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1.1. This policy establishes that Clemson University’s (“University”) digital realm is a place where all community members — regardless of their abilities — can share and receive meaningful contributions.
\r\n\r\n1.2. This policy supports the University’s commitment to inclusive excellence by
\r\n\r\n1.2.1. providing accessible Information and Communication Technology (ICT) resources to help ensure equal access to educational services, programs, and activities regardless of disability; and
\r\n\r\n1.2.2. removing barriers to knowledge by ensuring that everyone’s presence is valued.
\r\n\r\n1.3. This policy supports the University’s requirement to provide accessible ICT in accordance with federal and state laws, including but not limited to the Americans with Disabilities Act of 1990 (ADA) and the Rehabilitation Act of 1973.
\r\n\r\n2.1. This policy applies to all University employees who create, design, purchase, implement, or develop ICT used to conduct University business (hereinafter referred to as “responsible personnel”).
\r\n\r\n3.1. Accessible ICT is a key component in ensuring the University’s commitment to fostering an inclusive environment. Providing accessible ICT resources is the responsibility of all members of the University community.
\r\n\r\n3.2.1. The University’s Director of Digital Accessibility is authorized to establish University requirements and processes for conformance with digital accessibility standards.
\r\n3.2.2. As such, the Director of Digital Accessibility has established an ICT Accessibility Review Board that is responsible for:
3.2.2.1. Overseeing implementation of this policy.
\r\n3.2.2.2. Periodic review and updates to this policy.
\r\n3.2.2.3. The review and approval of exceptions to this policy.
3.2.3. Responsible personnel are required to conform with the established University ICT Accessibility Standards when conducting University business.
\r\n\r\n3.3.1. The University has adopted the following standards and guidelines to provide accessible ICT:
\r\n\r\n3.3.1.1. The Web Content Accessibility Guidelines (WCAG) 2.1 Level AA and the Web Accessibility Initiative Accessible Rich Internet Applications Suite (WAI-ARIA) for all Web-based ICT.
\r\n\r\n3.3.1.2. Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies (WCAG2ICT).
\r\n\r\n3.3.2. Expectations to meet these standards include, but are not limited to, providing captions for multimedia, providing alternative text for images, and using software that is compatible with keyboard navigation and assistive technologies.
\r\n\r\n3.4.1. Failure to meet the standards set by this policy may result in significant liabilities, sanctions, and financial penalties for the University.
\r\n\r\n3.4.2. The ICT Accessibility Review Board will review inaccessible ICT and may recommend or require, up to and including, that ICT be:
\r\n\r\n3.4.2.1. removed until it complies with this policy, or
\r\n\r\n3.4.2.2. brought into compliance by designated staff or contractors with the understanding that the expense of that work may be charged to responsible personnel’s department(s).
\r\n\r\n3.4.3. For questions regarding conformance to this policy, contact the Director of Digital Accessibility.
\r\n\r\n3.5.1. Responsible personnel seeking an exception to this policy must submit a written request to the Director of Digital Accessibility. The request must detail why conformance is not feasible and how responsible personnel will make ICT available to individuals with disabilities in an equally effective alternate format. Exceptions will be handled on a case-by-case basis.
\r\n\r\n3.5.2. Circumstances that may qualify as an exception to this policy include the following:
\r\n\r\n3.5.2.1. Where conformance is technically infeasible or may cause an undue burden.
\r\n\r\n3.5.2.2. Where conformance would result in a fundamental alteration of the resource, application, service, course, or program and not satisfy the original intent.
\r\n\r\n3.5.2.3. Where ICT is procured through third party vendors or contractors and no alternative accessible products are available.
\r\n\r\n3.5.2.4. Where ICT does not currently conform to accessibility standards, but proven remediation efforts are underway to fix accessibility defects within an approved timeline.
\r\n\r\n3.6.1. Accessibility issues can be reported online via the Barrier Report Form.
\r\n\r\n3.6.2. To identify as an individual with a disability to receive accommodations, students may register with Student Accessibility Services and employees may register with the Office of Access Compliance and Education (ACE).
