UMB Procedure Web Accessibility

Information Technology   |   Approved October 4, 2019

Purpose

The UMB Policy on Web Accessibility was established to promote an accessible University environment online. This Procedure describes and specifies the steps a Site Owner may be required to take in order to comply with X-99.22(A) UMB Policy on Web Accessibility. It also details the steps any unit can take to improve the accessibility of its Official UMB Websites, and the help that is available to support this process. All capitalized terms in this Procedure shall have the definitions assigned to them in the UMB Policy on Web Accessibility, which shall be incorporated into this Procedure by reference.

Applicability

Employees, students, or volunteers on campus involved in Web Based Content at UMB.

Instructions

Identifying a Site Owner for an Official UMB Website

Per X-99.22(A)UMB Policy on Web Accessibility, a Site Owner is the designated role or individual responsible for an Official UMB Website or application, as determined by the cognizant Dean, Vice President, Chair and/or Director of a University unit. Site ownership is best assigned to a role, instead of to individual people whose role can change over time. Site Owners may not have the knowledge and skills to directly address the accessibility of the Official UMB Web site they own. They are, however, responsible for the accessibility of these Websites by holding accountable content creators, developers, Suppliers, and others whose assistance is needed to ensure the accessibility of the site and/or application.

Managing Content on a UMB Website

To meet the requirements of the UMB Policy on Web Accessibility, Official UMB Websites must be in compliance with our standards. Information regarding web accessibility can be found on the following UMB websites:

Center for Information Technology (CITS) Accessibility Guidelines for Application Developers

https://www.umaryland.edu/cits/service-catalog/application-development/accessibility/

Office of Communications and Public Affairs (OCPA) Web Accessibility

https://www.umaryland.edu/web-accessibility/

Office of Educational Support and Disability Services

http://www.umaryland.edu/disabilityservices/

Evaluating a UMB Website for Accessibility

Evaluating an Official UMB Website for accessibility can be handled in multiple ways. It is recommended to apply a variety of approaches. CITS can assist with accessibility testing, including identifying reputable Suppliers. For more information on accessibility testing, visit the UMB Accessibility Resources.

Automatic scanning

The use of automatic scanning tools such as Silktide is recommended as a quick way to determine a rough level of accessibility; however, these tools cannot be relied on as the only means of assessment.

Manual checklist

A variety of manual checklists suited for developers, as well as visual designers and content creators, are available on the Accessibility Manual for umaryland.edu. Checklists can be simple and quick guides to identify the most common accessibility issues, or extensive documents which lead a development team through a full review.

User testing

User testing can identify accessibility challenges that may render a site or web-based service difficult for people with disabilities to use. Assistive technology should be used as part of user testing.

Expert review

CITS can assist with identifying reputable Suppliers for those wishing to have a third-party expert to validate accessibility. After review, Suppliers can either remediate the issue or provide guidance to the site’s developers and/or content creators on remediation.

Requesting an Exemption

When compliance is not feasible because it meets one or more of the approved exceptions listed in the UMB Web Accessibility Policy, an Accessibility Exemption Request form must be completed. Site Owners are responsible for the accessibility of the site and/or system; however, the schools and administrative departments (content providers) are responsible for monitoring the content.

An Accessibility Exemption request can be completed by a site owner, content creator, developer, supplier and/or individual responsible for the Website and/or application. Before an exemption is granted, the completed form must be reviewed and approved, at their discretion, by the Site Owner of the affected unit, CITS, and Educational Support & Disability Services. CITS will maintain a record of approved exemption requests in a database.

When an exemption is granted, factors such as who will be responsible for fixing the issues, timeframe allocated to address them, and the resources that will be needed will be determined based on the technology and audience affected. It will be the responsibility of the site owner to monitor and follow-up on exemptions while they are being addressed and completed.

