computer based technologies. These information technology resources include but are not limited to: software, electronic files, internet and web technologies, content management systems, learning management systems, computer based instructional technologies and telecommunications. It does not cover information on paper, recording tape, film, film strips, micro film or technologies for which no part of storage or rendering requires a general purpose computing device.
This policy will have a profound impact on the campus use, production and procurement of information technologies. Successful completion of this transformation will take formal planning, prioritization, timelines and periodic process audits with required remediation by entities who fail to make acceptable progress. Such a process should not place undue hardship on any campus entity, but it must constantly improve the equity of access to information technology for anyone who is entitled to the resource regardless of disability.
This policy will be accompanied by goals, guideline and standards that are reviewed and updated no less than every three years and no more than once per year by the Campus Information Technology Committee. The standards will comply with state and federal law as well as internationally recognized external standards. CSU System Guidelines on accessibility will be the baseline policy for planning and implementation. In accordance with state law and university system policy, the campus will adopt Section 508 of the Federal Rehabilitation Act as a minimum guideline (See Section 508 below). If there are disabilities that are not remedied by the 508 guidelines or CSU System Guidelines, then the campus will provide the accommodation needed to ensure equal access to informational technology resources within this class of disability.
Information technology resources accessibility shall be prioritized on the basis their importance to the mission of the university. Such prioritization cannot use disability class as a factor for prioritization.
Guiding External Policies/Standards and Federal/State Laws/Regulations
W3C (World Wide Web Consortium) Guidelines and Standards
These standards define the requirements specifications that establish information protocols, data structures and algorithms needed to maintain the World Wide Web.
Web Content Accessibility Guidelines (WCAG)
This delineates the structure of web content necessary for access by individuals with disabilities.
Authoring Tools Accessibility Guidelines
This determines the requirements of authoring tools used to create web content.
User Agent Accessibility Guidelines
This determines the requirements of browsers and media players that render web content perceivable and operable by humans.
Federal Law Rehabilitation Act
This act applies to programs and activities that receive federal assistance or are conducted by federal executive agencies. The Rehabilitation Act impacts CSULB as an employer, an educational institution, and a provider of programs, services, and activities:
- Section 503 requires affirmative action in employment of qualified individuals with disabilities.
- Section 504 prohibits denial of service and/or programs based solely on disability, and it requires reasonable accommodation to individuals with a disability through an interactive process.
- Section 508 defines specific criteria for accessible information technology.
Americans with Disabilities Act (ADA):
The ADA protects people with disabilities, regarded as being disabled, or having a record of disability, against discrimination and guarantees reasonable accommodation for qualified individuals with disabilities. Every activity/program/service on campus is covered by one of the titles of this act.
- Title I applies to employers with no less than 15 employees, state and local governments and the federal legislative branch. It protects employees and applicants against discrimination and guarantees reasonable accommodation.
- Title II (a) applies to programs and activities conducted by state and local governments. It guarantees reasonable accommodation.
- Title II (b) applies to public transportation. It guarantees reasonable accommodation.
- Title III applies to businesses and non-profits, restaurants, retail stores and private transportation. It guarantees reasonable accommodation.
- Title IV applies to campus Telecommunications
- Title V applies to issues relating to construction.
This requires publishers of textbooks to make book content available to disabled students in an e-text format. Note: This law applies to print media However, since the e-text resulting from the process is an information technology resource, it is covered by this policy.
This applies to all California Employers. It broadens definitions of disability, requires reasonable accommodation through an interactive process of dialogue between employers and employees.
This requires all public agencies to adopt Section 508 technology standard as a minimum for information technology accessibility.
This is the most current and thorough policy governing equal protection and reasonable accommodation for individuals with disabilities in the CSU System. It delineates disability policy in employment, architecture, information technology, parking, procurement and instruction. This policy is the real guideline to developing an IT Accessibility Policy. Among other things it charges campuses with developing accountability procedures for implementing IT Accessibility. Executive Order 926 has many referenced documents including documents relating to each collective bargaining unit. Critical to instructional programs is Coded Memorandum AA 2004-25 that established the California Alternative Media Project the CSU agent for implementing AB 422.
This memo sets out some very specific actions that must be taken by campuses including building an accountability system like the one described here.
Accountability (in progress)
The Policy shall include language which articulates that:
- all campus managers and supervisors are responsible for ensuring compliance with information technology accessibility policies and procedures and that
- departments/areas found through audits, incidents, reports, etc. to be in non-compliance shall take necessary steps to come into compliance within specified time limits.
Roles and Responsibilities
Operational responsibility for information access is delegated from the Chancellor to campus presidents to respective divisional vice presidents for units within each division and the respective directors for units reporting directly to the Office of the President.
The Campus Information Technology Committee will develop a biennial campus information technology accessibility plan. The plan shall provide guidelines for the campus and each of its divisions and units adequate to address all relevant laws and policies to which the campus is subject.
Each divisional vice president and unit directors shall identify an individual to be chief information technology accessibility officer (CITAO) for their respective division/unit.
The CITAO shall be responsible for:
- overseeing division/unit accessibility measures based upon guidelines issued annually by the Campus Information Technology Committee
- ensuring that all parties within the unit/division who need to be trained in accessibility measures are adequately trained
- providing an annual report to the divisional vice president and the Campus Information Technology Committee on accessibility issues.