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Information Technology Accessibility Standard

Purpose

The purpose of this standard is to ensure that Information Technology products and services at William & Mary meet the standards and requirements set forth in Section 504 of the Rehabilitation Act of 1973, the Americans with Disabilities Act of 1990, and the subsequent amendment to the Rehabilitation Act, Section 508 of the Rehabilitation Act. Collectively, these laws and standards ensure that people with disabilities, including faculty, staff, students and the general public, have access to and use of information comparable to the access and use by people who do not have disabilities. The goal is to achieve and maintain compliance with these requirements when procuring, developing, and/or maintaining information technology products and services. In cases where meeting this requirement creates an undue burden, the Information Technology department will document why it cannot achieve compliance and make a reasonable attempt to make the product or service accessible by some other means.

Scope

Following Section 508 of the ADA, this document sets standards for the following categories of technology products and services:

• software applications and operating systems;
• web-based Internet and intranet information and applications;
• telecommunication products;
• video and multimedia products;
• self-contained, closed products;
• desktop and portable computers.

Additionally, specific functional requirements must be met with respect to the technologies listed above and compliance with each of these functional requirements will apply to each category as well.

General Standard for Procurement, Development and Maintenance of Information Technology Products and Services

When procuring, developing or maintaining electronic and information technology products (either directly or through administration of contracts), W&M will ensure that the products comply with all laws set forth in Section 504 and 508 of the Rehabilitation Act of 1973 as well as the Americans with Disabilities Act of 1990, unless an undue burden would be imposed on the university.

Electronic and information technology products are any electronic information equipment or interconnected system that is used in the:

• acquisition,
• storage,
• manipulation,
• management,
• movement,
• control,
• display,
• switching,
• interchange,
• transmission, or
• reception of data or information, including audio, graphic, and text.

When procuring, developing, or maintaining a product, if the university determines that compliance with any provision of this standard imposes an undue burden, the documentation by W&M supporting the procurement shall explain why, and to what extent, compliance with each such provision creates an undue burden. Furthermore, when compliance with this standard is deemed to impose an undue burden, the university will make reasonable attempts to provide individuals with disabilities the information and data involved by an alternative method of access.

Technical Standards for Information Technology Products and Services

This technical standards section specifies what electronic and information technology is covered. For example, a computer and its software programs would be required to comply with the subsections titled Desktop and Portable Computers as well as Software Applications and Operating Systems.

A. Standards for Software Applications and Operating Systems
The following standards apply to all software applications and operating systems supported by the Information Technology department.

• When software is designed to run on a system that has a keyboard, product functions shall be executable from a keyboard where the function itself or the result of performing a function can be discerned textually.
• Applications shall not disrupt or disable activated features of other products that are identified as accessibility features, where those features are developed and documented according to industry standards. Applications also shall not disrupt or disable activated features of any operating system that are identified as accessibility features where the application programming interface for those accessibility features has been documented by the manufacturer of the operating system and is available to the product developer.
• A well defined on-screen indication of the current focus shall be provided that moves among interactive interface elements as the input focus changes. The focus shall be programmatically exposed so that assistive technology can track focus and focus changes.
• Sufficient information about a user interface element, including the identity, operation, and state of the element, shall be available to assistive technology. When an image represents a program element, the information conveyed by the image must also be available in text.
• When bitmap images are used to identify controls, status indicators, or other programmatic elements, the meaning assigned to those images shall be consistent throughout an application's performance.
• Textual information shall be provided through operating system functions for displaying text. The minimum information that shall be made available is text content, text input caret location, and text attributes.
• The position on a screen where an action will take place is referred to as the "focus". For example, when a menu item in a program is highlighted - meaning that if the user clicks the mouse or presses the enter key - the feature will activate and that item has the focus. Providing a visual indication of the focus allows someone who is viewing the screen to accurately access the program's features.
• Applications shall not override user selected contrast, color selections, and other individual display attributes.
• When animation is displayed, the information shall be displayable in at least one non-animated presentation mode at the option of the user.
• Color-coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.
• When a product permits a user to adjust color and contrast settings, a variety of color selections capable of producing a range of contrast levels shall be provided.
• Software shall not use flashing or blinking text, objects, or other elements having a flash or blink frequency greater than 2 Hz and lower than 55 Hz.
• When electronic forms are used, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.

