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Information Technology

Web Accessibility (VII.C.1)

Volume VII: Information Technology
Chapter C: World Wide Web
Responsible Executive: Vice President for Ethics and Compliance
Responsible Office: Office of Institutional Equity
Date Issued: March 15, 2010
Date Last Revised: November 18, 2011

TABLE OF CONTENTS

Statement of Policy
Reason for This Policy
Individuals and Entities Affected by This Policy
Who Should Know This Policy
Exclusions
Web Site Address for This Policy
Contacts
Definitions
Responsibilities
Procedures
Related Documents, Forms, and Tools
History and Updates
Appendices

STATEMENT OF POLICY

All new and Redesigned Web Pages published by any Purdue University college, school, department, program, or unit on or after the effective date of this policy must conform to the United States Access Board’s Electronic and Information Technologies Accessibility Standards and this policy. All Legacy Web Pages published prior to the effective date of this policy must conform to these accessibility standards no later than March 15, 2014. The time frames for achieving compliance are included in the Procedures section of this policy. Progress toward achieving and maintaining fully accessible Web pages must be documented on annual status reports.

This policy applies to all official Web pages and associated Web-based services developed by or for a college, school, department, program, or unit of Purdue University. Nothing in this policy is intended to prevent the use of designs or technologies as alternatives to those prescribed in the standards, provided they result in substantially equivalent or greater access to and use of a Web site by people with disabilities.

REASON FOR THIS POLICY

The creation and dissemination of knowledge is a defining characteristic of universities and is fundamental to Purdue University's mission to promote learning, discovery, and engagement. The use of digital and Web-based delivery of information is increasingly central to carrying out the University’s mission. Acknowledging this fact, Purdue University is committed to ensuring equal access to information for all its constituencies.

This policy establishes minimum standards for the accessibility of Web-based information and services considered necessary to meet the University’s goal and ensure compliance with applicable law.

INDIVIDUALS AND ENTITIES AFFECTED BY THIS POLICY

Any Purdue University college, school, department, program, or unit that publishes a Web site or page. This includes individual faculty who publish Web pages for university related business.

WHO SHOULD KNOW THIS POLICY

President
Chancellors
Vice Presidents
Vice Chancellors
Vice Provosts
Deans/Directors
Department Heads/Chairs
Faculty
Staff
Students
Non-employee (third party) users of remote access to university IT resources

EXCLUSIONS

Individual Web pages published by students, employees, or non-university organizations that are hosted by the University and do not conduct university related business are encouraged to adopt the University's policy and standards, but fall outside the jurisdiction of this policy.

Archived Web Pages do not have to be converted to the standard unless specifically requested by an individual with a disability. See the Procedures section of this policy for appropriate steps to take if a request is made.

Where compliance is not technically possible or may require extraordinary measures due to the nature of the information and the intent of the Web page, a request for exception must be made in writing to the Equal Opportunity Officer for the campus. Such requests must be based on issues other than cost alone.

WEB SITE ADDRESS FOR THIS POLICY

www.purdue.edu/policies/information-technology/viic1.html

CONTACTS

Subject Contact Telephone E-mail/Web Address
Policy Clarification Director, Office of Institutional Equity (765) 494-7253 www.purdue.edu/ethics/oie
Accessibility Concerns/Request for Exception Calumet Campus
Director for Equal Employment Opportunity/Diversity
(219) 989-3169
Fort Wayne Campus
Equal Opportunity/Affirmative Action Officer
(260) 481-6106 www.ipfw.edu/eoaa/
North Central Campus
Equal Opportunity/Affirmative Action Officer
(219) 785-5545
(800) 872-1231 Ext. 5241
www.pnc.edu/cd/Policy/index.html
West Lafayette Campus
Director, Office of Institutional Equity
(765) 494-7253 www.purdue.edu/ethics/oie

DEFINITIONS

Archive Web Site or Page
A Web site or page no longer in use but subject to records retention plans.

