POL-U1600.07 Ensuring Accessible Electronic Information Technology

The Director, Office of Civil Rights and Title IX Compliance is responsible for ensuring compliance with this policy.

1. Employees, including students working in an official Western capacity, who create, maintain, or otherwise manage and/or operate digital content for an official Western purpose are subject to and have responsibilities to meet Western’s commitment under this policy, which include, but are not limited to, completing the website accessibility training and as editing responsibilities increase, take additional training commensurate with responsibilities.
2. Employees who purchase, acquire, and/or use, to the extent practicable, hardware and/or software products shall follow information technology purchasing guidelines
3. Employees who create content within the university Learning Management System (LMS) must complete required training opportunities as set forth by the IT Accessibility Committee

The University relies on a combination of responsibilities within the following units to ensure compliance with this policy:

1. The IT Accessibility Committee is tasked with:
   1. Developing standards and guidelines/processes in consultation with the ADA Coordinator.
   2. Coordinating the evaluation and procurement of enterprise covered technology
   3. Overseeing and coordinating the University's efforts to provide training and education on policy compliance to faculty, staff, and students
   4. Reviewing and authorizing requests for exceptions to the policy in consultation with the ADA Coordinator.
2. Web Communication Technologies (WebTech) is tasked with:
   1. Maintaining standards for website accessibility, submitted to the IT Accessibility Committee in consultation with the ADA Coordinator.
   2. Maintaining the training modules for all Western website content editors
   3. Maintaining and monitoring the website barrier reporting mechanism.
3. ATUS is tasked with:
   1. Maintaining standards for Learning Management System (LMS) accessibility, submitted to the IT Accessibility Committee
   2. Maintaining the LMS accessibility training
   3. Coordinating LMS support
4. The Disability Access Center is tasked with:
   1. Providing accommodations for students with disabilities, including but not limited to converting digital documents to braille.
5. The Dean of Libraries or designee is tasked with:
   1. Responsibility for Library technologies and databases
   2. Maintaining the E -Resource Accessibility Evaluation Procedure.

This policy applies to the University acquisition of covered technology, procured, developed, substantially modified, or enhanced, including software available at no cost. All such acquisitions must be submitted to Business Services who will then forward for appropriate review, evaluation, and approval the requested covered technology to the appropriate offices and other resources to ensure it is accessible by individuals with disabilities, either directly or by supporting the use of assistive technology.

Alleged violations of this policy and/or accessibility-related complaints should be reported to the ADA Coordinator/Office of Civil Rights and Title IX Compliance using the PRO-U1600.02A Discrimination Complaint Procedure.

As part of the complaint process, violations will be referred to the IT Accessibility Committee by the ADA Coordinator for assistance with remediation or replacement. Remediation may include removal of non-compliant material until compliant with this policy.

Exceptions to this policy may be granted where full compliance would impose an undue burden, when an accessible format constitutes a fundamental alteration to the nature of the program, service, or activity; or when the creation of an accessible version is not otherwise possible.

Individuals or departments seeking an exception to procure inaccessible covered content must make that request to the IT Accessibility Committee, who will consult with the ADA Coordinator.