Changing web governance to reflect legal concerns UNIVERSITY INFORMATION TECHNOLOGY SERVICES Changing web governance to reflect legal concerns INDIANA UNIVERSITY KOKOMO

DISCLAIMER I speak only for myself and not in any official capacity. Please consult your attorney for legal advice.

Electronic & Information Technology Accessibility Implementing regulations vary by sector: Section 504: Education Section 508: Government ADA: Commercial Business

Section 504 "No otherwise qualified individual with a disability in the United States . . . shall, solely by reason of her or his disability, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance . . . .” https://www2.ed.gov/about/offices/list/ocr/504faq.html

DOE 6/29/10 Letter FAQ “students [who have disabilities] must be afforded the opportunity to acquire the same information, engage in the same interactions, and enjoy the same services as sighted students.” Equal Access Equal ways to provide the same information https://www2.ed.gov/about/offices/list/ocr/docs/dcl-ebook-faq-201105_pg2.html

Potential outcome of OCR investigation Voluntary Agreements to improve compliance Can require reallocation of existing positions, addition of new staff to address accessibility concerns One university is now required to respond to accessibility requests within 72 business hours and either provide a document in an accessible format or provide a business justification why it cannot be done, and provide the date that it will be completed Would force Accessibility to be a top priority over and above any campus or leadership priorities for websites

Related Articles Chronicle of Higher Education: One Activist Has Hundreds of Colleges Under the Gun to Fix Their Websites A Wave of Disability-Lawsuit Threats Against Colleges May Have Receded

The Problem Over 250 people can edit at least one page on our campus website Over 200 faculty who can each edit only their individual profile page Remainder are primarily staff spread across campus Web Content Statistics (August 2017) 93 unique subsites 6,898 web pages 9,664 images 2,338 PDF documents 856 Microsoft Word documents 131 Videos (Data excludes Academic Bulletin, One.IU.edu, and videos on YouTube)

Web Assets > 2 x People Example Campus Student Headcount: 3,029 (Fall 2017) Faculty & Staff FTE: 314 (Fall 2016) Total Web Pages: 6,898 (Fall 2017)

The Problem Distributed network of content contributors can’t easily be trained on web and electronic document accessibility Many spend 5-10% of duties or less on web, and will never be web experts due to nature of position Also difficult to train them all on branding and styling per university guidelines

Potential Solutions Centralize Web Services Remove access from most staff/faculty and have them open tickets with Web Services Team for content changes Add staff to Web Services Team to handle additional load

Potential Solutions Limit Content Contributors & Improve Training Require each unit to designate a single point person who is either given access to make changes or authorized to submit change requests to Web Services Team Require these content contributors to complete an annual training or restrict their access until training is completed.

POTENTIAL SOLUTIONS Ideas?

Our Charge Be proactive, not reactive Regularly engage web customers OUR SOLUTION Our Charge Be proactive, not reactive Regularly engage web customers Engage leadership (Chancellor’s Cabinet) Set clear expectations on all sides Review/remove outdated content Remove, remediate, or provide accessible alternatives for inaccessible content

Web Annual Review Process OUR SOLUTION Web Annual Review Process First Meeting Engage Leadership to champion web review Second Meeting Unit submits content changes to Web Services Third Meeting Web Services provides changed pages for review and approval

Annual Review Process Timeline OUR SOLUTION Annual Review Process Timeline Web Services books three meetings with each office, 30 days apart (total 90 days for each review). Before first meeting, we scan and fix any broken links or web accessibility issues that don’t require client input. If input is needed, we bring those issues to the first meeting. First meeting: Invite Cabinet member / Leadership of unit (Director, Assistant Director) and Web Content Contributor Explain review process

Annual Review Process Timeline OUR SOLUTION Annual Review Process Timeline First meeting, continued: Provide a site map of currently published web pages Provide a Stale Content Report from Cascade that lists all pages, assets, images, forms, etc., with ‘Last Modified’ dates Ask client to review and flag for removal any outdated or duplicative pages, assets, etc. Suggest appropriate systems to store archived documents (Box, OnBase, etc.) Provide a list of users who have access to edit unit web pages for review and approval by leadership

Annual Review Process Timeline OUR SOLUTION Annual Review Process Timeline Second meeting: Client asked to bring the site map and content report with items marked for editing or removal Content to be added or changed should be handed to Web Services Team at this meeting Client to submit any other changes needed to their web pages until the next annual review That said, we do respond to interim requests, but we will encourage clients to think about any other changes they may need, and if time sensitive, additional follow-up meeting(s) can be scheduled

Annual Review Process Timeline OUR SOLUTION Annual Review Process Timeline Third meeting: Web Services presents completed web pages to client for review and approval Any newly created forms are transferred to client ownership at this time Web Services can confirm date of first review meeting for next cycle Can be handled via email, especially with power users

OUR SOLUTION Sample Client Visit One office recently reviewed had over 250 items contained within their web pages, including over 100 PDF files, many of which had not been updated since 2012. We asked questions like these: Does this information still need to be on the campus website? Is each page accurate and up to date? Would any documents be a better fit for services such as Box, OnBase, or Canvas? Could we convert this PDF / Word document into regular HTML? Can your paper / PDF forms be made into online forms?

Accessibility Tools WAVE: https://wave.webaim.org/ TECH TOOLS Accessibility Tools WAVE: https://wave.webaim.org/ SortSite: https://www.powermapper.com/products/sortsite/ Functional Accessibility Evaluator: https://fae.illinois.edu/abouts/ AInspector Sidebar for Firefox/Mozilla: http://ainspector.github.io/

Any Questions? Email joegrant@iu.edu.