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Procedures and Procurement for Digital Accessibility

  1. Responsibilities
    1. All personnel responsible for existing NYU websites and content must use good faith efforts, subject to the requirements and exceptions of the applicable laws, to bring these websites, content and applications into conformance with WCAG 2.0 AA.
    2. Researchers applying for federal or other grants that create public websites at NYU or that result in publicly available videos must include the cost of accessibility in their grant proposals. For videos this means captioning. NYU IT Accessible Technology Services can advise on the costs.
    3. All units at NYU are responsible, with guidance from Procurement, for ensuring that requests for proposals, contracts or other service arrangements for the acquisition of digital technology include requirements to adhere to NYU web accessibility standards (currently WCAG 2.0 AA). For IT services (websites, content, applications) that are broadly used by NYU, a School/Campus or unit, the IT service provider is encouraged to independently validate the product accessibility rather than relying solely upon the vendor’s assertions. If more than one service is available and meets some, but not all, of the relevant provisions of WCAG 2.0 AA, the service that best meets the standard should be procured unless an exception is granted (see Exception Process)
    4. New and Pre-Existing Content: The Digital Accessibility Program will periodically and randomly audit NYU websites and provide information to enable schools and units to remediate inaccessible content as deemed necessary. Tools will be provided for each unit webmaster to test their websites and content. Units will be accountable for remediation of their websites and content.
    5. On an ongoing basis, NYU IT’s Accessible Technology Services will continue to test NYU websites and content for accessibility and report accessibility issues to the webmaster for that website. Any features found to be inaccessible must be remediated promptly.
    6. All NYU website footers must contain a link labelled “Accessibility” that links to the accessibility feedback webpage. Any individual who is unable to fill out the form at this site can email accessibility.feedback@nyu.edu with the request or complaint.
    7. The Moses Center will continue to seek input from NYU students regarding accessibility issues, and will continue to facilitate equal access to programs and services for students with disabilities throughout the schools and divisions of NYU and to foster independent decision making skills necessary for personal and academic success.
    8. The Office of Equal Opportunity (OEO) will continue to function as NYU's Americans with Disabilities Act (ADA) Coordinator, serving as a resource regarding reasonable accommodations in the workplace.
  2. Implementation Schedule
    1. New Content: NYU websites and newly published content (including captioning of videos) should conform to WCAG 2.0 AA by August 1, 2018.
    2. Pre-Existing Content: NYU websites and content (including captioning of videos) published after 1/1/2015 and not included in item 2.1, must conform to WCAG 2.0 AA by September 1, 2020.
    3. Upon a specific request by an individual with a disability, the University will update Legacy pages (anything published prior to 1/1/2015) to be in compliance with the WCAG 2.0 Level AA standard, or the University will otherwise make the content available to the individual in a timely manner and in an equally effective accessible format.
  3. Evaluating Digital Accessibility
    1. Evaluating a University Website for accessibility can be handled in multiple ways. It is recommended to apply a variety of approaches. NYU IT can assist with accessibility testing. For more information on accessibility testing, visit the NYU Accessibility website.
      1. Automatic scanning
        The use of automatic scanning tools such as WAVE, aXe, or HTML CodeSniffer is recommended as a quick way to determine a rough level of accessibility; however, these tools are insufficient as the only means of assessment.
      2. Manual checklist
        A variety of manual checklists suited for developers, as well as visual designers and content creators, are available on the NYU Digital Accessibility website. 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.
      3. 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. Training is available on assistive technology use, and Accessible Technology Services can assist with the review.
      4. Vendor assertions
        Working with Procurement, Accessible Technology Services can advise on whether or not third-party applications/services are accessible. See the Procurement section for more information.   