B. Standards for Web-based Intranet and Internet Information and Applications
The following standards apply to all web-based intranet, and internet information and applications supported by the Information Technology department.

• a web site shall ensure that foreground and background color combinations provide sufficient contrast when viewed by someone having color deficits or when viewed on a black and white screen. WAI WCAG checkpoint 2.2;
• the opening of new browser windows should only be done if the user is warned that a new window will open and there may be a possibility of functional difficulties;
• use style sheets to control layout whenever possible;
• do not use tables for layout unless the table makes sense when linearized;
• font sizes should be percentage based instead of fixed;
• a method shall be provided that permits users to skip repetitive navigation links. (See: WATG for more details);
• content headers shall use the Heading Element (H1 through H6) hierarchy, although style sheets may be used to modify the size and other characteristics of that text;
• the requirements of this Standard apply to all web sites supported by Information Technology, with the following exceptions:
  • downloadable documents (e.g. Word document, PowerPoint presentation, etc.) per se are exempted, although accessible and equivalent versions of the content must be available;
  • sites external to the Executive Branch.
• HTML frames are forbidden when in the visual template;
• title frames with text that facilitates frame identification and navigation;

C. Standards for Telecommunications Products
The following standards apply to all telecommunications products and services supported by the Information Technology department.

• Telecommunications products, which include voice communication functionality, shall support all commonly used cross-manufacturer nonproprietary standard TTY signal protocols.
• Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems shall be usable by TTY users either through direct TTY access or through use of the relay service and by Voice Carry over (VCO), Hearing Carry over (HCO), and Speech To Speech users through the relay service.
• Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems that require a response from a user within a time interval, shall give an alert when the time interval is about to run out, and shall provide sufficient time for the user to indicate more time is required.
• Where provided, caller identification and similar telecommunications functions shall also be available for users of TTYs, and for users who cannot see displays.
• If the telecommunications product allows a user to adjust the receive volume, a function shall be provided to automatically reset the volume to the default level after every use if the volume is capable of greater than 18 dB of gain.
• Where a telecommunications product delivers output by an audio transducer, which is normally held up to the ear, a means for effective magnetic wireless coupling to hearing technologies shall be provided.
• Products which have mechanically operated controls or keys, shall comply with the following:
  • Controls and keys shall be tactilely discernible without activating the controls or keys.
  • Controls and keys shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate controls and keys shall be 5 lbs. (22.2 N) maximum.
  • If key repeat is supported, the delay before repeat shall be adjustable to at least 2 seconds. The key repeat rate shall be adjustable to 2 seconds per character.
  • The status of all locking or toggle controls or keys shall be visually discernible and discernible through touch or sound.

D. Standards for Video and Multimedia Products
The following standards apply to all video and multimedia products and services supported by the Information Technology department.

• Equipment that includes a DTV receiver or display circuitry, shall be equipped with caption decoder circuitry which appropriately receives, decodes, and displays closed captions from broadcast, cable, videotape, and DVD signals.
• Television tuners, including tuner cards for use in computers, shall be stereo and equipped with secondary audio program playback circuitry.
• Training and information video and multimedia products, excluding television broadcasts and live Webcasts that contain speech or other audio information necessary for the comprehension of the content, shall be open or closed captioned.
• Training and informational video and multimedia products, excluding television broadcasts and live Webcasts that contain visual information necessary for the comprehension of the content, shall be Alternatively Described4.
• Display or presentation of alternate text presentation or audio descriptions shall be user-selectable unless permanent.
• Television broadcasts, both live and pre-recorded, are subject to all the rules and regulations as specified by the Federal Communications Commission (FCC) regarding the inclusion of captioning and video descriptions. (See www.fcc.gov)

