ICT Use and Purchase Procedures
In accordance with the University’s Access to Programs,
Services, Information, and Technology Policy Statement, the following purchase
and use procedures have been implemented for Information and Communication Technologies (ICT).
With the exception of
technology purchases intended for one
individual’s sole use, all ICT purchases
are required to be reviewed for compliance prior to procurement.
Note to purchasers:
This procedure for purchasing ICT is
required in order to assure that all products
are accessible to individuals with disabilities. All applicable University
purchasing policies must be adhered to. http://nau.edu/Contracting-Purchasing-Services/
determining the accessibility of a product should be directed to firstname.lastname@example.org.
I. Legal Requirements for
Educational institutions receiving federal aid must provide
resources for programs and services that
individuals with disabilities can use to independently acquire the same
information, engage in the same interactions, enjoy the same services within the same
timeframe, and with substantially equivalent ease of use as individuals without
Accessibility of programs and services to people with
disabilities is considered a civil
right in the United States. The Rehabilitation
Act of 1973 was the first major legislation in the United States to require
that the government and public support education that is accessible to people
with disabilities. The Act mandates that Titles I and II of the Americans with
Disabilities Act and the ADA Amendments Act reinforce that requirement for
public entities including universities.
These laws do NOT
require software developers, product manufacturers or vendors to make their products
accessible or prevent them from attempting to sell inaccessible products to
public entities. Therefore, the burden
of compliance with the law is on the University to examine the products
prior to purchasing and use and determine that they are indeed accessible, or
that there is a plan in place to provide accommodation that will result in equally
The University shall use the criteria of accessibility as
part of its decision making process in purchasing web resources, software,
electronic office equipment and computers. Purchasing priority is given to
technologies that are accessible to all.
II. Summary of Process for
Purchase and Use
If you have questions and concerns at any time during this
process, you can send an email to email@example.com .
if the product is accessible to individuals with disabilities, using the tools
in this procedure. If a product will be used by only one person and if that
person does not have a disability, you may submit the Accessibility Approval/Exceptions Request Form,
identifying that the product will be used by only one person without a
disability, and skip the rest of the steps.
- If it is
not fully accessible, look for an accessible product that will meet your needs.
and submit an Accessibility
Approval/Exceptions Request form, to the Accessible Technology Compliance
Committee (“ATCC”) for permission to purchase or to obtain further instructions.
- Once you have received permission from
the ATCC, you may proceed with the purchase if you have also complied with the University’s
applicable Contracting and Purchasing policies (http://nau.edu/Contracting-Purchasing-Services/).
III. Determining if a Product is
As you are researching products, you can request
accessibility information from a vendor in the following ways:
- Ask the vendor to provide you with a Voluntary
Product Accessibility Template (“VPAT”) for the product/version.
- Ask the vendor to provide an accessibility
statement, which should clearly indicate if the product is fully accessible, or
complies with, Section 508 of the Rehabilitation Act, as amended, or, if web
based content, conforms with WCAG 2.0 AA.
- Ask the vendor if they have third-party
independent verification of the accessibility of their product. If one is available, ask for a copy.
If you have obtained a VPAT (Voluntary Product Accessibility
Template) and it has sections that are labeled as “Supports with Exceptions” or
“Not Supported,” then the product is not fully accessible and you should
investigate other products which are fully accessible to meet your business
If you are unable to acquire any information on the
accessibility of the product, then you should look for another product which is
fully accessible that meets your business needs. In the event that an accessible product is
not available or the product which meets your business needs does not have a
VPAT or a statement of accessibility, then an Accessibility Approval/Exceptions
Request form should be fully completed, and submitted to the ATCC (read more about the exceptions request process).
If the product is fully accessible, provide the information
(e.g. a URL to the accessibility statement or VPAT, or a copy of an email from
the vendor stating that it is fully
compliant) to firstname.lastname@example.org and request purchase approval.
If the product is not fully accessible, but an exception
request has been approved, you should include an email from
email@example.com with your requisition stating the approved exception.
This link provides additional guidance on working with different types of purchasing scenarios (pre-packaged products and working with or without sales
This link provides additional guidance on determining accessibility, including
terminology and best practices for reviewing products.
Once you have determined the best product for your business
needs, complete and submit an Accessibility Approval/Exceptions Request form to firstname.lastname@example.org. If
your product appears to be accessible, please be sure to attach all relevant
documentation. If your product does not
appear to be accessible, you will be required to prepare an Equally Effective
Alternative Access Plan for review and approval as part of preparing the Accessibility
Approval/Exceptions Request Form. All other information you need will be
provided on the form and associated guidance document.
Once the form is received it will be reviewed for
completeness and determined if it needs to be reviewed by the ATCC. If it needs to go to the ATCC, it will be
sent to them and a final decision will be made in six business days following
receipt. The requestor will be sent an email with the final decision. If the exception is granted, it is approved
for two years.
You will not be allowed to complete the purchase until the Accessible
Technology Compliance Committee has approved it.