Scope
This procedure supports Michigan Technological University's Accessible Information and Communication Technology (ICT) Policy 1.15. It applies to electronic documents made available on public facing University webpages within the mtu.edu domain and associated subdomains, and includes web-based documents from third-party services purchased for core business and academic activities. Examples of common document file formats covered in these procedures include PDF (.pdf), Word (.docx), and PowerPoint (.pptx).
Technical Standard
Michigan Tech has adopted the Web Content Accessibility Guidelines (WCAG) 2.1 A/AA conformance level to measure, coordinate and implement compliance with the University Accessible ICT policy. Electronic documents must comply with WCAG 2.1 guidelines and success criteria as applied to non-HTML ICT content. In addition, electronic documents must also comply with the rules set forth by the Department of Justice on April 8, 2024. This includes the need for all electronic documents (examples include course materials, flowcharts, poster advertisements, etc) to be made accessible regardless of an accessible companion HTML webpage.
Consult the Department of Justice's web rule fact sheet or the full, final rule for more information on these additional requirements.
Procedure Conformance
Michigan Tech has assigned web accessibility coordinator responsibilities including the coordination, implementation of, and compliance with the University Accessible ICT policy to the ICT Accessibility Coordinator, IT Communication and Accessibility Manager, and their respective designees.
Training
Document accessibility training is required for any faculty, staff, administrators, and student employees who are responsible for the creation and/or distribution of electronic documents housed in official University websites or third party sites used in core academic and business activities. The training will provide information on how to create accessible documents or remediate existing documents to make them accessible.
Identifying Issues via Audits
Web accessibility audits will be conducted on a periodic basis. These audits will measure online content against the technical standard adopted in these document accessibility procedures. Inaccessible electronic documents housed in official University websites will be documented.
Correcting Issues
This procedure explicitly grants the ICT Accessibility Coordinator, IT Communication and Accessibility Manager, or their designees, the authority to take corrective actions.
In-House Created Content
Inaccessible documents created by Michigan Tech personnel must be remediated (where feasible), replaced with accessible versions, or removed.
- An initial notice of policy violation will be submitted to the web liaison or responsible party by the ICT Accessibility Coordinator, IT Communication and Accessibility Manager or designated individual, including a due date for correction not sooner than 30 days from the date of notice.
- If not corrected by the notice due date, a second notice of policy violation will be submitted to the web liaison or responsible party and their supervisor, including a due date for correction not sooner than 30 days from the date of the second notice.
- If not corrected by the second notice due date, a third notice of policy violation will be submitted to the web liaison or responsible party and their supervisor, with notice of the date when corrective action must be taken not sooner than 30 days from the date of third notice.
- If a corrective action is not taken during this outlined timeline, removal of the electronic documents in question or unpublishing of the page or website on which they reside may occur.
Correction Appeals
Formal appeals must be submitted to the Accessible Technology Working Group at accessibility-l@mtu.edu. Upon receipt, the correction process will be placed on hold while the appeal is evaluated. The Accessible Technology Coordinator and IT Communication and Accessibility Manager will manage the appeal process with final authority residing with Equal Opportunity Compliance. All appeal decisions will be made within 30 days.
Supporting Information
A recommended checklist is offered below for web liaison or responsible parties of inaccessible documents to help determine appropriate action:
- Determine if it’s necessary to continue posting the document on the website. You may discover that a document’s useful life has ended. If so, remove it. A document’s access history can be provided to help with this determination.
- Determine whether to remediate the existing document or create a new accessible version. Remediation may be appropriate if you have access to the source document (Word, Google Doc, etc.) versus the PDF version on the web. While it is possible to remediate PDF files for accessibility, it can be a time-consuming process depending on document complexity.
- If document remediation is not elected, creating a new, accessible version of the document is usually the more efficient recommended option.
Document Storage
Not sure where to store your documents?
Regardless of where digital documents are stored—whether in the CMS, Google Drive, or another platform—accessibility requirements still apply if those documents are shared online through websites, email, or other public channels. Moving documents outside the CMS does not exempt them from accessibility obligations or reduce our responsibility to provide accessible content. In fact, it makes compliance more difficult by preventing our campus accessibility scanning tools from identifying inaccessible documents, placing more responsibility on content owners to manually review and maintain those files. Ensuring that publicly shared documents meet accessibility standards remains the responsibility of the content owner, regardless of where the files are stored. We recommend storing all documents in the CMS where UMC can assist with monitoring them for compliance.