Equal Opportunity Officer
For purposes of this policy, this role is filled for each campus by the following individuals:

  • Fort Wayne: Equal Opportunity/Affirmative Action Officer
  • Calumet: Director for Equal Employment Opportunity/Diversity
  • North Central: Equal Opportunity/Affirmative Action Officer and Special Assistant to the Chancellor
  • West Lafayette: Director, Office of Institutional Equity

Legacy Web Page
A Web page published prior to the effective date of this policy.

Purdue University (the University)
Any campus, unit, program, association, or entity of Purdue University, including but not limited to Indiana University-Purdue University Fort Wayne, Purdue University Calumet, Purdue University North Central, Purdue University West Lafayette, Purdue Cooperative Extension Service, and Purdue University Statewide Technology.

Redesigned Web Page
A Web page where significant alteration or update is made to the visual design of a page or a major revision of the content of a page takes place.

RESPONSIBILITIES

Vice President for Ethics and Compliance
Initiate a review of and make necessary revisions to this policy at least once every two years.

Equal Opportunity Officer
Review campus status reports for compliance with this policy.

Review requests for exception to this policy on a case-by-case basis.

Colleges, schools, departments, programs, or units of Purdue University
Publish new or Redesigned Web Pages in compliance with this policy.

Revise all Legacy Web Pages according to the time frames outlined in this policy.

Submit annual status reports to the campus Equal Opportunity Officer.

Respond to requests by disabled individuals for access to a Legacy or Archive Web Page.

PROCEDURES

Compliance Requirements and Time Frames

  1. All new and Redesigned Web Pages published on or after the effective date of this policy must be in compliance with the U.S. Access Board’s Electronic and Information Technologies Accessibility Standards and must indicate in plain text a method of contact for users with disabilities having trouble accessing content within the site. The contact information is typically a phone number and/or e-mail address that puts the user in touch with the person(s) responsible for the content and function of the page who can usually reply within one business day

    Suggested language:

    “Copyright © 20__, Purdue University, all rights reserved. Purdue University is an equal access/equal opportunity university.  If you have trouble accessing this page because of a disability, please contact [insert job title] at [insert phone number and/or e-mail address].

  2. By July 1, 2010, all Legacy Web Pages must indicate in plain text a method of contact for users with disabilities having trouble accessing content within the site as outlined in Section A above.
  3. In addition to Section B above, all Legacy Web Pages must be revised to be in compliance with the U.S. Access Board’s Electronic and Information Technologies Accessibility Standards. Priority must be given to creating accessible Web pages for core institutional information pertaining to students, faculty, staff, alumni, retirees, and visitors. Units with large Web sites containing core institutional information must establish priorities for ensuring access to these pages based on time, sensitivity of function, and frequency of use. Decisions regarding the order in which Legacy Web Pages are revised are made by following the implementation priorities below. Each college, school, department, program, or unit of the University is responsible for determining which of their Legacy Web Pages fall into the percentages listed.
    1. The top 25% of Legacy Web Pages that are used most frequently (i.e., that get the largest number of hits) must be in compliance within one year of the effective date of this policy (March 15, 2011).
    2. Pages required for participation, funding, disability-related services, and other key pages needed by individuals with disabilities not already in the top 25% must also be in compliance within one year of the effective date of this policy (March 15, 2011).
    3. Remaining Legacy Web Pages must be in compliance according to the following schedule:
      • Next 25% by March 15, 2012 (50% of Web pages in compliance)
      • Next 25% by March 15, 2013 (75% of Web pages in compliance)
      • Next 25% by March 15, 2014 (100% of Web pages in compliance)

Specific Requests for Access

Upon specific request for access by an individual with a disability, Legacy Web pages must be made accessible, or an equally effective alternative provided, within 10 business days of receiving the request. The unit responsible for the creation and maintenance of the information on the Web page is responsible for making it accessible. Equally effective means that the alternative communicates the same information in as timely a fashion as does the original Web page. For interactive or service pages, equally effective means that the end result (e.g., registration) is accomplished in a comparable time and with comparable effort on the part of the requestor. If the context of the information or service the page provides cannot be made accessible within 10 business days, this timeframe may be extended.

