Web Accessibility Procedures

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Procedures statement

The University of California, Berkeley (“Berkeley”) is committed to making its websites and other online content accessible to all individuals. These Procedures are intended to carry out that commitment, and to meet web accessibility requirements for public content set forth in the University of California IT Accessibility Policy (ITAP), and a judicially supervised Consent Decree between the Regents of the University of California, acting on behalf of Berkeley, and the United States Department of Justice, regarding the accessibility of Berkeley’s public online content to users with disabilities. These Procedures, which may be periodically updated, are intended to ensure that all people are meaningfully able to enjoy and access Berkeley’s public online content.[1]

The Digital Accessibility Program is the campus unit responsible for the implementation of the Web Accessibility Procedures.

Who/What does this apply to?

These Web Accessibility Procedures and the requirements herein apply to “Online Content", “Covered Individuals” and "Berkeley Entities.” Each of these terms are described below in the "Definitions" section. Put simply, these procedures apply to Berkeley faculty, staff, and contractors who upload or manage any public Berkeley.edu website or any public audio or video content (either on Berkeley.edu or a third-party platform) controlled by Berkeley central administration or any Berkeley school, college, department, program, or academic unit.[2]

The Web Accessibility Procedures also establish recommended guidelines as best practices for those who are members of the Berkeley community who are not otherwise Covered Individuals. All members of the Berkeley community are encouraged to follow the Procedures as recommended guidelines and best practices in developing and uploading online content.[3]

Definitions

The Consent Decree uses specific definitions to outline who is subject to the Consent Decree, and which content must meet the Decree’s requirements. Unless otherwise noted, the Procedures use the terms as defined in the Consent Decree, which we set forth here:

  • Berkeley Entity/Entities: the central administration of Berkeley and any Berkeley school, college, department, program, or academic unit. Individual students and student groups are not Berkeley Entities.
  • UC Berkeley Platforms:
    • BerkeleyX;
    • Berkeley.edu and any subdomain of berkeley.edu that may be accessed by the general public and that is controlled by a Berkeley Entity;
    • any podcast channel or account controlled by a Berkeley Entity that is hosted on a third-party platform, such as Apple Podcasts and Spotify; and
    • any other audio or video channel or account controlled by a Berkeley Entity that is hosted on a third-party platform, such as YouTube or Vimeo.
  • Online Content: content created, developed, uploaded, or controlled by a Berkeley Entity, and made publicly available by a Berkeley Entity on any UC Berkeley Platform. “Online Content” includes (but is not limited to) content that is posted or uploaded on any UC Berkeley Platform by an individual faculty member acting within the scope of that faculty member’s employment. This includes publicly available faculty-created content related to courses, symposia, events, lectures, webinars, and podcasts.
  • Covered Individuals: an officer, employee, contractor, or other individual whose duties include creating, uploading and managing Online Content on a UC Berkeley Platform on behalf of a Berkeley Entity.
  • Audio and Video Content: Online Content in audio or video format.

What are the accessibility guidelines?

All Online Content must comply with the technical standard, Web Content Accessibility Guidelines (“WCAG”) 2.0, Level AA, as prescribed by the World Wide Web Consortium, unless an exception applies. Please see the "What are the exceptions" section for details on issues related to fundamental alteration, third-party platforms/technology, and third-party Online Content.

For publicly available content published by members of the Berkeley community that is not subject to these Procedures, it is strongly encouraged that the content meet the WCAG 2.0, Level AA accessibility standards, and such content may still be subject to the UC Information Technology Accessibility Policy requirements.

What am I required to do?

This section explains when Berkeley’s Online Content must meet the technical standard for web content accessibility. We will provide detailed training for Covered Individuals who manage and create Online Content on behalf of a Berkeley Entity. Some examples of compliance with these standards are also shared in the "What training and resources are available" section. We have outlined certain exceptions to these requirements in the "What are the exceptions" section.

Websites

Websites on berkeley.edu and its subdomains are required to follow WCAG 2.0 AA standards.

BerkeleyX Online Courses

BerkeleyX courses are required to follow WCAG 2.0 AA standards. If you would like to learn more about accessibility in BerkeleyX courses, please contact berkeleyx@berkeley.edu.

Audio Content

Audio-only content, including, for example, podcasts delivered on various platforms like iTunes, Apple Podcasts, and Spotify, must follow WCAG 2.0 AA standards, unless an exception applies. This includes providing an accurate transcript of the audio content so that those who are deaf or hard of hearing may also have access to this public content.

Video Content

Video Content on Berkeley Entity-controlled, public platforms like YouTube and Vimeo as examples, must follow WCAG 2.0 AA standards, unless an exception applies. This includes, but is not limited to, providing accurate captions. Captions are considered accurate when, among other things, they:

  • have correct punctuation and spelling;
  • are correctly synchronized with audio, i.e., the captions appear when the audio is heard;
  • if there is more than one speaker, identify each speaker; and
  • describe non-verbal audio, such as “music” or “laughter.”

