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Descriptive and Scenario-Based Guidance

The following descriptive and scenario-based guidance is designed to aid in the interpretation of certain terms, phrases, and requirements within the Policy. 

Notwithstanding the scope limitations of the Policy, the University strongly urges all University community members to bring all Digital Content into conformance with the Accessibility Standards, wherever such materials reside, because conformance with the Accessibility Standards provides wide-ranging benefits to all users.

University Website

A University Website has four elements: 

  1. It is a website or web-based application;
  2. It is public-facing and/or student-facing;
  3. It resides within a University-controlled domain;
  4. It is used to conduct University Business by University faculty or staff.

To the extent that any digital material does not meet all four requirements, it is not a University Website subject to the requirements of the Policy. Personal websites operated by University faculty, staff and students are not subject to the Policy.

The Policy’s requirements apply not only to University Websites generally, but also to any specific area, content, or page of a website that would, in and of itself, meet the four elements of a University Website, even if the entire website does not. In such cases, only the areas, content, or pages that meet the elements of the definition are subject to the Policy.

Public-Facing, Faculty-Facing, Staff-Facing or Student-Facing

The Policy only applies to websites or web-based applications that are public-facing, faculty-facing, staff-facing or student-facing. “Public-facing” sites are: 

  1. not subject to any access restrictions, such as login requirements, and
  2. located at URLs ascertainable by the general public, either through links from other public-facing pages or because they are indexed for search. 

Faculty- and Staff-facing websites and applications are those that faculty or staff utilize in the course of performing University Business. 

Student-facing content posted on course websites made available only to enrolled or registered students are subject to the Policy.

University-Controlled Domain

The Policy does not apply to websites and web applications that are outside of a “University-controlled domain.” This is because the University cannot manage the coding infrastructure of a third-party’s online platform and therefore cannot ensure that a third-party website conforms to the Accessibility Standards. Likewise, the University is unable to eliminate all barriers to accessibility or aspects of a third-party website that preclude users from posting content that conforms to the Accessibility Standards. However, while this Policy does not bar faculty or staff from posting content to third-party platforms that do not conform to the Standards and are outside the University’s control, the University strongly urges all faculty, staff and students to (1) make accessible all Digital Content they create at the time it is produced; (2) ensure that all content they post on third-party platforms is accessible; and (3) post content only on accessible third-party platforms. 

A “University-controlled domain” includes domains registered to the University and domains that University departments, laboratories, centers, and offices or members of the University community have registered in connection with University Business. Any URL within northwestern.edu is “within a University-controlled domain.”  Domains registered by vendors on behalf of the University to host web content posted by the University, are also University-controlled domains. 

Examples of Sites within University-Controlled Domains: 

  • The director of a University research center decides to move the center’s website outside of the subdomain assigned to her University school. She registers a unique domain name for the center (“theNorthwesterncenter.org”); that domain name is University-controlled, and web content posted within that domain is subject to the Policy.
  • A University academic department contracts with a vendor for web hosting services. At the department’s request, the vendor registers a unique web domain for the department’s website.  Although neither the University itself nor any member of the University community is the named registrant for the domain, the domain is University-controlled.

Examples of Sites Outside University-Controlled Domains: 

  • Sites on domains registered by corporate affiliates of the University, such as the University-affiliated hospitals, are not within University-controlled domains.
  • Third-party platforms — such as YouTube, Facebook, and Twitter — are not University-controlled domains under the Policy. However, if content posted on a third-party platform on a webpage with a URL is embedded within a University-controlled domain, then that content is considered to be posted within a University-controlled domain and, therefore, subject to the Policy.

University Business

The Policy defines University Business as “[a]activities carried out under the auspices of Northwestern University and in furtherance of the University’s mission, exclusive of activities organized or conducted by students or student organizations.” University Business includes, but is not limited to: 

  • work done by or at the direction of University employees acting within the scope of their employment; and
  • work done by University vendors acting within the scope of their engagement by the University.

University Business does not include: 

  • personal matters or personal business of University employees; or
  • activities organized or conducted by students or student organizations.

Examples: 

  • A University professor who posts content online that describes a recently completed research project is engaged in “University Business.”
  • A University graduate student working as a research assistant in a laboratory posts content on a University Website that relates to her work; this is considered “University Business.” The same graduate student’s online efforts to organize a kayaking trip are not “University Business.”
  • The University engages a vendor to produce videos that document events on campus. The vendor uploads those videos to a University Website. Although the vendor is not a University employee, the videos are considered “University Business.”

New & Substantially Revised Website

An entirely new University Website launched on or after September 1, 2021, must conform to the Accessibility Standards with respect to both its code/infrastructure and its content. In addition, any existing University Website’s underlying code and infrastructure must conform to the Accessibility Standards if the site is “substantially revised” after September 1, 2021.  A website is considered “substantially revised” if it transitions to another hosting platform, it is recoded from scratch, or meaningful changes are made to its design elements or overall structure that affect the conformance to the Accessibility Standards. 

