Procurement of electronic and information technology (E&IT) is a priority of the CSU Accessible Technology Initiative.
To comply with federal and state law and CSU policy, Cal Poly must apply the established Section 508 accessibility standards to E&IT products and services that it buys, creates, uses and maintains. It is the University's responsibility to obtain the most accessible product or service available that meets the business and functional requirements. Obtaining an accessible product at the outset is generally less expensive and performs equally or better than an inaccessible one.
The following categories of products and services are covered by Section 508:
- Software applications and operating systems, e.g., licenses, subscriptions
- Web-based information and applications, e.g., websites, online surveys, "cloud based" services, subscriptions, and other content, social media sites, etc.
- Telecommunication products, e.g., telephones, cell phones, PDAs, etc.
- Video and multimedia products and services, e.g., TV displays and tuners, projectors, media players and recorder, and mediated content such as DVDs, etc.
- Self-contained, closed products, e.g., printers, scanners, copiers, kiosks, digital cameras, scientific instruments, etc.
- Desktop and portable computers, e.g., monitors, input devices, storage devices, etc.
In general, if a product fits into one of these categories, requires user interaction, and involves creating, converting, transferring or duplicating data or information, then it is probably covered.
In addition to being reviewed for accessibility, campus policy requires that E&IT products and services be reviewed for compliance with existing security and technical standards. The current criteria for review are noted in the E&IT Decisions Standard. However, any E&IT product or service may be subject to review based on its potential impact on campus users.
What This Means to You
Requesters gather and submit as much information as possible to Information Technology Services (ITS) using an online form in accordance with the E&IT Decisions Review Process.
(Prior to making an E&IT decision, especially one involving a new product or service, it is important to consult with your management and IT support and ITS to assess the priority, resource implications, potential impact and alternatives, and available tools to meet the need.)
As part of the review process, the vendor must document if and how their product or service meets Section 508 requirements by completing the CSU's Voluntary Product Accessibility Template (VPAT) (Word). ( If the vendor provides you with a VPAT or related documentation, please submit it with the online form.)
Once the VPAT is received, the E&IT Campus Compliance Officer reviews the documentation, assesses the level of compliance, evaluates the potential impact/risk to the campus, and approves the product as compliant or grants an exception if it is not.
The most common reasons for granting exceptions are
- Fundamental Alteration – The product must be fundamentally altered to be compliant and doing so would invalidate its purpose or function. This exception may also apply to university programs and services that are designed around an existing E&IT product or service.
- Commercial Non-Availability – There is no accessible product on the market that meets the functional requirements, i.e., all competing products are equally non-compliant.
- Sole Source – There is no other product on the market that meets the functional specifications.
If a product isn't fully accessible, the requester must develop an Equally Effective Alternative Access Plan (EEAAP) (Word) describing how equivalent access will be provided for users who are likely to experience difficulties using the product due to any identified accessibility gap.
Websites and web-based applications, including social media sites, online surveys, and other web-based services, whether developed or hosted on or off-campus, must comply with Cal Poly’s Web Accessibility requirements.
- Cal Poly Procurement Website
- CSU Accessible Technology Procurement Process Resource Website
- U.S. Government Section 508 Website - related laws, technical standards; BuyAccessible online tool to help determine applicable Section 508 requirements; resources for building accessible content, e.g., electronic documents and Web pages