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Student and Public-Facing Digital Communications Accessibility Policy

Policy

Nova Southeastern University is committed to ensuring that everyone – regardless of their level of ability – will have equal access to student and public-facing digital communications. We have policies and procedures in place to help ensure that we comply with the Americans with Disabilities Act of 1990 (https://www.ada.gov/ada_intro.htm), Pub. L. No. 101-336, 104 Stat. 328 (1990), as amended, and other related state and federal laws, as applicable. This policy establishes minimum accessibility requirements for student and public-facing digital communications deployed on the web or other digital communication platforms.

Definitions

For purposes of this policy the following terms shall have the indicated meanings:

  • "Accessibility" means "the degree to which an environment, service, or product allows access by as many people as possible, in particular, individuals with disabilities."
  • "Accessibility Standards" means conventions, norms or requirements intended to provide access to an environment, product, or service, specifically for individuals with disabilities. The principle of accessibility may be mandated in law, and then specified in detail per regulations, standards, or codes.
  • "Alternative Formats" means information presented in Braille, in large print, via audio recording, or in an electronic format that can be accessed by individuals with disabilities. The Alternative Format must make the same content available and provide an equivalent level of access to the content by individuals with disabilities that are available to others who access the original document.
  • "Public-Facing Digital Communications" includes, but is not limited to, electronic or digital content, communications or applications that are:
    • In HTML, non-HTML platform digital formats;
    • Public facing and broadly disseminated, including academic information and student life information both online and on-campus;
    • Student support mechanisms (e.g. chat, email, etc.);
    • Digital and social media content;
    • For this policy – “public-facing digital communications” shall not include: archival copies stored or retained solely for archival purposes to preserve an exact image of a hard copy; or draft versions of documents that are not public facing, or which are intended for limited distribution.
  • “Readily Achievable” is defined as easily accomplishable and able to be carried out without much difficulty or expense. Failure to remove accessibility barriers where “readily achievable” constitutes discrimination. Determining what is “readily achievable” often involves analyzing the nature and cost of removing barriers and the overall financial resources of the business organization, among other factors. The analysis seeks to balance the benefit of the barrier’s removal and the harm (e.g. cost) to the business.
  • "Web Content Accessibility Guidelines 2.0", or "WCAG 2.0" (https://www.w3.org/WAI/intro/wcag), refers to the globally recognized standard for web accessibility developed by the World Wide Web Consortium (W3C) Web Accessibility Initiative (WAI), https://www.w3.org/WAI.
    • "Level A" refers to the minimum level of conformance that a website must satisfy regarding the WCAG guidelines, or a Level A conforming alternate version is provided.
    • "Level AA" refers to the intermediate level of conformance that a website must satisfy having met all of the Level A and Level AA success criteria regarding the WCAG guidelines, or a Level AA conforming alternate version is provided.

Scope

This policy applies to all Nova Southeastern University student and public-facing digital communications that are developed, procured, maintained, or used in the course of offering educational products, services and online account information to students and the general public.  This includes any accompanying support documentation and services associated with the public-facing digital communications. Employees and faculty of Nova Southeastern University, third party vendors, or individuals working either directly or indirectly on behalf of Nova Southeastern University shall comply with this policy.

Priority

The highest priority will be given to public-facing digital communications that are required for direct access to Nova Southeastern University academic programs, both online and on-campus as well as the overall online student life experience i.e., searching for and researching academic and degree programs, applying for admission and so on. All Alternative Format requests shall be completed in a 180 day time-frame. Equal access to the requested information may be provided instead of making the original material accessible.

Technical Standards

Nova Southeastern University has identified WCAG 2.0 Levels A and AA as their target accessibility standard for student and public-facing digital communications accessed by students and the public via computers, laptops, tablets and smart phones. Unless qualifying for an exception as defined below, as of the Effective Date of this Policy, all new and revised public-facing digital communications published, purchased or controlled by Nova Southeastern University must conform to the WCAG Level 2.0 Levels A and AA accessibility standard.

Primary Contact

Nova Southeastern University will appoint a single point-of-contact who shall be the primary contact point for public-facing digital communications accessibility compliance. All Nova Southeastern University departments responsible for public-facing digital communications should first contact this department to answer any questions about accessibility, address the accessibility of covered communications, and handle alternative format requests. The Nova Southeastern University Digital Accessibility compliance point-of-contact can be reached via email at digital-accessibility@nova.edu.

External Communication

Within sixty (60) days of the Effective Date of this policy or a reasonable time thereafter approved by the accessibility compliance point-of-contact, Nova Southeastern University shall make publicly available and directly link from the university homepage, www.nova.edu, a public statement of Nova Southeastern University’s Student and Public-Facing Digital Communications Accessibility Policy to ensure that individuals with disabilities have full and equal access to its website and other digital communications.  This public statement shall include an accessible means of submitting digital accessibility questions and problems.

