Information and Communication Technology Accessibility Policy (POL_ICT_2019_029)

Policy No. #: 2019-029 e-Learning Course Demos

I. General Policy Statement

This policy ensures that members of the e-InnoTech including divisions SecuRetain and e-InnoSec and their guests can effectively access e-InnoTech content and Information and Communication Technologies This policy covers all content and technology, including websites, web-based and mobile applications, email, instructional materials, electronic documents, blended and online courses, and all academic and administrative software applications acquired or adopted after the effective date of this policy. The e-InnoTech aims to make content and technology accessible to current and prospective customers (platform users), employees, visitors, and the public.

II. Reason for Policy/Purpose

Information and Communication Technology (defined below in Section V) - especially the Internet - is essential to the training mission of the e-InnoTech, includes e-learning, research, and critical administrative and employment functions. e-InnoTech values diversity, and accessible Information and Communication Technology is an important component of an inclusive e-InnoTech. This policy serves to integrate accessibility into all levels of Information and Communication Technology at the e-InnoTech in compliance with federal and state laws and guidance, thus enabling full participation by all.

III. Policy

Accessibility of Information and Communication Technology

In its commitment to diversity and inclusion, e-InnoTech will seek to ensure that individuals with disabilities are afforded equal access to Information and Communication Technology used by the e-InnoTech and its constituents. As such, and except as set forth below in Section III, the e-InnoTech commits that Information and Communication Technology products and services acquired, adopted, developed or updated after the effective date of this policy, shall be accessible to individuals with disabilities.

As a means of measuring accessibility, unless excluded below in Section III, all Information and Communication Technology at a minimum shall comply with the e-InnoTech Information and Communication Technology Accessibility Policy Standards.

ICT Governance

The ICT Accessibility Assessment Committee will be responsible for policy governance and implementation, and it includes the e-InnoTech ’s Human Resources Head, Accessibility Coordinator, Chief Operating Officer (COO) and Product/Services Procurement Lead. The committee will address the following:

  • Perform process reviews and gap analysis for accessibility
  • Prepare an action plan for compliance of inaccessible ICTs and maintaining records for tracking.
  • Managing VPAT documentation and governance
  • Work on the alternate means of access until the ICT is accessible.
  • Implementing a corrective actions process(s) and maintain records


Certain Information and Communication Technology (ICT) may be excluded from the mandates of this policy, including:

  • A single instance, specialized software or hardware purchased For Individuals use.
  • When compliance is not technically possible, would require a fundamental alteration, or would result in an undue burden, exceptions to the policy may be granted through the exception review process (outlined below in Section V) and shall be appropriately documented.

While approving the exceptions the ICT team will follow the e-InnoTech governance process, seek guidance from an external consultant, and management approval for policy exception.

IV. To Whom Does This Policy Apply

  • Customers
  • Employees
  • Guests/Visitors
  • Other Vendors & Suppliers

V. Appendices

A. Procedures

1. Compliance

Assessment of ICT products and services acquired or developed after the effective date of this policy shall follow the process outlined in the Procurement Accessibility Review Procedures. All ICT purchase requests will be reviewed for accessibility and a report submitted to the ICT Accessibility Assessment Committee. The ICT Accessibility Assessment Committee can approve the purchase, approve the purchase with conditions, or deny the purchase.

If denied, exceptions to the policy may be granted by the Information and Communication Technology Accessibility Compliance Committee (“ICT Accessibility Compliance Committee”).

Whenever an exception is granted, the e-InnoTech must use reasonable efforts to develop a plan for the functional or administrative unit seeking the exception to provide equally effective alternate access to the information or service of the technology to clients or employees with disabilities who need to access the information or service.

All approved exception requests are termed such that they will need to be evaluated every two years or at the time of the contract renewal of the product or resource.

2. Assistance

Requests for assistance with Information and Communication Technology Accessibility can be sent to Additional information can be found on the website.

3. Complaints

Any individual who has complaints about the accessibility of the e-InnoTech ’s Information and Communication Technology should contact Information Technology Services at

B. Definitions

  • Information and Communication Technology. Information technology and other equipment, systems, technologies, or processes, for which the principal function is the creation, manipulation, storage, display, receipt, or transmission of electronic data and information, as well as any technology-based equipment.
  • Information and Communication Technology Accessibility Compliance Committee. This is the committee responsible for reviewing requested exceptions to this policy. The ICT Accessibility Compliance Committee is co-chaired by the Director of Information Technology and the e-InnoTech ’s Coordinator.
  • Information and Communication Technology Accessibility Assessment Committee. This is the committee that is responsible for reviewing new e-InnoTech wide ICT purchases to ensure they comply with this policy. The ICT Accessibility Assessment Committee includes the e-InnoTech ’s Human Resources Head, Accessibility Coordinator, and Product/Services Procurement Lead.
  • Information Technology. Any equipment or interconnected system or subsystem of equipment, that is used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. The term information technology includes computers, ancillary equipment, software, firmware and similar procedures, services (including support services), and related resources.
  • Electronic Document. Any file that is posted or distributed electronically. These files usually are created, edited, and viewed or otherwise encountered with desktop and cloud productivity software and can be saved in a local file format or stored online for collaboration and presentation purposes. Common examples of software used to create such files include Microsoft Office, Google Documents, Sheets, and Adobe Acrobat, Illustrator, and Designer products.
  • Fundamental Alteration. A change to the e-InnoTech program or service that alters the essential purpose of the program or service or any of its components.
  • Accessible. A person with a disability is afforded the opportunity to acquire the same information, engage in the same interactions, and enjoy the same services as a person without a disability in an equally effective and equally integrated manner, with substantially equivalent ease of use.
  • Archive Web Site or Page. A Web site or the page no longer in use but subject to records retention plans.
  • Assistive Technology. Any item, piece of equipment, or system, whether acquired commercially, modified, or customized, that is commonly used to increase, maintain, or improve functional capabilities For Individualss with disabilities.
  • Standards and Guidelines. Following the e-InnoTech ’s guidelines and standards will add functionality and usability for all users, including users of assistive technology. The current Information and Communication Technology standard and web accessibility guidelines are available on the e-InnoTech ’s knowledge repository.
  • Mobile Applications. Mobile web content, mobile web apps, native apps, and hybrid apps developed for handheld devices such as smartphones, tablets, and more.
  • Web-based Applications. Usually provided by self-hosted and third-party contracted services, web-based applications are any services that are provided online through a web-browser, but not specifically in a web page format. Examples include, but are not limited to administrative portal, webmail, learning management system, web-conferencing, course catalog, student advising, and data warehouse.
  • Web Page. A single Internet address (aka URL) that contains content that must be viewed or otherwise encountered by using a web browser. Usually, multiple web pages are linked to define a website.
  • Website. A group of connected web pages regarded as a single entity, or several closely related themes, such as a college, department, or office website. A website usually consists of a home page and related sub-pages.
  • Restricted Access to Technology. Products installed in locations with restricted access such as data centers, and which are not interacted with except during maintenance, are not required to be accessible.

C. Policy Review

The Office of the Director for Information Technology will initiate a review of and make necessary revisions to this policy at least once the first year and every two years with the input of a review group. The review group will include, but not be limited to the members of the Information and Communication Technology Accessibility Compliance Committee.

D. Federal and State Regulatory Requirements

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