E. Standards for Self-Contained, Closed Products

• Self-contained products shall be usable by people with disabilities without requiring an end-user to attach assistive technology to the product. Personal headsets for private listening are not assistive technology.
• When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.
• Where a product utilizes touch-screens or contact-sensitive controls, an alternative input method shall be provided.
• When biometric forms of user identification or control are used, an alternative form of identification or activation, which does not require the user to possess particular biological characteristics, shall also be provided.
• When products provide auditory output, the audio signal shall be provided at a standard signal level through an industry standard connector that will allow for private listening. The product must provide the ability to interrupt, pause, and restart the audio at any time.
• When products deliver voice output in a public area, incremental volume control shall be provided with output amplification up to a level of at least 65 dB. Where the ambient noise level of the environment is above 45 dB, a volume gain of at least 20 dB above the ambient level shall be user selectable. A function shall be provided to automatically reset the volume to the default level after every use.
• Color coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.
• When a product permits a user to adjust color and contrast settings, a range of color selections capable of producing a variety of contrast levels shall be provided.
• Products shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.
• Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following:
  • The position of any operable control shall be determined with respect to a vertical plane, which is 48 inches in length, centered on the operable control, and at the maximum protrusion of the product within the 48 inch length.
  • Where any operable control is 10 inches or less behind the reference plane, the height shall be 54 inches maximum and 15 inches minimum above the floor.
  • Where any operable control is more than 10 inches and not more than 24 inches behind the reference plane, the height shall be 46 inches maximum and 15 inches minimum above the floor.
  • Operable controls shall not be more than 24 inches behind the reference plane.

F. Standards for Desktop and Portable Computers
The following standards apply to all desktop and portable computers supported by the Information Technology department.

• Products which have mechanically operated controls or keys, shall comply with the following:
  • Controls and keys shall be tactilely discernible without activating the controls or keys.
  • If key repeat is supported, the delay before repeat shall be adjustable to at least 2 seconds. Key repeat rate shall be adjustable to 2 seconds per character.
  • The status of all locking or toggle controls or keys shall be visually discernible, and discernible either through touch or sound.
  • If a product utilizes touch-screens or touch-operated controls, an alternative input method shall be provided.
  • When biometric forms of user identification or control are used, an alternative form of identification or activation, which does not require the user to possess particular biological characteristics, shall also be provided.
  • Where provided, at least one of each type of expansion slots, ports and connectors shall comply with publicly available industry standards.

Functional Performance Criteria

The following functional performance criteria apply to all Information Technology products and services where applicable.

• At least one mode of operation and information retrieval that does not require user vision shall be provided, or support for assistive technology used by people who are blind or visually impaired shall be provided.
• At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently, or support for assistive technology used by people who are visually impaired shall be provided.
• At least one mode of operation and information retrieval that does not require user hearing shall be provided, or support for assistive technology used by people who are deaf or hard of hearing shall be provided.
• Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion, or support for assistive hearing devices shall be provided.
• At least one mode of operation and information retrieval that does not require user speech shall be provided, or support for assistive technology used by people with disabilities shall be provided.
• At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided.

Information, Documentation and Support

• Product support documentation provided to users shall be made available in alternate formats upon request, at no additional charge.
• Users shall have access to a description of the accessibility and compatibility features of products in alternate formats or alternate methods upon request, at no additional charge.
• Support services for products shall accommodate the communication needs of users with disabilities.

Equivalent Facilitation

Nothing in this Standard is intended to prevent the use of designs or technologies as alternatives to those prescribed in this Standard provided they result in substantially equivalent or greater access to and use of a product for people with disabilities. Agencies may accept electronic and information technology offered by vendors, which uses designs or technologies that do not meet the applicable technical provisions, but provide substantially equivalent or greater access to and use of a product for people with disabilities. This is referred to as “equivalent facilitation.” Equivalent facilitation is not an exception or variance from the requirement to provide comparable access. Rather, it is recognition that technologies may be developed or used in ways not envisioned by the technical provisions of this document but still result in the same or better functional access. Functional outcome – not form – is the key to evaluating whether a technology results in “substantially equivalent or greater access.”

Definitions

The following definitions apply to this standard:

Access
The ability to receive, use, and manipulate data and operate controls included in information technology.