\r\n\r\n3.6.3. Accessibility Resources and Contacts are available for individuals who need assistance.
\r\n\r\n3.6.4. Any person who believes they have been denied or excluded from participating in or receiving the benefits of any program or activity of the University, including employment decisions, due to accessibility barriers may file a complaint of discrimination with the University based on the Non-Discrimination and Anti-Harassment policy by completing the On-Line Incident Report Form.
\r\n\r\n4.1. Accessible ICT: people with disabilities can use, perceive, understand, and interact with ICT.
\r\n\r\n4.1.1.The U.S. Office for Civil Rights states that accessible “means a person with a disability is afforded the opportunity to acquire the same information, engage in the same interactions, and enjoy the same services as a person without a disability in an equally effective and equally integrated manner, with substantially equivalent ease of use. A person with a disability must be able to obtain the information as fully, equally, and independently as a person without a disability. Although this might not result in identical ease of use compared to that of persons without disabilities, it still must ensure equal opportunity to the educational benefits and opportunities afforded by the technology and equal treatment in the use of such technology.”
\r\n\r\n4.2. Equally Effective Alternate Format: provides access to ICT for persons with disabilities; is based on timeliness of delivery, accuracy of translation, and delivery in a manner and medium appropriate to the disability of the person.
\r\n\r\n4.2.1. Equally effective alternate formats are not required to produce the identical result or level of achievement for disabled and non-disabled persons, but must allow disabled persons equal opportunity to obtain the same result, to gain the same benefit, or to reach the same level of achievement, in the most integrated setting appropriate to the person’s needs.
\r\n\r\n4.3. Individual with a Disability: an individual with an ADA covered disability that substantially limits one or more major life activities.
\r\n\r\n4.4.Information and Communication Technology (ICT): any electronic resources used for instruction, information distribution, or communication. ICT resources include, but are not limited to, instructional systems, online instructional lessons, Web-based services, software applications, electronic documents, computers, hardware systems, telecommunication products, video and multimedia products, mobile devices, information kiosks, transaction machines, and online events.
\r\n\r\n4.5. Fundamental Alteration: a change to a service, program, or activity that is so significant that it modifies the essential nature of the service, program, or activity offered.
\r\n\r\n4.6. Undue Burden: Undue financial and administrative burdens may be created when a proposed course of action causes significant difficulty or expense. Because the standard for finding undue financial and administrative burdens is high, the decision to invoke undue financial and administrative burdens will be carefully evaluated and if appropriate, sufficiently documented.
\r\n\r\n4.7. University Business: For the purposes of this policy, University business refers to business and academic activities, the delivery of content, or the interaction with individuals for administrative, instructional, or informational purposes.
\r\n\r\n5.1. Accessibility Resources and Contacts
\r\n\r\n5.2. Barrier Report Form
\r\n\r\n5.3. Clemson University Accessibility Portal
\r\n\r\n\r\n\r\n5.5. Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies
\r\n\r\n5.6. U.S. Department of Justice Guidance on Web Accessibility
\r\n\r\n5.7. Web Content Accessibility Guidelines
\r\n\r\n5.8. Web Accessibility Initiative Accessible Rich Internet Applications Suite (WAI-ARIA)
\r\n\r\n\r\n\r\n
6.1. CCIT (2802), Director of Digital Accessibility
\r\n\r\n6.1.1. The Office of Access Compliance and Education supports this policy’s compliance with state and federal regulations.
\r\n\r\n7.1. Director of Digital Accessibility: 864-656-8987
\r\n\r\n7.2. Student Accessibility Services: 864-656-6848
\r\n\r\n7.3. Office of Access Compliance and Education (ACE): 864-656-3181
\r\n\r\n7.4. Ethics/Safety Hotline: 877-503-7283
\r\n\r\n8.1. President Approval: 09/12/2023
\r\n\r\n8.2. Last Date of Revision: 09/12/2023
\r\n\r\n8.3. Originally Issued: 12/19/2018
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