Upon specific request for access by an individual with a disability, Archive Web Sites and Pages containing core administrative or academic information, official records, or similar information must be updated to be in compliance or the content of the Web page(s) must be made available by another means that is accessible to the individual. The unit responsible for the creation of the information on the page(s) is responsible for providing that access within 10 business days of receiving the request. If the context of the information or service the page provides cannot be made accessible within 10 business days, this timeframe may be extended.

Reporting

Status reports must be submitted annually no later than April 1 by each college, school, department, program, or unit of Purdue University to their campus Equal Opportunity Officer beginning April 2011. The report must summarize the efforts toward achieving and maintaining fully accessible Web pages, as defined by this policy. Efforts and accomplishments over the previous year, as well as targets for the upcoming year, must be included in each report.

Policy Review

The Office of the Vice President for Ethics and Compliance will initiate a review of and make necessary revisions to this policy at least once every two years with the input of a review group. The review group will include, but not be limited to, designees from the Office of Institutional Equity, Office of the Vice President for Information Technology, Disability Resource Center, Purdue Marketing and Media, and Enrollment Management.

RELATED DOCUMENTS, FORMS, AND TOOLS

Accessibility Concerns Notification Form:
www.purdue.edu/ethics/oie/ada_concern_report.html

Policy for Purdue Pages on the World Wide Web (Executive Memorandum C-42):    www.purdue.edu/policies/information-technology/c-42.html

Purdue University Equal Opportunity Policies:
www.purdue.edu/policies/human-resources/ethics.html#equal

U.S. Access Board’s Electronic and Information Technology Accessibility Standards: 
www.access-board.gov/sec508/standards.htm

Section 508 Homepage: www.section508.gov/

Guidance, additional details and information on implementing the accessibility standards: www.purdue.edu/webaccessibility

Resources for designers and programmers in understanding and meeting the standards set by the U.S. Access Board:

HISTORY AND UPDATES

November 18, 2011: Policy number changed to VII.C.1 (formerly V.2.1) and website address updated. Hyperlinks to policies in Related Documents section also updated.

April 22, 2011: Contacts section updated.

March 15, 2010: This is the first such policy to address this issue.

APPENDIX A

Electronic and Information Technologies Accessibility Standards and Examples

Purdue University is not a federal agency and as such is not subject to the compliance requirements of Section 508 of the Rehabilitation Act of 1973, as amended (“Section 508"). However, the University chooses to set the developed Web accessibility standards provided by the United States Access Board as the University’s guidance and standards for Web accessibility.

Below are portions of the standards related to Web-based intranet and internet information and applications from § 1194.22 of Section 508. Examples for each section are indicated in italics to illustrate the requirements. We wish to thank the Web Accessibility Center of Ohio State University (http://wac.osu.edu) for the examples.

(a) A text equivalent for every non-text element shall be provided (e.g., via "alt," "longdesc," or in element content).

Examples:

  • Non-text elements (images, java applets, flash files, video files, audio files, plug-ins, etc.) have alt tag descriptions that convey the purpose or intended meaning of the object (e.g., alt tags for images used as links describe the link destination).
  • Complex graphics that summarize information (graphs, charts, tables, etc.) are accompanied by text conveying the information providing a meaningful narrative of the information.
  • Decorative graphics with no other function have empty alt descriptions (alt= ""), not missing alt descriptions.
  • When descriptions are lengthy or refer to other resources or sites, a longer description will be made available using a link or supported "longdesc."

(b) Equivalent alternatives for any multimedia presentation shall be synchronized with the presentation.

