Accessible Digital Content Policy

Overview

In accordance with City University of New York ("CUNY") policy, The City College of New York ("CCNY" or "the College") is committed to providing equal access and full participation to all persons with disabilities. It is a violation of this policy for any member of the College community to engage in discrimination or to retaliate against a member of the community for raising an allegation of discrimination, filing a complaint alleging discrimination, or for participating in any proceeding to determine whether discrimination has occurred. To this end, CCNY aims to ensure that all digital content designed, developed, used, or procured be accessible to anyone with a disability, including those using assistive technologies and for all members of the College community to take proactive steps to ensure compliance because creating universal design is a team effort within the university.

In accordance with the Rehabilitation Act of 1973, the Americans with Disabilities Act of 1990, New York State Human Rights Law, and all other applicable non-discrimination laws and policies adopted by CUNY, CCNY requires all members of the College community to adhere to the World Wide Web Consortium (W3C) Web Content Accessibility Guidelines (WCAG) 2.0, Level AA, and, if not explicitly stated there, any guidelines set forth by Section 508 of the Rehabilitation Act (29 U.S.C. § 794 (d)), when generating digital content.

Entities Impacted by Policy

All administrative offices, academic or research departments, student-services offices, third-party vendors, and entities receiving support by the College of any sort (e.g., funding, physical space) must adhere to this policy.

Definitions

"Digital Content" means any form of communication generated by a member of the CCNY community, but not limited to, audio, video, images, tables, forms, presentations, spreadsheets, emails (to both audiences within and outside of CCNY), documents (in any format, including .docx and .pdf), and web pages.

"Accessible" refers to tools, technologies, and techniques that allow users with disabilities to use a product or service. In terms of digital content, examples include, but are not limited to software and hardware meant to verbalize text on a screen (i.e. screen readers), enlarge text, and specialized input devices.

"Legacy digital content" means a website that is intended to represent a historical snapshot of a course, research project, or other resources that is not being actively updated.

Guidelines

All digital content generated by or used by any of the aforementioned impacted entities shall follow the WCAG 2.0, Level AA, which is organized into four principles:

  • Perceivable: Information and user interface components must be presentable to users in ways they can perceive.
  • Operable: User interface components and navigation must be operable.
  • Understandable: Information and the operation of user interface must be understandable.
  • Robust: Content must be robust enough that it can be interpreted reliably by a wide variety of user agents, including assistive technologies.

For situations not addressed by WCAG 2.0, Level AA, content must adhere to all guidelines outlined by Section 508 of the Rehabilitation Act (29 U.S.C. § 794 (d)).

All digital content must, whenever possible, be provided in an equally effective alternate format which will accurately communicate and/or provide the same level of access as the original format or medium. Examples shall include, but not be limited to, providing alternative text for images and closed captioning for video content.

Additional considerations when generating or procuring digital content or programs must include, when applicable:

  • Universal design;
  • Usage of page headers and other visual cues;
  • Sufficient color contrast;
  • Inclusion of alternative text;
  • Closed captioning of videos (done either by automatic generation and later edited, or by a third party transcription service like Rev);
  • No pictures of text except when accompanied by a corresponding caption or alternative text;
  • Navigation and controls using only the keyboard (no mouse usage);
  • Scalable text;
  • Row and column headers for tables;
  • No redundant links nor links without contextual titles
  • Printer-friendly or text-only formats;
  • Sufficient timing for all timed elements; and
  • Labels for all form elements.

When procuring any products from third-party vendors, the vendor must certify that the product(s) being purchased to meet the aforementioned criteria.

All members of the City College community are encouraged to promote awareness of this policy particularly to those in positions responsible for the creation of digital content and/or procurement of digital content and/or applications.

Exceptions

Digital content that shall be exempt from this policy shall be limited to those generated by:

  • Students, faculty, staff, College departments, departments and/or offices meant for personal or internal usage and not intended for College business;
  • Students for academic purposes, unless required by classroom or research accommodation;
  • Accreditation bodies (e.g., Middle States Commission on Higher Education), or legal entities (e.g. CUNY, State of New York); and
  • Members of the faculty and/or staff with the intention of distribution only in a physical medium (i.e., printed).

Implementation Schedule

All newly generated digital content must adhere to WCAG 2.0 AA guidelines effective immediately.

All pre-existing digital content (created prior to September 1, 2019), must adhere to WCAG 2.0 AA guidelines no later than by July 1, 2020.

All legacy digital content (digital content created before the creation of WCAG guidelines in July 2005) shall be required to be made into an accessible format upon request and in a timely manner as determined by the College’s Chief Diversity Officer.

Reporting an Issue

Any complaints regarding inaccessible digital content or a request to make digital content accessible may be lodged by any member of the CCNY community by visiting this webpage. The complainant or requestor will receive an immediate confirmation email.

The Office of Institutional Advancement and Communications and/or the Office of Information Technology shall then forward the complaint to the appropriate CCNY office to address.

The Office of Institutional Advancement and Communications and/or the Office of Information Technology may also identify any non-compliant digital content and inform the member of the CCNY community who created/uses the digital content of the non-compliance with this policy.

All complaints and requests will be addressed as promptly as possible by the appropriate parties.

Related Information and Resources

Contacts

Last Updated: 09/16/2019 13:28