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  4. Complaints Associated with Digital Accessibility
    1. The accessibility feedback webpage states NYU’s position on digital accessibility and allows individuals to request that a website or content be made accessible, or to make a complaint. The requestor will get an immediate response that the request/complaint was received. The complaint or request will be provided to the webmaster or contact for the particular content or website, or to the Moses Center or OEO as appropriate.
    2. Recognizing the ongoing evolution of current web content and technologies, the designated webmaster or content owner for a particular site, upon being made aware of an accessibility issue concerning that website, application or content, should proceed as follows:
      1. Verify that the issue is an authentic accessibility issue.
      2. Treat all issues as important. Address any time-sensitive need of the individual promptly (generally within a period no greater than two business days), unless technology or work involved requires more effort, in which case the user will be promptly notified in writing of expected delivery.
      3. If, in consultation with the website's webmaster or content owner, it is determined that the content or website cannot be made accessible, or that doing so would constitute a fundamental alteration or present an undue burden, OEO or the Moses Center, as appropriate, will engage in an interactive process with the user about alternative methods for providing the information or service and will provide an equally effective alternative format or service, if one is available. In the event that an alternative format or service cannot be provided or the user is not satisfied with the results, he or she may contact the ADA/Section 504 Compliance Officer for assistance in resolving the issue.
  5. Requesting an Exception to NYU Website Accessibility Policy and Procedures
    1. Exceptions to the accessibility requirements set forth in the NYU Website Accessibility Policy and Procedures may be requested where the unit head believes that compliance would constitute an Undue Burden or Fundamental Alteration as defined in the Policy. In such cases, the unit head (Chair, Dean or VP) must complete the Digital Accessibility Exception Request form.
    2. Requests must include a written statement from the unit head explaining the basis for reaching the conclusion that compliance would constitute an Undue Burden or Fundamental Alteration, including the cost of meeting the requirement and the available funding. Requests must also include a description of how the unit will provide Equally Effective Alternative Access – i.e., other action that would not result in an Undue Burden or Fundamental Alteration but would nevertheless ensure that, to the maximum extent possible, individuals with disabilities have equally effective access to the benefits or services provided by the University as their non-disabled peers.
    3. Requests for an exception will be reviewed by the Digital Accessibility Program lead, in consultation with the Office of General Counsel, the Moses Center for Students with Disabilities, or the Office of Equal Opportunity, as necessary, and make a recommendation to the University President or an individual designated by the University President who has budgetary authority.
  6. Implementation Assistance
    1. Guidelines and best practices are available from the NYU Digital Accessibility website. In addition, on-campus assistance is available for designing and implementing websites that meet accessibility guidelines and for evaluating the accessibility of existing sites and those under development.
    2. Training is available for a variety of web developer, content creator, and faculty roles. Please refer to the Training section of the NYU Accessibility website.
    3. Guidance on best practice is available for a variety of web developer, content creator, and faculty roles. Please refer to the Training section of the NYU Digital Accessibility website. 

