Accessibility Policy

In accordance with the Information and Communication Technology (ICT) Standards and Guidelines under Section 508 of the Rehabilitation Act of 1973 as amended, Excelsior College is committed to ensuring accessibility in Electronic and Information Technology (EIT) and its learning resources including textbooks, labs, simulations, etc. Excelsior College strives to ensure that all individuals including those with disabilities, encompassing staff, students, faculty, and the public, have equally effective access to the services and content that the College makes available.

This policy is in alignment with:

  • The ICT Standards and Guidelines under Section 508 of the Rehabilitation Act of 1973, updated January 2017, and
  • The most current Web Content Accessibility Guidelines (WCAG) Level AA developed by the World Wide Web Consortium (W3C).
  • Excelsior College’s Mission Statement, which stresses providing educational opportunities to “…adult learners with an emphasis on those historically underrepresented in higher education” and expresses a mandate to “…meet[s] students where they are,”
  • The Excelsior CARES Credo,
  • Excelsior College’s Values, specifically “Accessibility and Completion” and “Equality and Inclusion,”

Under this policy, Excelsior College commits to:

  • Procure, develop, and maintain, EIT products and learning resources that provide equally effective access to individuals with disabilities, to the extent it does not constitute a fundamental alteration or undue burden.
  • Promote awareness of this policy to all members of the Excelsior College community, particularly those in roles that are responsible for creating, selecting, or maintaining electronic content, applications, text books, etc.
  • Uphold appropriate and timely training and resources for the Excelsior College community, which is necessary to support this policy.

Scope of Policy

This policy governs the use of EIT for the Excelsior College academic community and includes:

  • Websites. All website pages and web-based software published or hosted by the College or used to conduct College business.
  • Learning Resource Materials. All learning resources, optional and required, must be accessible. This includes, but is not limited to, syllabi, exams, textbooks, presentations and handouts delivered electronically or by non-electronic means. It also includes electronic instructional activities such as instructional videos, online collaborative writing, simulations, web conference archives, blogging, etc.
  • Electronic Documents. All College-produced, maintained, or distributed electronic documents must be accessible. This includes, but is not limited to, word processing documents, PDFs, presentations, publications and spreadsheets that are scanned, uploaded, posted or otherwise published or distributed electronically.
  • Electronic Media: All electronic multimedia resources used for instruction, communication, marketing, promotion or other academic or business purposes must be accessible.
  • Software, Hardware and IT Systems: All software, hardware and IT systems used for academic, research, administrative, business, and customer service purposes, must be accessible and produce accessible products or content, which includes compatibility with assistive technology. Software, hardware and IT systems include, but are not limited to, learning management, content management, library systems, email, online conferencing systems, human resources administration, financial systems, course or event registration, freeware, shareware, enterprise systems and online or remotely hosted software.
  • Procurement/Purchases: Excelsior College strives to purchase electronic products and solutions, including, but not limited to, software, operating systems, web-based applications, and multimedia that meet or exceed the stated accessibility standards.

Definitions
Accessible
“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. The person with a disability must be able to obtain the information as fully, equally and independently as a person without a disability. It still must ensure equal access to the educational benefits and opportunities afforded by the technology and equal treatment in the use of such technology. To obtain more information on this topic, see: https://www.w3.org/TR/WCAG20/

Disability
A physical or mental impairment that substantially limits one or more major life activities, a record of such an impairment, or being regarded as having such an impairment.

Electronic or Information Technology (EIT)
Any equipment, software, or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information, including but not limited to technologies identified in the Scope of this policy.

Equally Effective
“Equally effective” means that the alternative format or medium provided communicates the same information in as timely a fashion and with equivalent content as does the original format or medium.

Compliance Responsibilities

Chief Operating Officer in conjunction with the College Management Council (CMC)

  • Act as policy approver and has the authority to approve policy revisions upon recommendation by the Executive Director of Student
    Accessibility/Title IX Officer and Chief Technology Officer.

Executive Director of Student Accessibility, and Accommodations/Title IX Officer

  • Administer and interpret this policy.
  • Initiate a review of and make necessary revisions to this policy as required by regulatory and technological changes.
  • Conduct annual reviews of the policy, make any necessary revisions and share the revised policy with the appropriate College governance bodies as needed.
  • Conduct annual risk assessments and elevate potential risks to the Office of Risk Management, as necessary.
  • Review requests for exceptions to this policy.
  • Upon request, Accessibility Services will work collaboratively with appropriate College staff and faculty to find alternate ways to provide access to content in systems and courses that do not inherently provide accessibility.
  • The Accessibility Services Office will provide training annually, and when possible, will collaborate with the College’s course development vendor to provide training on specific accessibility topics.
  • The Executive Director of Student Accessibility will monitor the confidential in-box at ACS@Excelsior.edu for complaints or feedback received by phone and will either refer them to TFS when IT related, or respond to them in writing or by phone at 844-427-4356 within three (3) business days.