Content that was posted on a University Website before September 1, 2021, and later moved to a new or substantially revised University Website is not subject to the Policy, although the University strongly urges ICT Owners to make such content accessible. 

Examples: 

  • A University department contracts with an outside web developer to rebuild its website from scratch. The new code and content must conform to the Accessibility Standards.
  • The Libraries upgrade their website and apply a new visual design. The new code and content must conform with the Accessibility Standards, but content that was posted on the old website before September 1, 2021, is exempt.
  • A staff member switches from one theme to another for their website. This does not mean that the website was “substantially revised.”

Content Created and Produced at the University and Posted on University Websites

Created and Produced at Northwestern 

Content is considered “created or produced” at the University if University faculty or staff conceived, authored or co-authored, and/or digitally generated the content in connection with University Business.  

Examples: 

  • A University researcher performing field work in South America blogs about her experiences on the project. Her blog posts are created and produced at the University.
  • A University athletics team records digital video of an away game for upload online. The recording is content created and produced at the University. 
  • A production company obtains permission to enter upon University property to shoot a short film, which it uploads to the Internet as a digital file. This film is not created and produced at the University.
  • A University Website obtains a license from journal publishers to display University-authored journal articles online, in .pdf files issued by the journals. Although the content in the articles may have been created at the University, the .pdf files were not produced at the University and, therefore, are not subject to the Policy’s content accessibility requirements. 
  • A University scholar gives a talk at another university. The University records the presentation and uploads it to the Internet, and the scholar’s department embeds the video on its web page. The content of the presentation may have been created at the University, but the video was not produced at the University. 

Posted on a University Website

Content created and produced at the University, as described above, is subject to the Policy, only if it is also “posted on” a University Website. Content posted only via user accounts on third-party platforms such as YouTube, Facebook, Tumblr, or WordPress is not “posted on a University Website,” except in cases where that content also appears within a University-controlled domain. For example: 

  • If a department embeds a YouTube video or SoundCloud audio file on a department web page, that video or audio is “posted on” that web page.
  • If a School uses the WordPress platform for its School-level website and locates the resulting web pages within the northwestern.edu web domain, that content is “posted on” a University Website.
  • If a scholar uses Tumblr to host a website discussing his research and arranges for Tumblr to redirect associated Tumblr URLs to Tumblr hosted pages within a domain name registered by the scholar, the web content is “posted on” a University Website.

Captioning

 All videos posted to University Websites must include synchronized closed captions. Audio files, such as podcasts, that are posted to University Websites must be accompanied by transcripts. 

University-owned and managed channels on third-party platforms (e.g., YouTube, Facebook, Twitter, Vimeo, Kaltura, Brightcove, SoundCloud, etc.) do not meet the definition of a University Website. However, content owners who control these channels should still make content on these channels accessible, using any available platform features such as descriptions for images and high-quality captions for audio or video. In the case of videos produced for cross-posting on multiple platforms, a best practice is to integrate captions into a video asset promptly after its production, so that the captions are done once and easily propagated across the platforms used.  

Videos and audio must be captioned upon upload to a University Website at an accuracy rate equal to that offered by a third-party vendor captioning service such as 3PlayMedia or Rev, and in a manner consistent with industry standards regarding synchronicity, completeness, and placement. Captions auto-generated by platforms like YouTube, IBM Watson, and Microsoft are not sufficient to meet this standard and, therefore, are not recommended without additional procedures in place for verification and correction. High-quality captions include highly accurate transcription, proper punctuation, speaker identification, and the identification of sounds other than speech. 

Audio transcripts

Audio segments and podcasts posted on University Websites and covered by the Policy must be accompanied by a full transcript. These transcripts either must be available on the same page as the audio player or linked directly to the transcript in the description text.  Because audio transcripts do not need to be time stamped or synchronized, they may be easier to generate than video captions. To enhance clarity and ensure access, speakers should be identified within these transcripts. 

Live video captioning

University events that are live-streamed through third-party platforms are not subject to the Policy. However, events streamed on a third-party platform and embedded within a University Website are subject to the Policy. 

The University live-streams a wide range of content ranging from large-scale events, such as Commencement, to small activities within labs or departments. University-wide events (such as Commencement) for which video and/or audio are live-streamed over the Internet must be live-captioned to industry standards. 

  • For School-wide events or other larger events that are advertised and expected to generate substantial audiences, and for which video and/or audio are live-streamed over the Internet, the University strongly urges that industry-standard live captioning be provided as a matter of course. Some examples include but are not limited to:
    • Dance Marathon
    • Performing arts showcases
    • Public addresses by national figures
  • For smaller events for which video and/or audio are live-streamed over the Internet, the University recommends in all cases that the hosting department offer in advance the opportunity for individuals with disabilities to request an accommodation. In all cases where video of a live event is later posted to a University Website, such videos must be captioned as required by the Policy.