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  7. Procurement Process and Checklist
    1. Digital accessibility compliance means NYU has afforded individuals with disabilities an equal opportunity to participate in University programs and activities. It is important that everyone involved in the procurement process of information and communication technology, especially web products or services from third parties, ensure policy compliance. This encompasses purchases for everything including software or systems that can store, manage, control, manipulate or retrieve information for human interaction, and also videos, web content and communications products.
    2. The procurement selection process for web products and services (e.g., a website, mobile application, or related platform to develop, host or otherwise manage or provide any technology or online component) supplied by third parties intended for use or access by NYU students, alumni, faculty, staff, applicants, prospective students, or members of the public generally will take into account the level of accessibility support and the effort that NYU would need to undertake to address accessibility shortcomings present in the product or service.
    3. All content, interfaces, and navigation elements to be used by the University must be compliant with the Americans with Disabilities Act of 1990, as amended; Section 504 of the Rehabilitation act of 1973, as amended; and WCAG 2.0 AA standard.
    4. We encourage you to complete Digital Accessibility Purchasing Interest form early in your planning process. Someone in the Digital Accessibility Program or Procurement will be in touch to help guide you through the process of ensuring the University's accessibility requirements are met.
    5. Accessibility Procurement Checklist: The following sections provide detail about addressing accessibility in each step of the procurement process.
      1. A quick checklist is provided for easy reference:
        1. Contact the IT Accessibility Liaison to participate in the accessibility procurement process.
        2. Include text in the RFP or other procurement process that requires the supplier to submit information about the accessibility of the IT product or service, including test results, preferably including results obtained by users with disabilities.
        3. Seek contractual provisions in which the vendor agrees to promptly remediate accessibility concerns resulting from the vendor’s product and to indemnify the University against such claims where necessary.
        4. Require the supplier to demonstrate the accessibility of the product, perhaps by having a member of a disabled community use the product in the demonstration.
        5. Use the standard NYU Terms and Conditions for Goods and Services, which require accessibility.
        6. Have an IT accessibility expert review IT accessibility requirements and expectations with the selected supplier before installation or project initiation.
        7. Establish procedures to test software updates for accessibility, submit complaints about the product or service via procurement, and ensure issues are promptly remedied.
        8. Provide feedback to your IT Accessibility Liaison about addressing accessibility through the procurement process.
      2. Standard Set of Questions for requesting departments to ask themselves
        1. What does the product and/or services do and how are we using it?
        2. Is this a new purchase or renewal?
        3. How many people use or will be using this product and/or service? How many faculty/staff, how many students, how many members of the general public?
    6. RFI/RFQ/RFP Requirements
      1. NYU has adopted WCAG 2.0 AA for web based content. A product or service will be considered by NYU to have met this standard based on a review by NYU and/or when the supplier demonstrates to NYU that the work clearly meets the standard through documented accessibility testing. Supplier proposals, quotes, or bids should describe the accessibility testing process and may include, but are not limited to: code reviews by internal or external experts, evaluations with accessibility checking software, vendor test bedding with assistive technologies, testing by users with disabilities, or testing by a third party organization.
      2. The following questions must be included in any RFP bid document for web products and related services: (Please note that if you are working with Procurement and managing the RFP through our Sourcing Director Portal then these questions will be included)
        1. Provide your company’s policy or commitment statement regarding electronic accessibility.
        2. Do you have an accessibility function or team responsible for technical development? Describe its role in your organization.
        3. How does your company achieve compliance with IT accessibility standards?
        4. Describe the testing protocols you use to assess the accessibility of your product?
        5. Can you provide live or prerecorded demonstrations of the accessibility of your product?
        6. Has your company ever worked with accessibility as a functional requirement?
        7. What is your company’s level of involvement with users with disabilities and use of assistive technology in conducting testing? Explain the conformance testing process and identify the range of disabilities and assistive technologies.
        8. What experience do your developers have coding for accessibility?
        9. What standards are followed for coding of interfaces, both for administrators and end-users, that are part of your product or service (if 508, what parts; if WCAG 2.0, which level)?
        10. What are the details of the accessibility standards that the product or service meets (for example, the W3C Web Content Accessibility Guidelines (WCAG) 2.0 AA) and what is the supporting evidence of the testing process undertaken to assess standards conformance?
        11. If the product or service supports web content creation, what is the evidence of level of support for the W3C Authoring Tool Accessibility Guidelines (ATAG) 2.0?
        12. Does your company have a road map for accessibility going forward? If so, provide a general outline (e.g., goals, milestones).
        13. Have you tested and/or developed your mobile apps (especially iOS and Android) with accessibility in mind?
        14. If NYU finds that there are changes that need to be made to web/mobile interfaces/apps, what guarantee can be made to the University that these changes will be implemented to NYU’s satisfaction prior to go-live/going forward?
        15. What are the details of any areas where the product or service does not meet one of the above-referenced standards and what are any interim solutions or roadmap dates by which conformance will be achieved?
        16. If it is determined that the product or service is not fully accessible after the purchase, do you agree that remediation of the site or content will be done in a reasonable agreed-upon timeframe at no charge to NYU?
        17. Will your company provide the indemnity (below) to protect the University against legal action related to failures in accessibility?
        18. Please provide your company’s Voluntary Product Accessibility Template (VPAT) for your product or service?
      3. If the product is fully accessible, the supplier must provide that information (e.g. a URL to the accessibility statement or VPAT 2.0, or an email stating that it is fully compliant) with their response. If the supplier provides a VPAT and it has sections labeled as “Supports with Exceptions” or “Not Supported,” then the product is not fully accessible. If a VPAT is not available, but the supplier provides an accessibility statement, it should state clearly if the product is fully accessible or compliant, with Section 504 of the Rehabilitation Act, as amended, or (if web based content) WCAG 2.0 AA.
      4. For each area of noncompliance, suppliers are strongly encouraged to describe any planned remediation roadmaps, including any timelines and steps that will be taken to achieve full compliance, as well as interim workarounds to enable access by individuals with disabilities.
    7. Supplier Demonstration and Tests
      1. Supplier finalists should be required to provide demonstrations during their bidder presentation to support their statements about the accessibility of their products and/or services.