Examples:

  • Multimedia files posted to a department page have synchronized captions.
  • A Web page supporting an on-campus course presents multimedia files and provides a separate statement about requesting captioning and the instructor/department has a letter from the Disability Resource Center outlining the time frame and various responsibilities for providing captioning.

(c) Web pages shall be designed so that all information conveyed with color is also available without color, for example from context or markup.

Example:

  • If color is used to convey information, alternative indicators such as an asterisk (*), are used in conjunction.

(d) Documents shall be organized so they are readable without requiring an associated style sheet.

Examples:

  • When a document is rendered without associated style sheets, it must still be possible to read the document.
  • Provide a text equivalent for any important image or text generated by style sheets (e.g., via the “background-image," “list-style," or “content" properties).

Note: WCAG recommends using style sheets to control layout and presentation. This method is strongly preferred over the use of tables due to wider compatibility with end-user devices.

(e) Redundant text links shall be provided for each active region of a server-side image map.

Example:

  • Separate text links are provided outside of the server-side image map that links to the same content that image map hot spots access.

(f) 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.

Example:

  • Use standard HTML client-side image maps with appropriate alt tags for the image and hot spots.

(g) Row and column headers shall be identified for data tables.

Examples:

  • Tables used only for layout do not have header rows or columns.
  • In data tables, column and row headers are identified using the <th> tag.

(h) 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.

Example:   

  • Table cells are associated with the appropriate headers (e.g., id, headers, scope, and/or axis HTML attributes).

(i) Frames shall be titled with text that facilitates frame identification and navigation.

Example:

  • Each frame has a title that describes its purpose or the type of information contained within the frame.

(j) Pages shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.

(k) 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.

Examples:

  • A text-only page is acceptable when there is no other way to make the content accessible or when it offers significant advantages for ease of navigation.
  • The content for primary and text-only pages should be updated simultaneously.This process can be done using a common database to generate content for multiple versions of the same site.
  • Instead of static alternative pages, set up server-side scripts which generate accessible versions of a page on demand.
  • Text-only pages must be the functional equivalent to primary pages (e.g., provides alternatives for applets, scripts, plug-ins, and similar applications that are not directly accessible).
  • "Text-only" and "accessible" are not synonymous; designers must incorporate all of the above standards when designing text-only pages.

(l) When pages utilize scripting languages to display content, or to create interface elements, the information provided by the script shall be identified with functional text that can be read by assistive technology.

Examples:

  • Within scripts, information is text-based or a text alternative is provided.
  • All scripts (JavaScript, pop-up menus, etc.) work with keyboard-accessible alternatives (either within or outside of the script) that provide equivalent functionality.

(m) 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).

Examples:

  • When applets, plug-ins, or applications (Java applets, JavaScripts, Acrobat PDF files, or PowerPoint files) are not accessible to assistive technologies you must provide an alternative means of accessing the content within the applications (e.g., a mirror text file for a PDF file).
  • When an applet, plug-in, or application is utilized, you must provide a link to an accessible page where the plug-in can be downloaded.

(n) When electronic forms are designed to be completed on-line, the form 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.

Examples:

  • Form controls have text labels adjacent to them and keyboard access to control functionality.
  • Form elements have labels associated with them in the markup (e.g., the “id," “for," or “label," HTML elements).
  • Dynamic HTML scripting of the form does not interfere with assistive technologies.

(o) A method shall be provided that permits users to skip repetitive navigation links.

Example:

  • A link is provided to skip over lengthy lists of links (e.g., navigational menus).

(p) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.

Example:

  • Do not automatically forward, refresh, or otherwise alter pages unless you provide the user with a method to adjust the timing of these content changes.

Recommended Best Practices

Following these best practices will add functionality and usability for all users, including users of assistive technology.

Writing Style and Language

  • Try to break up large blocks of information into smaller sections to aid in navigation and readability.
  • Define the meaning of acronyms and abbreviations where they first occur in a document.
  • Identify the primary natural language of a document. Any changes in the primary natural language of a document must be identified. For example, if the natural language of a document is English and a section of the document changes to French, the French text must be clearly identified as being French.

