Nova Southeastern University Art Museum Accessibility Policy for 
Public-Facing Digital Communications

Policy
Nova Southeastern University (“NSU”) Art Museum is committed to ensuring that everyone – regardless of their level of ability – have equal access to our student and public-facing digital communications. We have policies and procedures in place to help ensure that we comply with the Americans with Disabilities Act of 1990, Pub. L. No. 101-336, 104 Stat. 328 (1990), as amended, and other related state and federal laws, as applicable. This Policy establishes minimum accessibility requirements for public-facing digital communications deployed on the web, mobile applications or other digital communication platforms.

Definitions
For purposes of this policy the following terms shall have the indicated meanings:

• “Accessibility” means “the degree to which an environment, service, or product allows access by as many people as possible, in particular, people with disabilities.”
• “Accessibility Standards” means conventions, norms or requirements intended to provide access to an environment, product, or service, particularly by people with disabilities. The principle of accessibility may be mandated in law, and then specified in detail per regulations, standards, or codes.
• “Alternative Formats” means information presented in Braille, in large print, via audio recording, or in an electronic format that can be accessed by people with disabilities. The Alternative Format must make the same content available and provide an equivalent level of access to the content by people with disabilities that is available to others who access the original document.
• “Public-Facing Digital Communications” includes, but is not limited to, electronic or digital content, communications or applications that are:
• In HTML, non-HTML or mobile platform digital formats;
  Public facing and broadly disseminated, including academic information and student life information both online and on-campus;
• Student support mechanisms (e.g. chat, email, etc.);
• Digital and social media content;
• For the purposes of this Policy – “public-facing digital communications” shall not include: Archival copies stored or retained solely for archival purposes to preserve an exact image of a hard copy; or draft versions of documents that are not public facing, or which are intended for limited distribution.
• “Readily Achievable” is defined as easily accomplishable and able to be carried out without much difficulty or expense. Failure to remove accessibility barriers where “readily achievable” constitutes discrimination. Determining what is “readily achievable” often involves analyzing the nature and cost of removing barriers and the overall financial resources of the business organization, among other factors. The analysis seeks to balance the benefit of the barrier’s removal and the harm (e.g. cost) to the business.
• “Web Content Accessibility Guidelines 2.0”, or “WCAG 2.0”, refers to the globally recognized, de facto standard for web accessibility developed by the World Wide Web Consortium (W3C) Web Accessibility Initiative (WAI).
  “Level A” refers to the minimum level of conformance that a website must satisfy in terms of the WCAG guidelines, or a Level A conforming alternate version is provided.
• “Level AA” refers to the intermediate level of conformance that a website must satisfy having met all of the Level A and
• Level AA success criteria in terms of the WCAG guidelines, or a Level AA conforming alternate version is provided.

Scope
This Policy applies to all NSU Art Museum public-facing digital communications. This includes any accompanying support documentation and services associated with the public-facing digital communications. Employees, third party vendors, or individuals working either directly or indirectly on behalf of NSU Art Museum shall comply with this Policy.

Priority
The highest priority will be given to public-facing digital communications that are required to access to NSU Art Museum. All Alternative Format requests shall be completed in a commercially reasonable time-frame. Equal access to the requested information may be provided in lieu of making the original material accessible.

Technical Standards
Nova Southeastern University has identified WCAG 2.0 Levels A and AA as their target accessibility standard for public-facing digital communications accessed via computers, laptops, tablets and smart phones. Unless qualifying for an Exception as defined below, as of the Effective Date of this Policy, all new and revised public-facing digital communications published, purchased or controlled by Nova Southeastern University must conform to the WCAG Level 2.0 Levels A and AA accessibility standard.

Primary Contact
David Guidi is the primary contact point for public-facing digital communications accessibility for NSU Art Museum. All NSU Art Museum personnel responsible for public-facing digital communications should first contact this department to answer any questions about accessibility, address the accessibility of covered communications, and handle alternative format requests. Questions should be sent to [email protected].

