Accessible Electronic and Information Technology Policy

Policy Approval Authority President
Responsible University Office Ethics and Compliance Office
Responsible Officer(s) Information Technology Accessibility Officer
Contact Person Katy Whitelaw
Primary Audience Faculty
Staff
Administration
Status Active
Last Review Date 05-18-2021
Policy Category/Categories Faculty & Academics
Finance / Risk Management
Human Resources / Employment
Information Technology
Student Affairs

Policy Narrative

NIU is committed to providing an accessible, usable, and integrated experience for all people. Therefore, NIU requires that all electronic and information technology (EIT) procured, developed, maintained or used be accessible, as defined in applicable law, so that all members of the NIU community can make the fullest use of its EIT. NIU relies on administrators, faculty and staff to work toward providing equal access to all EIT. When NIU procures, develops, maintains, or uses EIT, it will identify the needs of users with disabilities to determine:

  • How users with disabilities will perform the functions supported by the EIT; and
  • How the EIT will be developed, installed, configured and maintained to support users with disabilities.

Purchasers, developers and maintainers of EIT at NIU are required to abide by the Illinois Information Technology Accessibility Act (IITAA), the IITAA 2.0 Standards, and the IITAA 2.0 Techniques for EIT developed, procured, or substantially modified by NIU on or after January 18, 2018.

For EIT procured and developed before January 18, 2018, and not modified after January 18, 2018, NIU is required to use the IITAA 1.0 Standards, IITAA Implementation Guidelines for Web-Based Information and Applications, and the IITAA Procurement Recommendations for compliance with the IITAA. NIU encourages university developers and purchasers of EIT to strive to meet the IITAA 2.0 Standards and Techniques even for EIT developed or purchased before January 18, 2018 where reasonable.

The IITAA defines EIT as “electronic information, software, systems, and equipment used in the creation, manipulation, storage, display, or transmission of data, including internet and intranet systems; software applications; operating systems; video and multimedia; telecommunications products; kiosks; information transaction machines; copiers; printers; and desktop and portable computers.”

EIT at NIU must be accessible to people who are

  • Blind or have a visual impairment
  • Deaf or hard of hearing
  • Unable to use a mouse
  • Unable to use a keyboard
  • Wheelchair users

Accessible means that a person with disabilities is able to independently use electronic and information technology, in the same time frame as those without disabilities, to

  • acquire the same information
  • engage in the same interactions
  • enjoy the same services

Primary Audience

  • University EIT purchasers, developers, maintainers and users
  • Procurement Services and Contract Management
  • Division of Information Technology (DoIT) – IT Steering Committee – End User Technologies Sub-Committee
  • Colleges, departments, units, distributed IT personnel

Compliance (Rules / Regulations)

Roles and Responsibilities

  • Procurement Services and Contract Management (PSCM) includes accessibility language in purchase agreements for EIT orders that it handles.
  • The Division of Information Technology Steering Committee includes accessibility assessments that are in compliance with the IITAA and its applicable regulations, in its Architecture Review of products created in-house.
  • University purchasers of EIT are responsible for identifying purchases that are subject to this policy (i.e. electronic and information technology). Purchasers must request a Voluntary Product Accessibility Template (VPAT) from the vendor of the EIT. The purchaser must request an accessibility assessment from the ITAO when the VPAT shows deficiencies in accessibility.
  • The Disability Resource Center may be consulted on student needs, especially requests for reasonable accommodations in order to address a disability situation.
  • Academic Diversity, Equity and Inclusion may be consulted on employee needs, especially requests for reasonable accommodations in order to address a disability situation.
  • PSCM, ITAO, and the DoIT Steering Committee are committed to meeting on a regularly occurring basis to discuss best practices, workflow, and compliance. The Information Technology Accessibility Officer (ITAO) makes recommendations regarding the accessibility of EIT purchases and/or development, especially when the accessibility of a product is unknown. The ITAO assists with assessing the accessibility of EIT and creation of an equally effective alternative when necessary if an exception is made. The ITAO may be consulted when accessibility assessments are conducted and will provide training to the campus community on EIT accessibility.

Procedures

In purchasing EIT, PSCM or the purchasing department will consider at minimum the following:
  • Accessibility shall be a factor in scoring during Requests for Proposal or sole source decision-making.
  • Sufficient degrees of accessibility must be certified by the vendor. Traditionally this is accomplished through a completed Voluntary Product Accessibility Template (VPAT) 2.0 or higher (doc). If the VPAT or other information indicates that the EIT is not accessible, the ITAO shall be consulted to determine whether to procure the technology, or whether an exception applies. Final decisions on whether EIT is appropriately accessible are made by the ITAO. The ITAO may consult with other appropriate persons or entities when making such determinations.
  • IITAA Procurement Recommendations must be reviewed and adhered to, where applicable.
  • Pursuant to NIU Procurement Certification 3.24, the vendor of EIT is required to certify that information technology, including electronic information, software, systems and equipment, developed or provided under this contract comply with the applicable requirements of the IITAA Standards 2.0.

IITAA Additional Purchasing Resources are also available for consideration.

In developing or maintaining/updating current EIT, DoIT will include accessibility in its Architectural Review. In addition, standards, implementation guidelines, techniques, and procurement recommendations under the IITAA 2.0 must be reviewed and adhered to, where applicable. Those authorities are as follows:

Exceptions

NIU purchasers and/or purchasing departments can seek exceptions to the requirement to make EIT accessible, as defined under applicable law.

The law recognizes these exceptions:

  • There is no accessible alternative.
  • The product is the industry standard and therefore required.
  • An equivalent accessible product is much more expensive (the dollar amount is not specified in the law).
  • The product is not public-facing.
  • The product will be used by a small known group of people who do not have a disability that will prevent them from using it.

The EIT Accessibility Exception Acknowledgment and Plan for an Equally Effective Alternative forms on file will serve as a record of the fact that the product is an exception to our accessible technology standards.

Procedural History of the Policy

Accessible Technology Policy adopted 1/1/2016

Policy on Purchasing, Developing, Maintaining and Using Accessible Electronic and Information Technology adopted 1/18/2018

The two policies were combined in May 2021.

Contact Us

Policy Library
815-753-5560
policy-library@niu.edu 

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