Layout and Presentation

  • If color is used to convey information, make sure that the information is also available without color.
  • Background colors and foreground colors should provide sufficient color contrast.
  • Link text should be clear and meaningful. Avoid using "click here."
  • Provide a site map or table of contents.
  • Navigation features and style of presentation should be consistent throughout the site.
  • Style sheets should be used to create layout and presentation instead of tables.
  • Use relative units rather than absolute units in markup language attribute values and style sheet property values.
  • Use Header (H1, H2 etc.) to indicate headers and sub-headers, and use them in the correct order. Do not use headers to embellish fonts.
  • Use lists and list items properly and do not use them for layout or formatting purposes.
  • Use quotation markup for quotations and not for formatting purposes such as indentations.
  • Avoid the use of screen flicker and blinking at rates faster than 2 per second and slower than 55 per second. Flashing, flickering, and blinking of a document or document element can cause seizures in people with photosensitive epilepsy.
  • Automatic refresh and auto-redirect of pages can be confusing and disorienting to some users. Instead, configure the server to perform redirects, and create a static page that provides the new URL to direct the user to the new Web location.
  • Use W3C technologies when they are available and appropriate for a task and use the latest versions when supported.
  • Outdated elements of W3C technologies should be avoided and replaced with newer technologies. The FONT tag is an example of an outdated element that has been replaced through the use of style sheets. Refer to the W3C References for more information.

Additional Recommendations

  • It is recommended that a variety of Web browsing software (including text-only and voice output browsers), workstations, and evaluation tools be used to test access to Web pages.
  • Any university college, school, department, program, or unit should use this guidance when purchasing new forms of electronic and information technologies.

Definitions Used in Appendix A

These definitions are adopted from the Accessibility Forum’s Quick Reference Guide to Section 508 Resource Documents, dated September 15, 2003, and available at:  http://www.accessibilityforum.org/paper_tool.html

Applet
A program that is part of content and that the user agent executes.

Data Tables
Tables used to represent tabular information.

Documents
Named, structured units of text, images, or other elements; Web pages.

Equivalent Alternatives
Captioning provided for audio information, audio description of visual information, or other alternative presentations of information that fulfills the same function or purpose upon presentation to the user.

Field Element
A user interface element that appears within an electronic form field.

Flicker
An unintentional and undesirable cyclic variation in display of a screen image.

Functional Text
Text that when read conveys an accurate message as to what is being displayed by the script or that describes or what action the script will perform.

Hertz (Hz)
The international unit of frequency, equal to one cycle per second.

Multimedia Presentation
Any presentation of more than one type of media, typically both audio and visual information.

Non-Text Element
Any element that is not presented in electronically readable text and that conveys meaning that is required for comprehension of content or to facilitate navigation (e.g., an image, image of text, graphic, audio clip, or other element).

Plug-in
A program that runs as part of the user agent and that is not part of content. Users generally choose to include or exclude plug-ins from their user agent.  Note: these add-on programs or "plug-ins" can be downloaded and installed on the user's computer that makes it possible for their Web browsers to display or play the content of the files with proprietary formats when these file(s) is (are) included as a part of the Web page.

Redundant Text Link
A link that points to the same location as the active image region, or to another location that is equivalent to that referenced by the active image region.

Repetitive Navigation Links
A set of routine navigation links that appear on the top or the side of a Web page.

Scripting Language
A programming language that is used to manipulate, customize, and automate the facilities of an existing system. Note: this provision only refers to the use of scripting languages for creating and displaying dynamic Web content.

Style Sheet
A collection of formatting instructions stored in a file that determines how the layout of the documents to which it is attached is presented (e.g., displayed on screens, printed, or pronounced).

Synchronized
Having common timing and coordination of execution.

Text Equivalent
Words added as (electronically readable) text to represent the purpose of a non-text element.