External Communication
To view NSU Art Museum’s Digital Accessibility Statement, please visit the following url: https://nsuartmuseum.org/accessibility-statement/

Compliance
All Nova Southeastern University departments responsible for public-facing digital communications shall collaborate with the Nova Southeastern University Digital Accessibility point-of-contact to understand accessibility requirements, receive accessibility training, address accessibility of covered public-facing digital communications, and document how the public-facing digital communications conform to the WCAG 2.0 Level A and Level AA accessibility standards. Departments are responsible for implementing procedures to inform faculty, authors, developers, publishers, and procurers about applicable laws, policies and contractual obligations. Nova Southeastern University reserves the right to remove or suspend distribution of public-facing digital communications found to be in noncompliance with this Policy.

Evaluation & Monitoring
All Nova Southeastern University departments responsible for public-facing digital communications shall provide standards conformance reports for public-facing digital communications they are responsible for, on an annual or ad hoc basis, including both components developed by Nova Southeastern University as well as components developed by third-party vendors and deployed on or integrated into NSU Art Museum managed platforms or applications. Such reporting, evaluation and monitoring may be done using the system adopted by the Nova Southeastern University Digital Accessibility point-of-contact. NSU Art Museum will conduct automated accessibility tests of its core website, www.nsuartmuseum.org, at regular intervals approved by the accessibility point-of-contact to identify any instances where the core website is not in conformance with the WCAG 2.0 accessibility standard.

NSU Art Museum shall obligate its third-party vendors to conduct periodic audits of public-facing digital communications acquired by Nova Southeastern University under contract, and provide such reports to Nova Southeastern University upon request. This includes VPATs® or other accessibility conformance reports for typically used third party platforms and applications like learning management systems, bookstore, etc.
Training

This Policy will be communicated to all NSU Art Museum personnel s responsible for public-facing digital communications, including, but not limited to: student services representatives, project managers, faculty, designers, developers, content authors, QA analysts, and compliance/risk managers. The Policy will also be communicated to and be binding upon external vendors and contractors who develop public-facing digital communications for NSU Art Museum. Training will be offered on an as-needed basis to help these staff to implement the Policy.

Exceptions
Where compliance with this Policy is not possible, exceptions to this Policy may be granted by NSU Art Museum. Requests for exceptions must be documented and submitted to the Nova Southeastern University Digital Accessibility point-of-contact. Exceptions may be granted in the following scenarios:

• “Not Readily Achievable” – Compliance with this Policy may be waived if the nature and cost of removing digital accessibility barriers exceeds the financial resources of the university. This does not include not budgeting for addressing digital accessibility barriers, and should only be used in extreme circumstances where addressing digital accessibility barriers would financially harm the university.
• “Fundamental alteration” – Compliance with this Policy may be waived if addressing digital accessibility barriers would result in a fundamental alteration in the nature of the Nova Southeastern University service, program, or activity or result in undue financial and administrative burdens.
• “User generated content” – Content that is created by users of Nova Southeastern University systems, which is not readily accessible to the public may be exempted from compliance with this Policy. This exception only applies to the content itself, not the controls provided in association with the content, such as “Like” or “Follow” buttons, next page links, logins which may be required to view content, etc.
• “Linked sites and resources” – Sites, resources, or systems that are linked to or from any Nova Southeastern University published or controlled website or application, but which are provided by a third party outside of Nova Southeastern University’s operations may be exempted from compliance with this Policy, unless there is a contract in place with a vendor who is being paid to provide access to the third-party component, website, resource or system.
• “External Digital Content” – Digital Content about or relating to Nova Southeastern University that is hosted by third parties may be exempted from compliance with this Policy, unless there is a contract in place with a vendor who is being paid to provide such Digital Content.
• “Short Term Digital Content” – Digital Content that is hosted for less than three weeks may be exempted from compliance with this Policy.
• “Orphaned Digital Content” – Digital Content that is orphaned or available but not linked directly from any web site published or controlled by Nova Southeastern University may be exempted from compliance with this Policy.
• “Back Office” – Nova Southeastern University digital assets used for administration or monitoring of public-facing digital communications, but which are not available for use by the public or customers are exempted from Compliance with this Policy.

Effective Date
The effective date (“Effective Date”) of this policy is March 16, 2018.