What is EIT?
Electronic information technology, or “EIT,” is a term that encompasses a range of technologies that are used for the creation, conversion, duplication or delivery of information. The Electronic and Information Technology Accessibility Procedures and Guidelines address the principal forms of EIT that we use at the University (websites; electronic library and instructional materials and electronic documents; video and audio; and software and hardware systems) along with procurement practices, but “EIT” includes other technologies and can be expected to evolve as technology and the ways it is used develop.
Why is EIT accessibility important?
According to The World Bank, 1 billion people (15% of the world’s population) experience some form of disability, with almost 57 million in the U.S. alone. At Georgetown, more than 650 students are registered with the Academic Resource Center as having disabilities, and a number of our faculty and staff also have disabilities. Many of these individuals – particularly those with visual, auditory, or motor skill disabilities – need assistive technology such as screen readers, captioned videos, or keyboard controls, in order to be able to access information online. If websites, electronic documents, audio and video and other types of information provided through technology are not provided in a way that can be accessed or “read” through assistive technology or other means, it can be difficult for people with disabilities to participate and to benefit from the University’s activities and programs. As information is increasingly moved online and accessed or delivered using technology, Georgetown’s programs and activities must be inclusive of, and accessible to, all of our faculty, staff, and students regardless of disability status.
Why do we need a policy for EIT accessibility?
The law, and the University’s existing policies, already prohibit discrimination on the basis of disability and require that we provide accommodations that enable those with disabilities to access services and information. So this Policy really does not change our community members’ obligations. However, as EIT has become integral to University life, understanding what “accessibility” means in various contexts (e.g., websites, e-readers, online courses, live-streamed video, etc.) has become more complex. As a result, policies that specifically address and help explain EIT accessibility and promote equal access to electronic information have become important for colleges and universities.
What is the purpose of the Procedures and Guidelines?
The Procedures and Guidelines that accompany the Policy are intended to set standards and provide guidance and resources to enable University community members to comply with the Policy and the law that underlies it. Standards are either required by regulatory or enforcement agencies, or are considered best practice. For example, the WCAG 2.0 AA standard for website accessibility is the standard that the Departments of Education and Justice require universities to meet in order to comply with federal law. Other guidelines and procedures (e.g. the procedure for ensuring all newly purchased software meets compliance standards) are generally accepted best practices used by colleges and universities to meet their legal and ethical obligations to provide equal access.
In developing these Procedures and Guidelines, we collaborated with, engaged, and benefited from the contributions of many individuals and offices that have particular expertise or will be most significantly engaged in activities affected by the Policy. The Procedures and Guidelines will be regularly reviewed and updated by the EIT Accessibility Advisory Group.
Does this new policy change how faculty should prepare instructional or course materials?
No. Under current University policy and federal law, faculty are already required to ensure that their course materials are made accessible for those with disabilities upon request. The new Policy, and the associated Procedures and Guidelines state that “instructional materials must be made accessible to students with disabilities upon request and in accordance with the procedures of campus disability services offices.” The new policy does not change current obligations.
Does this new policy change how websites are created?
No, it does not change existing obligations, but it may highlight existing obligations of which you are unaware. Federal enforcement agencies expect the University's websites to be accessible by default. Just as new public buildings must have wheelchair ramps even if nobody specifically requests one, public websites should be designed to be accessible to those who use screen readers or other assistive technology. The new Policy and associated Procedures and Guidelines merely reiterate this obligation and provide resources and information about how Georgetown faculty and staff can ensure their websites are accessible (e.g., in accordance with the WCAG 2.0AA web accessibility standards) and comply with federal law. The website standards are different than those for electronic instructional/course materials, which can be made accessible upon request (rather than by default) and in consultation with the University’s disability services offices.
How am I supposed to make the thousands of pages, maps, photographs, charts, videos, archival texts, etc. posted to my website accessible?
The Procedures and Guidelines are designed to be pragmatic and prioritized and take into account costs and burdens and the infeasibility of making some content or materials accessible. For example, new website content (after March 1, 2019) must be accessible by default, but for legacy (older) content, departments can set up a plan to update and make that more accessible in a prioritized manner (e.g., prioritizing public facing or heavily trafficked content). Similarly, all new video content that is made publicly available needs to be accessible (i.e., captioned) by default, but content that is behind a firewall and requires GUID to access only needs to be made accessible upon request. These and other distinctions recognize the goal of making as much content as possible accessible and the reality that fixing websites, transcribing thousands of videos, and taking other steps would be extremely costly and in some instances not feasible.
I work in a highly technical field with complex charts/symbols/graphics that cannot be made accessible; or I need to procure certain software that cannot be made accessible. Will I be in violation of the policy?
No. The Policy requires compliance with federal and local disability laws. Laws like the ADA and Section 504 of the Rehabilitation act require that websites be made accessible or that reasonable accommodations be made unless doing so would change the fundamental nature of the program or cause an undue financial or administrative burden. If no technology reasonably exists that can make your materials or your software accessible, then the law – and University policy – do not require you do to so. However, in the classroom/instruction context, if there are other ways that the information can be reasonably conveyed to a student (such as having a written or spoken description of a complex chart), the law – and University policy – would require you to provide that reasonable alternative.
With respect to procurement, the University realizes that in some limited circumstances, it may be necessary to procure software, hardware, and other products may not be fully compliant with accessibility standards. The procurement process has an exception policy through which a department can explain why the product is necessary, why it cannot be made accessible, whether it will be made accessible in the future, and how the individual/department procuring the product will provide an alternate solution in the event an individual with a disability is unable to use the product.
Who is in charge of updating the Procedures and Guidelines?
The EIT Accessibility Advisory Group will meet periodically to review and update the “Procedures and Guidelines” to reflect changing accessibility standards and technology without needing to make changes to the Policy itself.
How am I supposed to know how to make content accessible?
The University has created this website https://accessibility.georgetown.edu to includes a wealth of resources and information to help Georgetown community members understand accessibility. UIS also offers web accessibility training for community members, and the Web Services team is always available to talk through concerns or questions and assist.