        Demo Requirements:
        In your demo, please show how your online product/service is accessible to users with different disabilities, including visual, hearing, and motor control.

        The demo should include but not be limited to:
        1. Navigating the content with only a keyboard (no mouse)
        2. Displaying captions on videos
        3. Navigating the content using headings (using screen reading software)
        4. Bringing up all the links on a page (using screen reading software)
        5. Sufficient color contrast
        6. Alternative text for images
        7. No pictures of text
        8. Scalable text
        9. No keyboard traps for video controls
        10. Visual cues to identify where the cursor is on the page/slide
        11. Completing at least one task from start to finish with a screen reader (e.g., complete a form)
        12. Technical issues – A quick reference guide to some of the technical accessibility issues we check for is available on our website.
    8. Decision Making and Exceptions
      1. If the supplier is unable to provide any information on the accessibility of the product, then the University should look for another product which is fully accessible that meets its business needs. In the event that no product which meets its business needs is fully accessible, or the product that does meet its business needs does not have a VPAT or a statement of accessibility, then an Accessibility Exception request should be made.
      2. Once the exception request is received, it will be reviewed and every effort will be made to make a final decision in six business days following receipt. The initial requestor will be sent an email with the final decision. If the exception is granted, it is approved for two years.
    9. Contract
      1. All purchases must include NYU’s standard accessibility language. This will ensure that vendors are accountable for the accessibility of their product.

        Online Accessibility
        To the extent that the Services include the development of online content and/or functionality for any NYU programs, services, or activities, Seller agrees that such content and/or functionality will be accessible to individuals with disabilities as measured by conformance with the W3C's Web Content Accessibility Guidelines (WCAG) 2.0 Level AA, with the exception of audio description.

        Upon request, Supplier will provide information about conformance with applicable accessibility standards via the Voluntary Product Accessibility Template (VPAT). Supplier agrees to promptly respond to and resolve any reasonable complaint regarding accessibility of its services, deliverables, and/or products, and each party agrees to provide reasonable cooperation to the other with regard to such responses and resolutions.
      2. For questions about or issues with contract language, please work with Procurement, OGC, or email the Digital Accessibility Program.
    10. Post Purchase
      1. Once the product and/or service have been purchased, it is important for IT accessibility experts to meet with the supplier, before installation or project initiation, to review accessibility requirements and expectations.
      2. It also is important to clarify how product/service accessibility will be maintained throughout the life of the contract. This includes establishing procedures to
        1. Re-test new versions/updates.
        2. Evaluate and duplicate any complaints.
        3. Communicate complaints to the supplier via the Procurement team.
        4. Verify that issues have been remedied.
        5. Alert the IT Team if there are significant accessibility problems with products widely used at NYU.
        6. Provide feedback to the IT Team about suppliers, products, and the purchase process to help improve these guidelines.                                      

 

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