Compliance

All Nova Southeastern University departments responsible for public-facing digital communications shall collaborate with the Nova Southeastern University Digital Accessibility compliance point-of-contact to understand accessibility requirements, receive accessibility training, address accessibility of covered public-facing digital communications, and document how the public-facing digital communications conform to the WCAG 2.0 Level A and Level AA accessibility standards. Departments are responsible for implementing procedures to inform faculty, authors, developers, publishers, and procurers about applicable laws, policies and contractual obligations. Nova Southeastern University reserves the right to remove or suspend distribution of public-facing digital communications found to be in noncompliance with this policy.

Evaluation & Monitoring

All Nova Southeastern University departments responsible for student and public-facing digital communications shall provide standards conformance reports for public-facing digital communications they are responsible for, on an annual or ad hoc basis, including both components developed by Nova Southeastern University as well as components developed by third-party vendors and deployed on or integrated into Nova Southeastern University managed platforms or applications.  Such reporting, evaluation and monitoring may be done using the system adopted by the Nova Southeastern University Digital Accessibility compliance point-of-contact.

Nova Southeastern University shall obligate its third-party vendors to conduct periodic audits of public-facing digital communications acquired by Nova Southeastern University under contract, and provide such reports to Nova Southeastern University upon request.  This includes VPATs® or other accessibility conformance reports for typically used third party platforms and applications like learning management systems, bookstore, etc.

Training

This policy will be communicated to all Nova Southeastern University departments responsible for public-facing digital communications, including, but not limited to: student services representatives, project managers, faculty, designers, developers, content authors, QA analysts, and compliance/risk managers. The policy will also be communicated to and be binding upon external vendors and contractors who develop public-facing digital communications for Nova Southeastern University. Training or training resources will be offered on an as-needed basis to help these staff to implement the policy.

Exceptions

Where compliance with this policy is not possible, exceptions to this policy may be granted by Nova Southeastern University. Requests for exceptions must be documented and submitted to the Nova Southeastern University Digital Accessibility compliance point-of-contact.  Exceptions may be granted in the following scenarios:

  • “Not Readily Achievable” – Compliance with this policy may be waived if the nature and cost of removing digital accessibility barriers exceeds the financial resources of the university. This does not include not budgeting for addressing digital accessibility barriers, and should only be used in extreme circumstances where addressing digital accessibility barriers would financially harm the university.
  • "Fundamental alteration" – Compliance with this policy may be waived if addressing digital accessibility barriers would result in a fundamental alteration like the Nova Southeastern University service, program, or activity or result in undue financial and administrative burdens.
  • "User-Generated Content" – Content that is created by users of Nova Southeastern University systems, which is not readily accessible to the public may be exempted from compliance with this policy. This exception only applies to the content itself, not the controls provided in association with the content, such as "Like" or "Follow" buttons, next page links, logins which may be required to view content, etc.
  • "Linked Sites and Resources" – Sites, resources, or systems that are linked to or from any Nova Southeastern University published or controlled website or application, but which are provided by a third party outside of Nova Southeastern University’s operations may be exempted from compliance with this policy, unless there is a contract in place with a vendor who is being paid to provide access to the third-party component, website, resource or system. Exemptions will not be applied to linked sites and resources that provide critical systems or critical services.
  • "External Digital Content" – Digital Content about or relating to Nova Southeastern University that is hosted by third parties may be exempted from compliance with this policy, unless there is a contract in place with a vendor who is being paid to provide such External Digital Content.
  • "Short Term Digital Content" – Digital Content that is hosted for less than three weeks may be exempted from compliance with this policy.
  • "Orphaned Digital Content" – Digital Content that is orphaned or available but not linked directly from any web site published or controlled by Nova Southeastern University may be exempted from compliance with this policy.
  • "Back Office" – Nova Southeastern University digital assets used for administration or monitoring of student and public-facing digital communications, but which are not available for use by the public or customers are exempted from compliance with this policy.

Compliance Contact

If you would like further information on the Nova Southeastern University

Student and Public-Facing Digital Communications Accessibility Policy or have additional questions, please contact us via email to the Nova Southeastern University Digital Accessibility compliance point-of-contact at digital-accessibility@nova.edu.

Student Services Contact

If you are a student, perspective student or parent and would like more information about services offered for students with disabilities, please contact Student Disabilities Services via email at disabilityservices@nova.edu  or by telephone at (954) 262-7185.

Employee Services Contact

If you are employed at the university, and would like more information about services offered for employees with disabilities, please contact Human Resources via email at Hr4u@nova.edu or by telephone at (954)262-4748.

 

Effective Date: 08/09/2018

Last Review: New

Review Period: Every three years

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