IT Accessibility Risk Statements and Evidence by Topic

The purpose of this page is to help identify accessibility risks to consider in risk management process. It provides Electronic and Information Technology (EIT) accessibility risk statements and evidence by topic. An EDUCAUSE version provides a numbered list version.

Resources

Risk Statement: Failure to allocate sufficient resources and authority to coordinate and implement the Electronic and Information Technology (EIT) Accessibility Policy.

Risk Source, Documentation, or Proof:

Risk Statement: Failure to assign a person or entity to coordinate institution-wide accessibility.

Risk Source, Documentation, or Proof:

Content

Risk Statement: Failure to provide accessible Websites.

Note: A series of lawsuits has made it evident that accessibility of Websites under Title III of the Americans with Disabilities Act (ADA) includes access for people with disabilities. Litigation, and threatened litigation, surrounding the issue is on the rise, exposing institutions to a potential claim that they are failing to comply with anti-discrimination laws. The argument, in a nutshell, is that institutions are violating Title III of the ADA prohibition on discrimination on the basis of disability because their site or app lacks certain functionalities (such as including a text equivalent for every non-text element on a website and ensuring that all functions can be accomplished by using a keyboard instead of a mouse) that would make them accessible to people with disabilities.

Risk Source, Documentation, or Proof:

Risk Statement: Failure to provide native EIT accessibility (e.g., relying on second class EIT alternatives for people with disabilities.)

Risk Source, Documentation, or Proof:

Risk Statement: Failure to provide accurate video captioning.

Risk Source, Documentation, or Proof:

Risk Statement: Failure to provide audio descriptions.

Risk Source, Documentation, or Proof:

Risk Statement: Failure to provide captioning of announcements and commentary made over public address systems during athletic events.

Risk Source, Documentation, or Proof:

Failure to provide accessible instructional materials and library resources in a timely manner.

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Hardware

Risk Statement: Failure to provide accessible digital signage (e.g., providing information only in a visual, touch screen format for notices such as campus-wide activities, closures, and emergency alerts)

Risk Source, Documentation, or Proof:

Procurement

Risk Statement: Failure to ensure EIT obtained, provided or developed by third parties is accessible.

Risk Source, Documentation, or Proof:

Risk Statement: Failure to implement a procedure, which ensures procured EIT is accessible, such as including accessibility requirements in RFPs and contractual language.

Risk Source, Documentation, or Proof:

Awareness and Training

Risk Statement: Failure to provide a top level website dedicated to accessibility, which serves as a central repository and includes, but is not limited to providing accessibility information, news, tools, and best practices.

Risk Source, Documentation, or Proof:

Risk Statement: Failure to make faculty, staff and students aware of institutional resources for accommodation and accessibility.

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Risk Statement: Failure to provide regular ongoing, training, instruction and support at all levels (e.g. administrators, faculty, IT staff, support staff, student employees) regarding the institution's EIT Accessibility Policy and procedures, tools and techniques to ensure the Accessibility policy and procedures are effectively and consistently implemented.

Risk Source, Documentation, or Proof:

Monitoring and Testing

Risk Statement: Failure to systematically and effectively monitor EIT content and services to ensure accessibility.

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Risk Statement: Failure to thoroughly test EIT for accessibility (e.g., automated testing alone catches but a small percentage of errors.)

Risk Source, Documentation, or Proof:

Standard and Policy

Risk Statement: Failure to define a technical standard for implementing EIT accessibility (such as WCAG 2 or Section 508).

Risk Source, Documentation, or Proof:

Related References