Electronic & Information Technology Accessibility Policy

Smith College is committed to providing equal opportunity to persons with disabilities, including equal access to participate in and benefit from college programs, services and activities provided through electronic and information technology (EIT). It is important that accessibility is in the forefront as we design, build, acquire or use new EIT. Therefore, this policy establishes minimum standards and expectations regarding the design, acquisition or use of EIT to achieve the college’s legal,¹ moral and ethical commitments in the digital environment.

1. The American with Disabilities Act of 1990 (ADA) and Section 504 of the Rehabilitation Act of 1973

This policy extends to the college’s electronic and information technologies and applies to their procurement, development, implementation and ongoing maintenance.

All members of the Smith community with responsibility for creating, selecting, procurement, developing, implementing and maintaining electronic and information technologies are responsible for ensuring that such technologies are compliant with this policy and the related standards.

It is the policy of Smith College that all community members must make a reasonable effort to ensure that electronic and information technology (EIT) be accessible to students, employees and the general public, except as described below or otherwise governed by applicable law.

This policy is in accordance with federal and state laws including the Americans with Disabilities Act of 1990 (ADA), as amended, and Section 504 of the Rehabilitation Act of 1973.

Standards for Policy

College community members will follow the standards related to the procurement, development, implementation, and ongoing maintenance of EIT (the “Accessibility Standards”).

Exceptions

When conformance to the standards 1) fundamentally alters a program, service, or activity, 2) creates an undue administrative burden, or 3) is not technically feasible, the individual, office or department sponsoring the program, service or activity must provide equally effective alternative access that communicates the same information in as timely a fashion as does the original format or medium.

These definitions apply to terms as they are used in this policy. 

“Accessible” means that individuals with disabilities are able to independently acquire the same information, engage in the same interactions, and enjoy the same services within the same timeframe as individuals without disabilities, with substantially equivalent ease and effectiveness of use.

“Electronic and information technology” or “EIT” includes information technology and any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information. The term electronic and information technology includes, but is not limited to, the internet and intranet websites, content delivered in digital form, electronic books and electronic book reading systems, search engines and databases, learning management systems, classroom technology and multimedia, personal response systems (“clickers”), and office equipment such as classroom podiums, copiers and fax machines. It also includes any equipment or interconnected system or subsystem of equipment that is used in the automatic acquisition, creation, storage, manipulation, management, movement, control, display, switching, interchange, transmission or reception of data or information. EIT includes telecommunications products (such as telephones), information kiosks, automated teller machines (ATMs), transaction machines, computers, ancillary equipment, software, firmware and similar procedures, services (including support services), equipment maintained and services operated by third-party vendors, and related resources.

“Equally effective alternative access,” with respect to electronic and information technology, means an alternative format, medium or other aid that accurately and in a timely manner communicates the same content as does the original format or medium, and which is appropriate to an individual’s disability. To provide equally effective alternative access, the college need not ensure that qualified individuals with disabilities achieve the identical result or level of achievement as individuals without disabilities, but the college must provide appropriate auxiliary aids and services as necessary to afford individuals with disabilities an equal opportunity to obtain the same result, gain the same benefit or reach the same level of achievement, in the most integrated setting appropriate to their needs. In providing equally effective alternative access, the college may rely on any commonly accepted standard or combination of standards provided the remainder of this definition is met. The college is not required to take any action that results in a fundamental alteration in the nature of a service, program or activity, or in undue financial and administrative burden, but must nevertheless ensure, to the maximum extent possible, that qualified students with disabilities receive the benefits or services provided by the college.

“Undue administrative burdens” are created when a proposed course of action causes significant difficulty.  Because an institution must consider all resources available when reviewing claims of undue administrative burdens, the decision to invoke undue administrative burdens should be carefully weighed, sufficiently documented and ultimately authorized by the president or designated official. In situations where undue administrative burdens can be documented, equally effective alternative access must still be provided.

Resources

• Office for Equity and Inclusion
• Accessibility Resource Center
• Risk Management

Additional Reference Material

• The Americans with Disabilities Act
• Section 504, Rehabilitation Act of 1973