Accommodation
Accommodations are changes in the way things are customarily done that enable individuals with disabilities to enjoy equal access and benefits. Most often in this Standard the term refers to the provision of effective communication through delivery of auxiliary aids and services such as:

• qualified interpreters,
• note takers,
• transcription or captioning,
• qualified readers,
• Braille,
• video description, and
• assistive devices.

Alternate Formats
Alternative formats usable by people with disabilities may include, but are not limited to:

• Braille,
• ASCII text,
• large print,
• recorded audio, and
• electronic formats.

Alternate Methods
Alternate methods are different means of providing information, including product documentation, to people with disabilities. Alternate methods may include, but are not limited to:

• voice,
• fax,
• relay service,
• TTY,
• Internet posting,
• captioning,
• text-to-speech synthesis, and
• audio description.

Assistive Technology Device
Any item, piece of equipment, or product system, whether acquired commercially off the shelf, modified, or customized, that is used to increase, maintain, or improve functional capabilities of individuals with disabilities.

Electronic and Information Technology
Includes information technology and any equipment or interconnected system or subsystem of equipment that are used in the creation, conversion, or duplication of data or information. The term electronic and information technology includes, but is not limited to:

• telecommunications products (such as telephones),
• information kiosks and transaction machines,
• World Wide Web sites,
• multimedia, and
• office equipment such as copiers and fax machines.

Equivalent Facilitation
Equivalent facilitation is that which provides the same level of access as that provided to non-disabled individuals. Equivalent facilitation is required for all non-compliant, inaccessible content of Web sites, and all noncompliant products, services, and devices.

Heading Elements
The six heading elements, H1 through H6, denote section headings. Although the order and occurrence of headings is not constrained by the HTML DTD, documents should not skip levels (for example, from H1 to H3), as converting such documents to other representations is often problematic.

Example of use:

• <H1>This is a heading</H1>
• Here is some text
• <H2>Second level heading</H2>
• Here is some more text.
  • information kiosks and information transaction machines,
  • copiers,
  • printers,
  • fax machines,
  • voting machines, and
  • other similar types of products.

Typical renderings are:
H 1 Bold, very-large font, centered. One or two blank lines above and below.
H 2 Bold, large font, flush-left. One or two blank lines above and below. H 3 Italic, large font, slightly indented from the left margin. One or two blank lines above and below.
H 4 Bold, normal font, indented more than H3. One blank line above and below.
H 5 Italic, normal font, indented as H4. One blank line above.
H 6 Bold, indented same as normal text, more than H5. One blank line above.

Individual with Disabilities
Any individual who is considered to have a disability for the purposes of any Federal or Virginia law.

Non-visual Access
Synthesized speech, Braille, and other output methods not requiring sight.

Operable Controls
A component of a product that requires physical contact for normal operation. Operable controls include, but are not limited to, mechanically operated controls, input and output trays, card slots, keyboards, or keypads.

Self-Contained, Closed Products
Products that generally have embedded software and are commonly designed in such a fashion that a user couldn't easily attach or install assistive technology. These products include, but are not limited to:

Telecommunications
The transmission, between or among points specified by the user, of information of the user's choosing, without change in the form or content of the information as sent and received.

Television Broadcast
Pertains to any video production distributed via an FCC regulated television station, but not including the same video production distributed or redistributed via the Internet or an internal intranet.

Teletypewriter (TTY)
An abbreviation for teletypewriter. Machinery or equipment that employs interactive text-based communications through the transmission of coded signals across the telephone network. TTYs may include, for example, devices known as TDDs (telecommunication display devices or telecommunication devices for deaf persons) or computers with special modems. TTYs are also called text telephones.

Video Description
Video description is the insertion of verbal descriptions about the setting and/or action in a video program when information about these visual elements is not contained in the audio portion of the program. These descriptions supplement the regular audio track of the program. Video descriptions are a way to let people who are blind or have low vision know what is happening on screen. Note: In this Standard the term video description is used rather than audio description. The term audio description is reserved for verbal descriptions of live events.