Chief Technology Officer

  • Ensure that any content management system (CMS) and other web production software be accessible and able to produce accessible websites.
  • Ensure that learning management systems (LMS) and online conferencing systems are accessible and, as applicable, compatible with assistive technology. If that is not possible, the CTO or their designee needs to formally document the rationale, and provide that documentation to the Executive Director of Student Accessibility/Title IX Officer.
  • Strive to purchase only electronic information, communication and technology systems that are accessible and, as applicable, compatible with assistive technology. If that is not possible, the CTO or their designee needs to formally document the rationale, and provide that documentation to the Executive Director of Student Accessibility/Title IX Officer.
  • Strive to ensure that all software and other applications including third-party vendor products, hardware, video and audio equipment, and other IT resources are compatible with assistive technology, and that assistive technology is made available to faculty, staff and students, as necessary and reasonable. If that is not possible, the CTO or their designee needs to formally document the rationale, and provide that documentation to the Executive Director of Student Accessibility/Title IX Officer.

Department, School, and Deans

  • Ensure that online learning environments, including labs, are equipped with IT resources that can deliver accessible electronic information, communication and technology and, as applicable, are compatible with assistive technology.
  • Ensure that all hardware, software, applications, systems, video and multimedia purchased or developed by the unit are accessible and, as applicable, compatible with assistive technology.
  • Submit to the Executive Director of Student Accessibility/Title IX Officer and Dean (or designee) a written request for an exception in the event it is not technically possible or it would constitute a fundamental alteration or undue burden to make specific electronic information, communication and technology accessible. If is not possible, the Dean or their designee needs to formally document the rationale, and provide that documentation to the Executive Director of Student Accessibility/Title IX Officer.

Instructional Faculty and Faculty Program Directors

  • Comply with this policy.
  • Create and present accessible instructional materials.
  • Complete the latest WCAG 2.0 Accessibility Checklist when creating material:
  • Use accessible electronic information, communication and technology to create, deliver and present instructional material and to conduct course related work. If an alternative format is not available, formally document the rationale, and provide that documentation to the Executive Director of Student Accessibility/Title IX Officer. https://www.w3.org/TR/WCAG20/

Staff

  • Comply with this policy.
  • Complete the latest WCAG 2.0 Accessibility Checklist when creating material:
    https://www.w3.org/TR/WCAG20/
  • Create and use accessible electronic information, communication and technology when conducting college business.
    Forward non-routine requests or complaints to the Executive Director of Student Accessibility/Title IX Officer.

Website Accessibility Feedback and/or Concerns

Excelsior College is committed to ensuring that its website is accessible to people with disabilities, and follows the latest W3C WAI’s Web Content Accessibility Guidelines Level AA Standards. This policy applies to all web content on https://www.excelsior.edu/. Each page of the website will include a link to a form allowing users to submit feedback on the site; any issues with accessing content on this website should be submitted there. This information will be compiled and considered during the regular website review process. Any submitted feedback will be responded to within 72 hours.

Complaint Process

Accessibility complaints should be submitted to the Executive Director of Student Accessibility/Title IX Officer via a confidential email box, ACS@excelsior.edu and appealed to the Provost, as outlined below.

The Executive Director of Student Accessibility/Title IX Officer (or designee) will acknowledge receipt of any complaints within three (3) business days either by phone or in writing, and where possible, provide a response within that timeframe. Complaints that require more time to address will be responded to in writing, within fifteen (15) days of receipt of documentation from the complainant. If an individual is unsatisfied with the outcome of their complaint, they may appeal to the Provost within thirty (30) days of receipt of the Executive Director of Student Accessibility/Title IX Officer’s response. The Provost (or designee) will respond to appeals in writing thirty (30) days of receipt. As necessary, the Executive Director of Student Accessibility/Title IX Officer will consult with the VP of HR regarding staff and faculty accessibility complaints or concerns that require further escalation.

Annual Staff Training

Training on the Accessibility Policy will be provided annually for staff and faculty.

Cross Reference to Related Policies

For further information on Excelsior College’s ADA policies, visit the Student Reasonable Accommodation Policy or the Employee Disability Accommodation Policy.

Effective date: July 1, 2019