When will online content be made accessible?

  • Much of Berkeley’s Online Content is already accessible. These Procedures will help us further our goal of ensuring that Berkeley’s Online Content can be enjoyed by all.
  • All BerkeleyX Online Content must comply with the WCAG 2.0 AA standards by no later than September 2, 2023.
  • All Audio and Video Content published on or after December 2, 2022 (both on berkeley.edu websites and on third-party platforms) must comply with the WCAG 2.0 AA standards by no later than September 2, 2023.
  • Berkeley.edu: All berkeley.edu websites and webpages that qualify as Online Content must conform to the WCAG 2.0 AA standards by no later than June 2, 2024.
  • Existing Audio and Video Content: All Audio and Video Content published prior to December 2, 2022 (both on berkeley.edu websites and on third-party platforms), except Audio and Video Content that falls within the “Legacy Content” exception below, must comply with the WCAG 2.0 AA standards by no later than December 2, 2025.

What are the exceptions?

There are exceptions that are included within this section of the procedures. If you have questions about any of the exceptions listed here, please contact improving-accessibility@berkeley.edu.

  • Legacy Content with Fewer Than 750 Views/Plays. We encourage you to make all content accessible. However, existing Audio and Video Content need not be made accessible pursuant to the Consent Decree if it was published prior to December 2, 2020, and has less than 750 views (or had less than 750 views as of December 2, 2022) (“Legacy Content”). Nevertheless, we encourage you to make accessible Legacy Content that falls under this exception. And if you receive a request to make specific excepted Legacy Content accessible, please contact improving-accessibility@berkeley.edu immediately for guidance and questions.
    • Podcast Content. All podcast content that is on a UC Berkeley Platform must be made accessible, regardless of the date of posting or the number of downloads or plays. The legacy content exception does not apply to podcast Content.
    • Berkeley.edu Website Content. All Audio and Video Content on Berkeley.edu must be made accessible, regardless of the date of posting or the number of downloads or plays.
  • Color Contrast on Videos Recorded Before December 2, 2022. Because color contrast cannot be fully corrected on pre-recorded videos, Video Content that was recorded before December 2, 2022 does not need to comply with any applicable color-contrast-related accessibility standards prescribed by WCAG 2.0.
  • Technological Limitations on Third-Party Platforms. A significant amount of Online Content, particularly Audio and Video Content, is hosted on third-party platforms such as YouTube. That Online Content must be made accessible as described in these procedures. But if the limitations of the third-party platform prevent you from making your Online Content accessible, you are not responsible for coming up with a solution for those limitations.
  • Lack of Access. There is no obligation to make specific Online Content accessible if: (1) administrator access to a website, webpage, or an account hosted on a third-party platform is necessary to make Online Content accessible, and no Covered Individual has or can obtain such access; or (2) the original source file of Online Content is necessary to make that Online Content accessible, and the original source file cannot be accessed by any Covered Individual.
  • Third-Party Content That is Linked to, or Embedded on, a Berkeley.edu website. Berkeley webpages managed by Covered Individuals will frequently link to third-party websites. They may also embed content that is created by, and hosted on, a third party’s website.

    The accessibility requirements in these Procedures apply only to Online Content controlled by Berkeley Entities. As a result, if you link to, or embed, third-party content that a Berkeley Entity does not control, you are not obligated to make that content accessible.

    For example, if you embed a video hosted on a third-party news organization’s YouTube channel or website, and the video lacks captions, you are not responsible for generating captions for that video.

    Berkeley Entities and Covered Individuals are required to use an accessible form of third-party content if it is available. If, for example, you are aware of two versions of a third-party’s video content—one with captions, and one without—and both versions are available to you, you are obligated to use the version with captions.
  • Fundamental Alteration and Undue Burden Cases. In certain cases, applying the WCAG 2.0 AA standards to Online Content may fundamentally alter that content (“Fundamental Alteration”). In other cases, making Online Content accessible may be unduly burdensome (“Undue Burden”). If applying the WCAG 2.0 AA standards to particular Online Content would cause a Fundamental Alteration or an Undue Burden, you may not be required to fully comply with those standards. Please note, however, that the decision regarding whether the Fundamental Alteration or Undue Burden exception applies for your Online Content cannot be made by you alone; it must be made following the process set forth below (after the examples).

    Examples may include: (1) your website hosts an online exhibit of a notable artist’s work, which includes audio content consisting of non-verbal sounds that invite the listener to interpret the sounds, and a text description or caption would not be adequate because each experience is subjective; or (2) there is unique Online Content on a Berkeley Website that cannot be made accessible unless an exorbitant, bespoke accessibility solution is created for that Online Content.

