Captioning and Open Access Technology (Procedure #1110.A)

The University of Wisconsin-Whitewater is committed to supporting students, faculty, and staff accessibility across campus within both spatial and virtual considerations. This commitment means that UW-Whitewater facilitates a culture of accommodation with intrinsic best practices for all members of the campus community, regardless of ability, by operationalizing inherent virtual and physical accommodations-related practices.

Office of Human Resources (ADA Coordinator)

Alternate Formats: Alternate formats usable by people with disabilities may include, but are not limited to, Braille, ASCII text, large print, and recorded audio, among other formats.

Alternate Methods: Different means of providing information, including product documentation, to people with disabilities.

Disability: 

• A physical or mental impairment that (1) makes achievement unusually difficult or limits the capacity to work and/or (2) substantially limits one or more major life activities
• A record of such an impairment; or
• Being perceived or regarded as having such an impairment.

Open Access: Refers to accessibility measures that are built proactively into an event, and do not need to be requested on a case-by-case basis.

Voluntary Product Accessibility Template (VPAT): A document which evaluates how accessible a particular product is according to the Section 508 Standards. It is a self-disclosing document produced by the vendor, which details each aspect of the Section 508 requirements and how the product supports each criteria. Requestors for VPAT related software can be any of the following: an individual, department, unit, research project or grant, division, UW-Whitewater or UW-System. The software can be operated on a local computer, hosted by the University or System, or third-party hosted (including cloud or off site based).

The University of Wisconsin-Whitewater provides resources to the campus community concerning a variety of disabilities and actively collaborates with students, faculty, and staff to create an inclusive, accessible university experience.

A. Online Accessibility for Meetings and Events

UW-Whitewater strives to achieve open access for online meetings and events in which accessibility measures are built proactively into these virtual gatherings. At minimum, when a department or unit hosts meetings or events (whether they are area-specific or campus-wide, in-person or virtual) it is critical for the host facilitator to ensure appropriate accessibility technology or services are made available upon request.

• Internal Department/Unit Meeting or Event Procedure
  Accommodations only need to be provided upon request. For example, staff meetings do not have an expectation to provide captioning if not requested. Utilizing automatic captioning within video conferencing platforms is a recommended best practice to exercise when available. Contact the ADA Coordinator for guidance when addressing employee accommodation requests.
• Student-related Meeting or Event Procedure
  Contact CSD if a student requests an accommodation related to coursework needs.
• Large, Community-oriented Meeting or Event Procedure
  Refer to the Virtual Event and Open Access Quick Guide for an accessible event checklist and resources for managing your own open access meetings and events.

Examples of accommodations may include:

• • an interpreter,
  • interpretation software, or
  • activating built-in software features that allow closed captioning for in-person and/or virtual meetings, events, or activities.

Examples of meetings, events, or activities may include but are not limited to:

• • Town Hall Meetings,
  • Graduation Ceremonies, or
  • Training videos/webinars, etc.

After the host department or unit facilitator reviews the Virtual Event and Open Access Quick Guide and still requires special assistance, they can submit their request via the ITS Help Desk via
helpdesk@uww.edu or (262) 472-4357. Assistance may be provided with support from CSD when appropriate. Meetings and events must be addressed on a case-by-case basis. Depending on the
needs of the department/unit hosting the meeting, event, or activity and the associated timeline, it may be necessary for the department or unit to pay for these accommodations-based services
provided by subject-matter experts within relevant departments including but not limited to CSD, ICIT, or vendors approved by UW System.

• General Best Practices
  Visit the Virtual Event Captioning Quick Guide for reference, which includes a checklist and
  hyperlinked resources for planning guidelines, day-of best practices, and post-event finalization
  steps. Topics include:
  • Publicity
  • CART/ASL Preparations
  • Responding to Accommodations Requests
  • Access Announcements
  • Recorded Video Captions
  • Common “Do’s and Don’ts”

B. Voluntary Product Accessibility Template (VPAT)

VPATs are used by departmental purchasing requestors to determine how accessible a software product is and where any potential deficiencies may be. This procedure provides guidance on how to review for accessibility. The following considerations were developed to support these related needs, and reflect our W3C Web Accessibility Initiative:

• Will it work on current hardware and software?
• Can it be used with current security requirements?
• Are text alternatives for non-text (images, graphics, videos, etc.) content in place?
• Are captions and audio descriptions embedded in multimedia formats?
• Does content cause seizures?
• Can the Users easily navigate, find content, and determine where they are and how to use?
• Is the text readable and understandable?
• Are Users helped to avoid and correct mistakes?
• Are updates, drivers or patches part of the purchase or is this additional cost?

1. NOTE: When software is purchased, it is the responsibility of the requestor to:
   • ensure that the software complies with UW-Whitewater technology and accessibility policies, standards, and regulations.
   • ensure the software will be accessible to the identified users or audience.
   • determine if there are accessibility issues post-purchase
   • identify any necessary, associated costs. 
2. Identify the software and determine if there is comparable University accessibility technology currently used by either employees or students. UW-Whitewater has identified a bundle of accessibility software for use in all classrooms, labs, and general access computers for student access. Requesters are encouraged to contact the ITS Help Desk for guidance via helpdesk@uww.edu or (262) 472-4357. 
3. Determine if unique users are using individualized adaptive technology. The University does not have standardized accessible software for employees. Accessibility is more specific to individuals with disabilities; however, many accessibility requirements also improve the usability for everyone. 
4. Request the accessibility standards from the company directly, even if purchasing through a third party. If a full VPAT is recommended by the iCIT Help Desk, then have all vendors (items needing multiple bids) or the vendor (I.e. sole source, RFP, RFB, simplified bid, or purchase under $4999.00) complete the Voluntary Product Accessibility Template (VPAT).
5. Determine if the software will comply with UW-Whitewater technology policies, agreements and procedures in general. Ensure that the software is able to allow information to be in perceivable format. The following units or departments may assist with assessing for compliance: 
   • ICIT for purchasing/procurement
     • General Computer and classroom access
   • Financial Services for purchasing/procurement
   • Center for Students with Disabilities for student access
   • Human Resources for employee access
   • ADA Coordinator for guest access
   • Facilities for physical access
6. Attach the VPAT to the Purchase Request for processing. If aspects of the software are identified as not accessible, include justification for the purchase or how access will be created. The Purchase Request may be returned if sufficient documentation is not presented.

If there are unanswered questions or additional procedures involved, individuals are encouraged to consult the ITS Help Desk via helpdesk@uww.edu or (262) 472-4357. 

Regent Policy Document 14-10: Nondiscrimination on the Basis of Disability

Wis. Stat. 106.52

2005 Wisconsin Act 354

Section 508 of the Rehabilitation Act of 1973

Section 255 Guidelines of the Telecommunication Act of 1996

Americans with Disabilities Act of 1990

First approved: January 21, 2021