Information and Communication Technology Accessibility Guidelines

Accessibility Statement

In accordance with Section 504 of the Rehabilitation Act of 1973, Title III of the Americans with Disabilities Act (ADA) of 1990 and the Americans with Disabilities Act Amendments Act (ADAAA) of 2008, Southern New Hampshire University (“University”) does not discriminate on the basis of disability in admission, treatment or access to its programs or activities, nor does it discriminate in its employment opportunities.

The University will take reasonable actions to promote equal access, or provide equally effective alternate access, to its Information and Communication Technology (“ICT”) for individuals with disabilities engaging with the University community and environment.

Definitions

“Accessible” means structured and designed to ensure that individuals with disabilities can access and use information and data in ways that are comparable to those without disabilities.

“Disability” means a physical or mental impairment that substantially limits one or more major life activities.

“Information and Communication Technology" or "ICT" means information technology and other equipment, systems, technologies or processes for which the principal function is the creation, manipulation, storage, display, receipt or transmission of electronic data and information, as well as any associated content. Examples of ICT include but are not limited to: computers and peripheral equipment, information kiosks and transaction machines, telecommunications equipment, customer premises equipment, multifunction office machines, software, applications, websites, videos and electronic documents.  As defined within these guidelines, ICT may include, but are not exclusive to: learning management systems, web portals, email systems, audiovisual communication platforms, digital forms and assessments, course content and media and electronic workstations or access points, whether employee or student facing.

“Equally effective” means the alternative format or medium communicates essentially the same information as does the original format or medium to the maximum extent possible and that individuals with disabilities receive essentially the same benefits or services as individuals without disabilities. To provide equally effective alternate access, alternates are not required to produce the identical result or level of achievement for persons with and without disabilities, but should afford persons with disabilities 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.

Scope

Accessibility is the responsibility of all individuals and departments involved in the design, delivery, support and adoption of ICT. SNHU has created the Information and Communication Technology Accessibility Guidelines (“the Guidelines”) in good faith to facilitate the direction of its efforts to improve ICT accessibility for individuals with disabilities. The Guidelines are not to be construed as a binding plan but instead provide an aspirational framework to help further the path forward to greater accessibility and inclusion. The University reserves the right to change the Guidelines at any time without notice.

The Guidelines apply to academic and administrative ICT in use on learner, employee and public interface sites and mobile applications that facilitate fundamental transactions with and within the institution, including community and public-facing content that is procured, adopted developed, maintained or used by the University or contracted third parties.

Additionally, the Guidelines apply to University-produced and maintained or distributed electronic documents that are learner-, employee- or public-facing. Electronic documents include, but are not limited to, word processing documents, PDFs, fillable forms, presentations, publications and spreadsheets that are scanned, uploaded, posted or otherwise published or distributed electronically.

Finally, the Guidelines apply to media resources used in University programs and activities. For example, this includes, but is not limited to, media that is instructional, informational, marketing and promotional.

Notwithstanding appropriately identified exceptions, including but not limited to those made for archival and pre-existing conventional documents and third-party content not posted on behalf of the University, the Guidelines are intended to apply equally to efforts to maintain, remediate and improve existing ICT and those intended to ensure new ICT meets or exceeds the Guidelines.

Exceptions to these Guidelines include, but are not limited to, content that is historical or archived, provided it is stored within a designated electronic archival system, has not been updated within one year following the implementation of these Guidelines and is not used for current administrative operations, academic instruction or student services. The University recognizes that, even when content falls within these exceptions, it may still be appropriate to provide equally effective alternative access or other reasonable accommodations.

Standard

All web pages and mobile content hosted on snhu.edu, its subdomains or third-party sites published by any department, program or unit as a part of a program or activity hosted by the University should meet the Web Content Accessibility Guidelines (“WCAG”) 2.1 Level AA (“Standard”).1 Employees of the University, vendors, consultants or individuals working either directly or indirectly on behalf of the University should strive to ensure that ICT content is accessible or that an equally effective alternative can be provided. In addition, all software and IT systems purchased should produce accessible products and documents and/or should be compatible with assistive technology to the extent reasonably feasible.

When reasonably feasible to do so, all public-facing University websites should link to the University’s main Accessibility page, which includes a statement of non-discrimination, contact information for assistance, a link to the ADA/504 Grievance Procedure and a method for reporting any accessibility barriers.