    Fundamental Alteration or Undue Burden determinations are made on a case-by-case basis. Note that even similar cases may result in different determinations on whether the Online Content must be (or can be) made fully accessible.

    If you believe that Online Content cannot be made to conform to WCAG 2.0 AA without resulting in a Fundamental Alteration and/or Undue Burden, you must contact improving-accessibility@berkeley.edu with a link to the Online Content in question, and summarize the reasons why making the Online Content accessible will lead to a Fundamental Alteration or an Undue Burden. Berkeley’s Web Accessibility Coordinator will review the request and will contact you regarding next steps.

    Even if Fundamental Alteration and/or Undue Burden apply, the Berkeley Entity and/or Covered Individual responsible for that content must ensure that, to the maximum extent possible, qualified individuals with disabilities are able to access the substance of that content.

What is the process for public requests for accessibility?

Members of the public may submit feedback, complaints, or requests that specific Online Content be made accessible. This request form will be made available on the main Berkeley.edu website, the Digital Accessibility Program website (dap.berkeley.edu), and the Disability Access and Compliance website (dac.berkeley.edu).

We will respond to requests and feedback within seven days of receiving a request or feedback (for the latter, only if a response is necessary or requested).

We welcome all comments and suggestions about our digital accessibility efforts, including reports about accessibility barriers. We note, however, that our accessibility work is ongoing, and we anticipate that Online Content covered by the Consent Decree and covered by these Procedures will be made accessible within the timeframes that we provide above.

We will address the accessibility barrier within 14 days of receiving a request. We may require an additional 14 days to address the barrier; if more time is necessary, we will inform the requester. We note, however, that Online Content that is currently being reviewed and made accessible under the timelines above (“When will online content be made accessible?”) may not be made accessible within the time periods specifically provided in this section. If we receive an accessibility request for Online Content identified in the section titled “When will online content be made accessible?”, we will prioritize addressing the barriers identified in that request—but we can make no guarantees as to timing, other than the timelines provided in the “When will online content be made accessible?” section.

Whenever we are notified that a specific item of Online Content has accessibility barriers that should be removed, we will engage in a good-faith effort to make the content at issue accessible rather than remove the content from public access.

What training and resources are available?

Covered Individuals will receive training and guidance on how to comply with the Procedures as part of their mandatory training. Guidance on how to implement the WCAG 2.0 AA standards will be made available to all members of the university community at Web Accessibility Training of the Digital Accessibility Program website. All creators and managers of Online Content, regardless of whether they are Covered Individuals, are encouraged to review the guidance once it is made available.

Generally, the WCAG are intended to address a diverse array of abilities and barriers. For example:

  • Audio content, including audio-only files and videos with voices and sounds, should include captions or transcripts, which help eliminate barriers for people with auditory disabilities.
  • Alternative text (hidden text descriptions of images read by screen readers), text and images with sufficient color contrast, and full keyboard support for website navigation are some of the features that help eliminate barriers for people with visual disabilities.
  • Ensuring that forms, buttons, and other components of a website are properly labeled and formatted in a way that allows for keyboard-only navigation, as well as providing different ways of navigating a website (such as a menu and a search bar), may help eliminate barriers for people with manual, visual, cognitive, learning, and neurological disabilities.

This is intended to be an illustrative, not exhaustive, list of ways that Online Content can be made accessible. If you have any questions regarding how specific Online Content can be made accessible, please contact improving-accessibility@berkeley.edu.

Who is the contact for questions about these procedures?

For questions about the Web Accessibility Procedures, please contact Suzanne Harrison, Berkeley’s Web Accessibility Coordinator, at improving-accessibility@berkeley.edu.

Footnotes

[1] We are currently in the process of updating other web accessibility guidance documents so that they align with these Procedures. To the extent that other existing guidance documents require more than the minimum accessibility standards established in these Procedures, those documents remain in effect. If a conflict arises between these other documents and these Procedures, these Procedures will control. (Go back to reference 1.)

[2] “Central administration” refers to the offices of university leadership, such as the Chancellor, the Executive Vice Chancellor and Provost, Vice Chancellors, and the Vice Provosts. (Go back to reference 2.)

[3] Content that is not available to the general public, and available only to Berkeley faculty members, staff, and/or students, is not subject to these Procedures, but may be subject to ITAP. (Go back to reference 3.)

Individual students and student groups are not subject to these Procedures.

Faculty members are not required to follow the Procedures for content on personal pages or accounts; however, faculty content available to the general public (such as courses, lectures, and symposia) on any Berkeley.edu website controlled by a Berkeley Entity or on any account on a third-party platform (such as YouTube or Spotify) controlled by a Berkeley Entity is subject to the requirements of these Procedures.