Digital Accessibility for Digital Tools and Electronic Resources

• Titles II of the Americans with Disabilities Act of 1990, (42 U.S.C. § 12131, et. seq)
• Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. § 794d
• 28 CFR §§ 35.201-205
• Wis. Stat. § 36.12
• Wis. Stat. § 111.321
• UW System Board of Regents Policy 14-10: Nondiscrimination on Basis of Disability
• UW System Administrative Policy 655, Accessibility of Web Content and Mobile Applications

In accordance with disability laws and Universities of Wisconsin System policies, the University of Wisconsin–Milwaukee (“UW–Milwaukee”, “UWM”, or “university”) is committed to preventing discrimination based on disability. The university is required to provide digital tools and electronic resources that are, to the greatest extent possible, fully, equally, independently, and privately usable by individuals with disabilities.

Scope of this policy applies to:

All digital tools and electronic resources that are utilized by employees, students, and guests to participate in university-related services, programs, or activities.

1. Application: This policy applies to all web content and mobile apps, including third party and open source content, provided or made available for use in all university services, programs, and activities,  and ensures they are accessible, as defined by the conformance with the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA, unless this would result in a modification that is so significant that it alters the essential nature of the program, service or activity.
2. General requirements:
   1. All digital tools and electronic resources, including those developed, created, provided, or hosted by an affiliated third-party, must be accessible by meeting the minimum requirements set by WCAG 2.1 Level AA and the UW System Administrative Policy 655.
   2. Digital tools and electronic resources that cannot be made accessible due to technological or legal limitations must be accompanied by a conforming alternate version by the owner.
   3. The conforming alternate version must be provided by the individual or unit owner for the program, service, or activity. The conforming alternate version must also meet effective communication standards.
   4. Units or departments may have additional policies, practices, or procedures to ensure compliance with this policy.
3. Digital tools and electronic resources owner(s) responsibilities:
   1. All digital tools and electronic resources in the possession of the university must have an owner as defined by this policy.
   2. The owner of these assets holds the responsibility to ensure that digital tools and electronic resources meet accessibility standards.

• Accessible: Complying with the standard(s), WCAG 2.1 Level AA.
• Affiliated third-party: Except as provided for below, any individual, organization, or vendor under control or sponsorship of the university and creating, hosting, or supplying digital tools and electronic resources through contractual, licensing, or other arrangements.
• Conforming alternate version: A version of a digital tool or electronic resource that offers the same information and functionality as the original version, but in an accessible format usable by individuals with disabilities.
• Digital tools and electronic resources: Web content, software, web applications, mobile applications, cloud-based services, electronic documents, and web content used to create, deliver, or present information in digital formats, including third party services. These resources communicate information through visual, auditory, or other sensory means (e.g., public-facing websites, intranet sites, internal databases and software, email, PDFs, videos, etc.)
  1. Web Content: The information and sensory experience to be communicated by a user agent, such as software, web pages, web applications, or other digital materials, environments, or services, including code or markup that defines the content’s structure, presentation, and interactions. Examples of web content include text, images, sounds, videos, controls, animations, and conventional electronic documents.
  2. Mobile applications (mobile apps): Software applications that are downloaded and designed to run on mobile devices, such as smartphones and tablets.
• Effective communication: information delivered in an accessible format for disabled individuals.
• Owner: refers to the individual or designated role within the university who holds primary responsibility for creating, maintaining, procuring, or managing a specific digital asset, information, tool, platform, or service. This includes, but is not limited to, websites, documents, instructional materials, multimedia, software, applications (including cloud-based and mobile), and third-party tools used to deliver services, information, or programs.
• WCAG 2.1 Level AA: WCAG 2.1 Level AA are technical standards developed by the World Wide Web Consortium (W3C) Web Accessibility Initiative and available on the W3C website.

1.  Digital Accessibility oversight and coordination at UWM:
   1. The university will maintain a Digital Accessibility Coordinator (DAC) role to provide coordination and oversight for digital accessibility compliance activities at UWM, leveraging these guidelines and practices to ensure its effectiveness and sustainability.
2. Tools and training:
   1. The university, in coordination with the DAC role and other applicable units, will be responsible for providing tools, training, and other resources to aid the efforts of owners to achieve and maintain compliance.
   2. Owners are responsible for leveraging these resources in support of this work as needed.
3. University purchased and developed digital tools and electronic resources:
   1. Digital tools and electronic resources purchased by the university must include verifications of accessibility to the standards as a condition of the purchase or future use, as these tools and resources change.
   2. Digital tools and electronic resources that the university or a university employee would develop must meet digital accessibility requirements and align WCAG 2.1 Level AA and university-established guidelines and practices established by WCAG 2.1 Level AA and the university prior to their availability, use, and future iterations.
   3. A conforming alternate version, that complies with effective communication standards, of the digital tool or electronic resource, as defined by WCAG 2.1 Level AA may be used only where it is not possible to make content directly accessible due to technical or legal limitations.
4. Student, program participant, and student-organization digital content:
   1. Digital tools and electronic resources created by students or program participants for personal use are generally exempt from this policy.
   2. Digital tools and electronic resources created by students or program participants as part of any university course or activity requirement for use by others to apply to, participate in, or benefit from a program, service, or activity must be accessible.
   3. Digital tools and electronic resources created or hosted by registered student organizations are generally exempt from this policy unless the digital content is for use in a university-sponsored program, service, or activity.
5. Equity and Effectiveness:
   1. Documents (e.g., Word, Excel, PDF, PowerPoint, ePub, etc.) shared with or distributed to a select population must be presented in their original file format unless the distribution requires an alternative format (such as a PDF). In this case, a conforming alternate version (such as a PDF) must be fully accessible at the time of distribution.
   2. Text alternatives, captions, and audio descriptions must meet the effective communication standards at the same level of information available for nondisabled individuals.
6. Exemptions, Complaints, and Non-compliance:
   1. Requests for exemptions to this policy must be submitted upon discovery to the DAC for approval as appropriate.
   2. Individuals may submit information or issues about digital accessibility barriers using the Digital Access Issue form.
   3. Individuals may file discrimination complaints concerning digital accessibility with the Office of Equal Opportunity and Civil Rights pursuant to Selected Academic and Administrative Policy (SAAP) 05-01 Discriminatory Conduct and Consensual Relationships Policy.
   4. Digital tools and electronic resources found in non-compliance with this policy will follow standard university practices and applicable policies for remediation or removal of content or tool.

1. Web Accessibility Reporting Form 
2. Accessibility at UW-Milwaukee
3. Digital Accessibility Guidelines at UW-Milwaukee
4. Wis. Stat. § 36.12: Student Discrimination Prohibited
5. SAAP 05-01 Discriminatory Conduct and Consensual Relationships Policy
6. Wis.Stat. § 111.322: Discriminatory Actions Prohibited