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Responsible Senior Staff Member(s:) Chief Information Officer/Executive Director Library, Information, and Technology Services (LITS), Vice President for Equity and Inclusion and Chief Diversity Officer
Responsible Office(s:) Library, Information, and Technology Services (LITS), Office of Diversity, Equity and Inclusion
Date Established: September 5, 2017
Drafted By: Technology Access Committee
Date Last Revised: April 26, 2022

Statement

������ƵCollege is committed to providing equal opportunity to persons with disabilities, including equal access to participate in and benefit from College programs, services and activities. In our mission to do so, it is important that accessibility is in the forefront as we consider, design, build, acquire or use new electronic and information technology (EIT), including EIT that is freely available, obtained or procured at no cost, and/or open source.  Therefore, this policy establishes minimum standards and expectations regarding the design, acquisition or use of EIT to achieve the College’s legal, moral, and ethical commitments in the digital environment.  

An essential goal in the consideration, adoption, and use of any technology is to achieve the highest standard for accessibility, and to ensure equal access for all participants as originally designed and implemented. However, programs, services, or activities will not be deemed inaccessible due to the mere presence of technological barriers as long as individuals are provided the same information or functionality in an accessible way, or provided equally effective alternative access as prescribed within this policy.

Scope

This policy extends to the College’s electronic and information technologies and applies to their procurement, development, implementation and ongoing maintenance.

Responsibilities

All members of the College community with responsibility for creating, selecting, procurement, developing, implementing, and maintaining electronic and information technologies are responsible for ensuring that such technologies are compliant with this policy and the related standards.

Policy

It is the policy of ������ƵCollege that all community members must make a reasonable effort to ensure that electronic and information technology (EIT) be accessible to students, employees and the general public, except as described below or otherwise governed by applicable law.

This policy is in accordance with federal and state laws including the Americans with Disabilities Act of 1990 (ADA), as amended, and Section 504 of the Rehabilitation Act of 1973.

Procedures

1. Standards — College community members will follow the standards related to the procurement, development, implementation, and ongoing maintenance of EIT available at  (the “Accessibility Standards”). 
2. Exceptions — When conformance to the standards a) fundamentally alters a program, service, or activity, b) creates an undue administrative burden, or c) is not technically feasible, the individual, office or department sponsoring the program, service, or activity must provide equally effective alternative access that communicates the same information, provides the same functionality, and affords individuals with disabilities an equal opportunity to obtain the same result, gain the same benefit or reach the same level of achievement, in the most integrated setting appropriate to their needs in as timely a fashion as does the original format or medium.  Guidance for providing Equally Effective Alternative Access Plans can be found in the “Accessibility Standards” as linked above. 
3. Escalations — At the discretion of the 504 Coordinator, decisions that require further evaluation beyond the scope of TechAccess will be escalated to the responsible Senior Staff members of this policy and the Vice President of the department.

Definitions

“A�����������������” means that individuals with disabilities are able to independently acquire the same information, engage in the same interactions, and enjoy the same services within the same timeframe as individuals without disabilities, with substantially equivalent ease and effectiveness of use.

"Electronic and information technology" or "EIT" includes information technology and any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information. The term electronic and information technology includes, but is not limited to, the internet and intranet websites, content delivered in digital form, electronic books and electronic book reading systems, search engines and databases, learning management systems, classroom technology and multimedia, personal response systems ("clickers"), and office equipment such as classroom podiums, copiers and fax machines. It also includes any equipment or interconnected system or subsystem of equipment that is used in the automatic acquisition, creation, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. EIT includes telecommunications products (such as telephones), information kiosks, Automated Teller Machines (ATMs), transaction machines, computers, ancillary equipment, software, firmware and similar procedures, services (including support services), equipment maintained and services operated by third-party vendors, and related resources. 

"Equally effective alternative access," with respect to electronic and information technology, means an alternative format, medium, or other aid that timely and accurately communicates the same content as does the original format or medium, and which is appropriate to an individual's disability. To provide equally effective alternative access, the College need not ensure that qualified individuals with disabilities achieve the identical result or level of achievement as individuals without disabilities, but the College must provide appropriate auxiliary aids and services as necessary to afford individuals with disabilities an equal opportunity to obtain the same result, gain the same benefit, or reach the same level of achievement, in the most integrated setting appropriate to their needs. In providing equally effective alternative access, the College may rely on any commonly accepted standard or combination of standards provided the remainder of this definition is met. The College is not required to take any action that results in a fundamental alteration in the nature of a service, program, or activity or in undue financial and administrative burden, but must nevertheless ensure, to the maximum extent possible, that qualified students with disabilities receive the benefits or services provided by the College. 

“Undue administrative burdens” are created when a proposed course of action causes significant difficulty.  Because an institution must consider all resources available when reviewing claims of undue administrative burdens, the decision to invoke undue administrative burdens should be carefully weighed, sufficiently documented and ultimately authorized by an appropriate College official.  In situations where undue administrative burdens can be documented, equally effective alternative access must still be provided.

Policy violations

Violations of college policies are adjudicated according to procedures outlined in the Student Handbook, the Handbook of Faculty Legislation, and the Staff Handbook, with disciplinary consequences imposed by the adjudicating authority up to and including dismissal. Some offenses are punishable under state and federal laws. 

Related information

Resources:

• Disability Services
• Five College Risk Management ()
• LITS Services and Resources for Individuals with Disabilities ()

Additional Reference Material:

* The American with Disabilities Act of 1990 (ADA) and Section 504 of the Rehabilitation Act of 1973