Digital Accessibility Policy

Digital Content Owners are responsible for the accessibility of their sites and must hold content creators, developers and other necessary parties accountable for ensuring the site’s accessibility. Digital Content Owners will coordinate with their Digital Accessibility Liaison(s) to oversee remediation processes and to identify any resource/training needs. 

Digital Content Owners are designated by the unit's Dean, Vice President, Chair, Unit Leader and/or Director. While each Digital Content Owner is an individual person, Digital Content Owner assignments should be based on the individual’s role within the University. Some Digital Content Owners may also serve as Digital Accessibility Liaisons.  

Examples of Digital Content Owners  

• Three different labs each have their own website. Organizationally, the labs report up to a Department; the Department reports up to a Division; and the Division reports into a School. The School is responsible for designating an individual to serve as the Digital Content Owner on behalf of the Division and Department and the School is responsible for holding content creators accountable.  Appointed individuals may be the Director of Communications, a specified Associate Dean, or the PI of the lab, as appointment structure may vary across University schools. 
• An interfaculty initiative (“IFI”) creates a site to promote their annual event. Organizationally, the IFI reports up to The Office of the Provost. The Office of the Provost is responsible for holding the IFI accountable. The appointed Digital Content Owner may be the Director of the Initiative or a designated Associate Provost,  but should not be “the Office of the Provost.” 

In order to request a temporary exception to the Policy, Digital Content Owners must submit a request to the Office of Civil Rights and Title IX Compliance (“OCR”) for approval.

Exception requests must include a detailed description as to why conformance with the Policy is not feasible or would cause undue hardship. Digital Content Owners requesting an exception will be required to submit an Equally Effective Alternate Access Plan detailing how information will be made available to individuals with disabilities until conformance with the Standards is achieved. All exception requests will be reviewed by OCR in consultation with DASC within 30 days. Documentation of exception requests and their disposition will be retained by OCR, which will undertake periodic review of the exceptions process.

• Computational spreadsheets containing program modules or macros that were developed to perform automated analysis or draw data from external or legacy databases.  
• Third-party licensed documents from scientific journals or conferences (e.g., where the license agreement does not allow the user to modify the file or where the files are hosted and updated by the journal on its server).
• Scanned written or poor image/text quality historical documents or publications that are in a digital archive and/or archived historical legacy files.
• Complex dynamic visualizations, such as medical diagnostic or research imaging technologies, 3D models, virtual environments, computer-aided design (“CAD”) software.

OCR, in partnership with the DASC, may require a Digital Content Owner, in cooperation with a DAL, to establish a plan to remediate those portions of an existing University Website that do not conform to the Accessibility Standards. This may include websites that would not otherwise be required to conform, such as a site created or revised prior to September 1, 2021. 

In evaluating Websites that require remediation, OCR and DASC will consider several factors, such as: 

• How essential the Website or its content is to University functions (i.e., whether it is functional or             informational);
• Whether the Digital Content Owner is already planning to revise the Website;
• Target audience (i.e., whether the Website is directed to internal or external users); and
• Size of audience.

The Office of Civil Rights and Title IX Compliance will refer identified sites to the Digital Content Owner and the applicable DAL to provide information about their site and identify resources available to support remediation. OCR, in partnership with DASC, can assist Digital Content Owners and DALs in deciding what to improve first and how to approach the work, such as through incremental updates made by existing staff, contracted work, and/or platform migration. Digital Content Owners must provide an evaluation report to OCR. 

NUIT and Northwestern Office of Global Marketing and Communications (“OGMC”) will be consulted as needed to address technical issues, and the Office of Civil Rights and Title IX Compliance will consult on reported issues that may implicate the University’s Policy on Institutional Equity.   

Digital Content Owners shall develop a regular testing schedule for University Websites that utilizes both automated and manual testing tools.  The testing schedule should occur on an annual basis minimally.  Automated testing tools speed up the process of evaluation and allow for regular monitoring. However, human evaluation is also required to assess a website’s accessibility, since no one tool alone can determine whether a site conforms to the Accessibility Standards.

More information on automated and manual testing tools are available through the Accessibility Website.

Digital Content Owners should make every effort to address reported barriers within a reasonable timeframe. Timeframes will vary case-by-case, according to a number of factors including but not limited to:

• The complexity of the reported barrier;
• The urgency of the user’s needs; and
• Whether a third party’s involvement is required to address the barrier.

In some cases, the Digital Content Owner may have to provide an accommodation to meet a user’s immediate needs, and then work to address the barrier afterwards.

Addressing software accessibility is a fundamental part of the purchasing process. To that end, the University has created guidance that outlines the process which should be followed when procuring digital software.  In sum, the process consists of the following steps:

1. Collect information on planned usage of the product including the primary product users, the annual cost, the frequency of use, and the expected number of users (Link)
2. Collect product accessibility information from the vendor (link)
3. Use the usage and vendor accessibility information to determine next steps via the Purchasing Accessibility Matrix (link)

Most software tools are likely to have some accessibility issues. This does not necessarily mean that purchase of the tools is prohibited. However, in the event a tool with known accessibility issues is purchased, the purchasing department must complete, and submit to the Office of Civil Rights and Title IX Compliance in a timely manner, an Equally Effective Alternate Access Plan (“EEAAP”) describing how access will be provided to individuals affected by these issues.

To assist the University community in meeting the responsibilities set forth in the Policy, training and support resources are available to those responsible for creating or maintaining Digital Content. The training and support resources, including instructions on how to make websites and web-based applications accessible, how to perform manual checks and use automated tools for evaluation, and how to get help can be found here.

Most remediation can be achieved with little or no expense (e.g., adding alt text). In the unusual circumstance that remediation results in significant costs, OCR will assess the need for funding assistance on a case-by-case basis.