Acquiring Accessible Software and Professional Services

The Supplier Selection Process
It is important to consider accessibility from the beginning of the software or service acquisition process. This includes software and web-based services that may be free or built in-house or by Suppliers. Waiting until the later stages of the acquisition or development process may fail to uncover an accessible solution with the desired functionality and features. When purchasing or otherwise acquiring a web application, whether via a software license or professional services, fill out the Web Accessibility Feedback form to inform the Site Owner, so they can work with the respective unit sponsor and CITS to evaluate the accessibility of applicable deliverables and/or services. Web applications should be in compliance with WCAG 2.0 level AA guidelines. Site Owners must complete and submit an approved exemption form with their requirement to Strategic Sourcing and Acquisition Services in those instances when requesting acquisitions not in compliance WCAG 2.0 level AA guidelines.

If the acquisition is by Request for Quotes or Invitation for Bids and requires WCAG 2.0 Level AA, this requirement cannot be waived once quotes and/or bids are received. If the acquisition is by Request for Proposals and WCAG 2.0 Level AA is a mandatory requirement, the University may waive the requirement if in the best interest of the University and the contract for the product may include a roadmap with target dates for the product to achieve full compliance.

Implement Roadmap to Accessibility Compliance

When the contract includes target dates for a Supplier to achieve full compliance with WCAG 2.0 Level AA, it is the Site Owner’s responsibility to contact a Supplier and inquire about adherence to their roadmap. If a Supplier is not cooperative, engage Strategic Sourcing and Acquisition Services for assistance. If the site is free or based on work done by a Supplier or in-house, the Site Owner is responsible for ensuring the roadmap target dates are met. When the product is accessible, the Site Owner will submit notification of compliance via the Web Accessibility Feedback form. CITS will maintain a record of compliance notifications.

Reporting and Responding to Accessibility Issues

Accessibility Statement
UMB Websites should contain the words “Web Accessibility” in the footer or any visible location that will link to a common institutional Web page that contains the following statement: “The University of Maryland Baltimore is committed to equal access to Web content. If you need to request Web content in an alternative format or have comments or suggestions on accessibility, use the Web Accessibility feedback form. For more information about accessibility at UMB, visit
https://www.umaryland.edu/web-accessibility/."

Site Owner Responsibilities

Site Owners must ensure their Official UMB Website(s) complies with the Web Accessibility Policy.

If a Site Owner receives a complaint directly, they should immediately report it via the Web Accessibility Feedback form.

Site Owners shall treat all accessibility issues with a sense of urgency. Address any time-sensitive need of the user promptly (generally within a period of no greater than two business days), unless technology or work involved requires more effort. If Site Owners are unable to address the accessibility need of a user promptly, they must contact the Office of Educational Support and Disability Services. In all cases, accessibility issues must be reported via the University Web Accessibility Feedback form.

If the Office of Educational Support and Disability Services, in consultation with the Site Owner, determines that the information or service provided on an Official University Website cannot be made accessible, or that doing so would constitute an undue burden, the Office of Educational Support and Disability Services will engage with the user and Site Owner to determine alternative methods for providing the information or service. In the event that an alternative format or service cannot be provided or the user is not satisfied with the results, the UMB General Counsel’s Office may be called upon for assistance.

Available Assistance

Strategic Sourcing and Acquisition Services (SSAS)
SSAS can hold Suppliers accountable for accessibility. SSAS will coordinate with Site Owners to provide assistance with the purchase of accessible solutions. For more information regarding the acquisition of web applications, please complete the Web Accessibility Feedback Form.

Training and Support

To assist staff, faculty, and students in meeting the responsibilities described in this document, UMB will make training and support readily available, including a Website devoted to providing information regarding Web Accessibility.

The training and support will include specific information for staff, faculty, and students who are responsible for creating, selecting, or maintaining Web pages and web-based content in any University program, service or activity. The training and support will also include instructions on how to make Websites accessible, how to both manually check and use automated tools to ensure the accessibility of content therein, and how to get assistance.

Consulting

On-campus consulting will be made available for designing and implementing Websites that meet accessibility guidelines and for evaluating the accessibility of existing sites and those under development. If such assistance is needed, please visit the Web Accessibility Website.

Financial Responsibility

The responsibility for assuring that an Official University Website is accessible, including providing required funds, rests with the cognizant Dean, Vice President, Chair and/or Director of a University unit. Consideration of the costs related to creating accessible web-based information and services early in the development or procurement process will help Site Owners plan their budgets appropriately. For help thinking through the financial impact of making your site, information or service accessible, complete the Web Accessibility Feedback Form.