Undue Burden and Fundamental Alteration

The ADA Coordinator(s) will provide appropriate guidance to designated University leadership for undue burden and fundamental alteration decisions and will consult with legal counsel as appropriate. Should, through this process, a determination be made that a case-specific adherence to the Guidelines would result in a fundamental alteration or pose an undue burden, an equally effective alternative should be provided to the extent reasonably feasible.

ICT Accessibility Coordinator(s)

The University will designate at least one individual (ICT Accessibility Coordinator) to provide consultative subject matter expertise on these Guidelines and related subject matter and to coordinate and implement a strategic ICT Accessibility Plan and related interdepartmental initiatives. The ICT Accessibility Coordinator will work with designated University leadership to develop the ICT Accessibility Plan and supporting protocols to ensure the continued procurement and development of accessible ICT, to remediate reported and otherwise identified barriers promptly and effectively, and to coordinate efforts toward the systemic implementation of the Guidelines.

Appointed coordinators may include, but will not be limited to, the University’s ADA Coordinator(s) and appropriate representatives from departments such as Information & Technology Solutions, Assistive Technology, the Provost’s Office, the Office of Diversity & Inclusion and the People Team. The University reserves the right to modify the number of ICT Accessibility Coordinators so long as at least one ICT Accessibility Coordinator is designated.

Procurement

ICT adoptions, including all enterprise applications, should meet the University’s accessibility Standard and provide an equal opportunity for individuals with disabilities to access the University’s programs, benefits and services as they do to individuals without disabilities, except when designated University leadership has made a determination that doing so would fundamentally alter a program or present an undue burden. To that end, the University strives to conduct regular and appropriate ICT accessibility evaluations as a function of its internal procurement process by way of efforts such as Voluntary Product Accessibility Template (VPAT) or Accessibility Conformance Report (ACR) review, accessibility testing and the employment of established third-party services for the same. Such evaluations will, wherever appropriate, include efforts to ensure ICT compatibility with common assistive technologies.

Should designated University leadership determine that a case-specific adherence to the Guidelines would result in a fundamental alteration or pose an undue burden, accessible alternate ICT should be planned for, resourced and provided by the requesting adopter by way of proactive contingency planning.

ICT Development

All ICT created or customized by the University, including websites, digital tools and applications, should also conform to WCAG 2.1 Level AA standards. To that end, departments responsible for ICT development should strive to integrate accessibility from the earliest stages of the design and development process to mitigate the need for future remediation. Where feasible, protocols should include user experience testing appropriate to the technology and designed to address the needs and experiences of individuals with disabilities.

Education and Professional Development

University partners, in collaboration with the ICT Accessibility Coordinator(s), will identify an appropriate audience for and, where required, provide education necessary to promote the implementation of plans promulgated in support of these Guidelines. As a matter of general principle, appropriate education and professional development opportunities will not necessarily be limited to technical training, but may instead also focus on topics such as fostering disability literacy, promoting the use of accessible tools and services, empowering individuals to address accessibility proactively within their roles and any other topic responsive to or identified as within the scope of the ICT Accessibility Plan.

Current ICT Content and Functionality

The University will strive to proactively monitor and timely remediate ICT as a function of its commitment to continuous improvement in the area of ICT accessibility. To that end, the University will maintain an accessibility webpage to inform learners, prospective learners, employees, guests and visitors that they may report accessibility barriers, file a formal complaint through its ADA/504 Grievance Procedure and/or contact the ICT Accessibility Coordinator(s) and/or related disability and accessibility support departments with any accessibility concerns. Appropriate contact information will be included on the accessibility webpage. The University will strive to make content and functionality accessible in a timely manner or provide an equally effective alternative unless doing so would result in a fundamental alteration or undue burden.

Additionally, and as part of its ICT Accessibility Plan, the University will develop measurable and, where appropriate, time-bound objectives to identify and remediate inaccessible content and functionality for individuals with disabilities while facilitating the University’s continued support of the highly trafficked public and learner-facing sites affiliated with fundamental University communications, engagement, transactions and learning.

New ICT Content and Functionality

All individuals and departments tasked with the procurement or development of new ICT content and functionality should strive to promote the expectation of accessibility by integrating accessibility evaluation, consideration and contingency planning into product and program workflows, timelines and other operational imperatives. Where appropriate, new, newly-added or substantively modified ICT should be accessible to people with disabilities as measured by the Guidelines, except where doing so would impose a fundamental alteration or undue burden. The University reserves the right to remove or suspend distribution of ICT found to be in nonconformance with the Guidelines.