| CORNELL UNIVERSITY POLICY LIBRARY |
POLICY 5.11 Volume: 5 Chapter: 11 Responsible Executive: Vice Presidents of Information Technologies and Communications Responsible Office: Vice Presidents of Information Technologies and Communications Originally Issued: Revised: |
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DRAFT University Policy 5.11, Web Accessibility |
I. Policy Statement
All official Web pages within the Cornell University Web space, including but not restricted to those within the cornell.edu domain, those paid for with university funds, and/or those residing on university servers, subject to exceptions enumerated in this policy, must, by adopting as a minimum all requirements of Section 508 of the Rehabilitation Act of 1973, be made accessible to the widest range of users, including those with the more common sensory, motor and cognitive disabilities.
II. Reason For Policy
Cornell University is committed to a diverse and inclusive educational and work environment that encompasses its presence on the World Wide Web. Moreover, a Cornell Web accessibility policy comports with Cornell's founding motto, "Where any person can find instruction in any study." Consequently, the university recognizes that accessible design is good web page design generally and that the benefits of accessibility accrue to all web users globally whether or not an individual has a specific disability.
III. Entities Affected By This Policy
- All Units of the University including the Weill Cornell Medical College
IV. Who Should Read This Policy
All members of the university community
V. Website Address For This Policy
[Cornell University Policy Office to complete]
VI. Related Documents
| University Documents | Other Documents |
|---|---|
| University Policy 6.13, Disability Accommodation Process | Rehabilitation Act of 1973 (Pub. L. 93-112) Americans with Disabilities Act |
VII. Contacts
| Subject Matter | Office Name | Telephone Number | Email/URL |
|---|---|---|---|
| Policy Clarification | Director of IT Policy | 254-3584 | IT-policies@cornell.edu |
| Policy Clarification | Director of Web Communications | 255-1290 | univcomm.cornell.edu/ webcommunications |
VIII. Definitions
| Section 508 standards for accessibility | Web design standards established through federal law and regulation under the Rehabilitation Act of 1973. See appendix for a detailed list of those standards. |
| Web Page | A (web) document rendered by an (xhtml/html) markup language, independent of its transmission protocol (http) and user agent (browser/reader). |
| Web Application | Any software that delivers dynamically generated content intended to be rendered in a web browser. |
| Web Accessibility | The practice of making Web pages accessible to all users, especially those with disabilities, by applying specific principles for Web page design and programming that enable assistive technologies to function properly. |
| Assistive Technologies | Adaptive, rehabilitative devices, whether acquired commercially or off the shelf, modified, or customized, that promote greater independence for individuals with disabilities by changing how these individuals interact with technology. Assistive technologies include special input devices, such as a head or foot mouse, and screen-reading software, which can read aloud for the user the details of material displayed on a monitor. |
| Web Site | Any collection of Web pages residing under a single domain and whose content is centered around a single organizational unit or workgroup, a university course, a research or business activity, or an area of academic content. |
| Official Web Site | A web site that has been created or sponsored by the university, its schools, departments, units, or other administrative offices and that is used in the process of conducting official University business. In addition, Web applications—both those developed in-house and those purchased from outside vendors—are considered official. |
| Unofficial Web Site | A site published by an individual such as a student or a university employee, or by a non-university organization, which is hosted on university servers but does not conduct university business. These include:
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| Cornell Web Space | The entire collection of Web sites whose purpose for existence can be legitimately connected with Cornell University activities, including academic, research, and outreach activities. A Web site may reside on a non-Cornell Web server, or may not have a cornell.edu domain name, but may still be considered part of the Cornell Web space. |
| Archival Web Site | A web site that is (a) intended to represent a historical snapshot of a course, research project, or other Web information, and (b) not used to gather or disseminate information about any current course, currently active research project, or current administrative function of the university. |
| Web Site Redesign | Any phase during the development or maintenance of a Web site in which significant alteration or update is made to the visual design, institutional branding, information architecture, or technical functionality of the site. Minor content updates are not considered Web site redesign projects. |
IX. Responsibilities
| Party | List of Responsibilities |
|---|---|
| Unit Heads | Provide necessary support within the unit for compliance with this policy. |
| Web Developers | Design all web sites under the purview of this policy, i.e. those conducting university business, subject to exceptions, according to section 508 standards for accessibility. |
X. Principle
This document proposes that Cornell University approve the development of a policy to adopt Web accessibility standards for official Web sites that are paid for with Cornell University funds and/or hosted on its servers. The federal government requires its agencies to comply with the Rehabilitation Act of 1973, 29 U.S.C. 794d, "Section 508" (29 U.S.C. 794d, subpart B 1194.22 "Web-based intranet and internet information and applications").
Currently, higher education is not required to comply with these standards. This proposed policy initiates proactive adoption of these standards in anticipation of federal mandate. More important, a Cornell Web accessibility policy comports with our founding motto, "Where any person can find instruction in any study..."
Web accessibility standards evolve with technology. Currently, the two most widely accepted standards for Web accessibility are the aforementioned Section 508 and the Web Content Accessibility Guidelines (WCAG) of the World Wide Web Consortium (W3C). Cornell has chosen Section 508 standards because they are the legal standards required of all federal agencies and may well represent the standards that higher education may be expected to adopt if compliance were to branch out to educational institutions or the public sector.
This policy divides the Cornell University web space into sectors for the purpose of creating zones of compliance, exceptions, and time lines for implementation as outlined in the procedures section below.
XI. Procedures
A. Official Cornell Web Space to Which Web Accessibility Requirements Will Apply
This policy proposes that the following areas of Cornell Web space be required to adopt Section 508 standards:
- Administrative
- Central unit sites — www.cornell.edu and central administrative unit sites
Academic unit sites — college and department sites constructed for marketing and university business functions - Academic
- Teaching
Course sites
Research
Course collaboration tools
Pages created by students to fulfill academic requirements which also fall within one or more of the official categories listed herePublic presentation of research results online
Outreach
Sites created for the purpose of conducting research by collecting data from human subjects
(Note the exemptions below for research collaboration sites and for sites created to conduct research or experiments in developing or utilizing new technologies and applications for the Web)Outreach program sites
Professional organizations
Collaborative sites - Information Repositories
- Collections
Databases
B. Official Cornell Web Space to Which Web Accessibility Requirements Will NOT Apply
- Web applications for which no accessible functionally equivalent alternative exists
- Research collaboration sites
- If these sites or Web pages fulfill any university purpose other than the conduct of research (example: also serve as a course Web page), then alternate accessible sites or Web pages must be provided.
- Sites and Web pages created to conduct research or experiments in developing or utilizing new technologies and applications for the Web
- Sites and Web pages created to experiment with new workflow processes that involve Web tools
- Once a tool moves beyond an experiment and becomes an accepted part of a workflow process, that tool must comply with this policy.
- Whole-course capture sites (automated videotaping or audio recording of every class session)
- Any site intended for use by fewer than 25 people
- Archival sites
- Undue burden: compliance with this proposed policy would interfere significantly with the site owner's teaching, research or service mission
XII. Enforcement
Routine audit procedures for university policy.
Appendix
A. Web Accessibility Requirements
In accordance with Section 508, for the above categories of Cornell Web space, the following will be required of Web developers. This list is taken directly from the Section 508 provisions, which can be found at www.section508.gov/Web.
- A text equivalent for every non-text element shall be provided (examples: via "alt," "longdesc," or in-element content).
- Equivalent alternatives for any multimedia presentation shall be synchronized with the presentation.
- Web pages shall be designed so that all information conveyed with color is also available without color. For example, from context or markup.
- Documents shall be organized so they are readable without requiring an associated style sheet.
- Redundant text links shall be provided for each active region of a server-side image map.
- Client-side image maps shall be provided instead of server-side image maps, except where the regions cannot be defined with an available geometric shape.
- Row and column headers shall be identified for data tables.
- Markup shall be used to associate data cells and header cells for data tables that have two or more logical levels of row or column headers.
- Frames shall be titled with text that facilitates frame identification and navigation.
- Pages shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.
- A text-only page, with equivalent information or functionality, shall be provided to make a Web site comply with the provisions of this part, when compliance cannot be accomplished in any other way. The content of the text-only page shall be updated whenever the primary page changes.
- When pages utilize scripting languages to display content or create interface elements, the information provided by the script shall be identified with functional text that can be read by assistive technology.
- When a Web page requires that an applet, plug-in, or other application be present on the client system to interpret page content, the page must provide a link to a plug-in or applet that complies with §1194.21(a) through (l).
- Online forms shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.
- A method shall be provided that permits users to skip repetitive navigation links.
- When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.
Notes:
- Section 508 includes the following provision: "A text-only page, with equivalent information or functionality, may be provided to make a Web site comply [with Section 508 requirements], when compliance cannot be accomplished in any other way. The content of the text-only page shall be updated whenever the primary page changes." In short, providing a fully accessible, text-only alternative with equivalent information or functionality will satisfy accessibility requirements under this proposed policy.
- This proposed policy does not cover the accessibility of sites outside Cornell University to which a Cornell University page might be linked. Sites outside the Cornell Web space containing required content for courses should be reviewed for accessibility before making the course assignments, and faculty will advise students of available accommodation for any inaccessible content assigned. In the case of equivalent content being available from multiple sources, faculty will give preference to the accessible alternative.
Appendix B. Timing Requirements for This Policy
This proposed policy should be promulgated as soon as is practicable within the normal parameters of university policy development. Risks that attach to a failure to promulgate include potential future legal liabilities, impediments to forming effective collaboration with academic and non-academic partners (examples: research, government, corporate, and community), barriers in communication to external audiences (examples: prospective students, media, and the academic community), and dilution of the university's outreach mission.
Timeline for Implementing Web Accessibility Standards:
| Implementation Deadline | Web Page(s) or Site(s) to Comply |
|---|---|
| Within one year of promulgation | All new and redesigned1 Web sites published by any university college, department, or program |
| Within two years of promulgation | All official administrative and academic instructional Web sites |
| Within three years of promulgation | All academic research and outreach Web sites |
| Within three years of promulgation | All large-scale Web applications developed completely within the university, by any university college, department, program, or unit All licensed or open source Web applications not purchased by Cornell but in use within the Cornell Web space |
| Within three years of promulgation, or upon the next renewal of contract with the vendor | All Web applications purchased from an external vendor2 or obtained under contract with other institutions |
| Within five years of promulgation | All official Web sites (subject to exceptions) |
Notes:
- As noted in the "Definitions" section above, Web site redesign refers to any phase during the development or maintenance of a Web site in which significant alteration or update is made to the visual design, institutional branding, information architecture, or technical functionality of the site. Minor content updates are not considered Web site redesign projects.
- If the vendor does not offer a compliant product, all market alternatives must be explored.