POLICY STATEMENT

In its commitment to diversity and inclusion, 91��ɫ College seeks to ensure that individuals with disabilities are afforded equal access to Information and Communication Technology (ICT) used by the College.

NSC seeks Information and Communication Technology (ICT) that is universal in design and Accessible to all individuals. In the event this is Technically Infeasible or imposes an Undue Burden, the College ensures Equally Effective Alternate Access. All ICT acquired, adopted, developed, or updated after the effective date of this policy must meet applicable Accessibility standards.

DEFINITIONS

Accessible: Individuals with disabilities are able to independently acquire the same information, engage in the same interactions, and enjoy the same benefits and services within the same timeframe as their nondisabled peers, with substantially equivalent ease of use.

Archive Content: Content that is no longer in use but subject to records retention schedules.

Equally Effective Alternate Access: An alternative format, medium, or other aid that accurately and in a timely manner communicates the same content as the original format or medium, and which is appropriate to an individual’s disability.

Fundamental Alteration: A change that is so significant that it alters the essential nature of the goods, services (including academic courses), technology, facilities, privileges, or accommodations offered.

Information and Communication Technology (ICT): Includes, but is not limited to, computer hardware and software, operating systems, computer or web-based information and applications, cellular and mobile apps, enterprise applications, learning management systems, telecommunication products, information kiosks and transaction machines, instructional materials, websites (including web pages, web applications, and web content), multimedia, and office equipment.

ICT Accessibility Committee: A standing committee consisting of one representative each from the Disabilities Resource Center (DRC), the Office of Marketing and Events, and the Office of Information and Technology Services (ITS).

Legacy Content: Content created before January 1, 2016.

Significantly Updated: A modification to the majority of content or a change that substantially alters usability or design.

Technically Infeasible: A situation in which there is little likelihood of accessibility because there is no existing software and/or hardware solution to provide the same level of access to all persons.

Undue Burden: A proposed course of action would result in significant difficulty, hardship, or financial or administrative burden.

PROCEDURES

This policy applies to Information and Communication Technology (ICT) that is developed, procured, updated, or used by 91��ɫ College (NSC) after this policy is adopted. The policy also provides guidance for remediation of pre-existing content.

If an ICT cannot be made Accessible due to Technical Infeasibility or an Undue Burden, Equally Effective Alternate Access must be provided in a timely manner. Alternatives are not required to produce the identical result or level of achievement for individuals with and without disabilities, but must provide appropriate auxiliary aids and services necessary to afford individuals with disabilities an equal opportunity to obtain the same result, gain the same benefit, or reach the same level of achievement, in the most integrated setting appropriate to their needs.

NSC is not required to take action that results in a Fundamental Alteration in the nature of a service, program, or activity or in an Undue Burden, but must nevertheless ensure, to the maximum extent possible, that qualified students with disabilities receive the benefits and services provided by NSC.

I. Defining Accessibility

Unless listed in Section VI (Exceptions), all software applications and web-based information or applications shall be qualify as Accessible if they comply at a minimum with the World Wide Web Consortium’s WebContent Accessibility Guidelines Levels A and AA (WCAG 2.0 AA). Other ICT shall qualify as Accessible if it complies with Section 508 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act of 1990, as amended (ADA).

II. Addressing ICT Acessibility

The Office of the President oversees implementation of and compliance with the ICT Accessibility Policy. The ICT Accessibility Committee coordinates those efforts. The ICT Accessibility Committee is responsible for submitting recommended revisions to the policy as needed.

Unless listed in Section VI: Exceptions, the following requirements apply to ICT.

A. Instructional Materials: All instructional materials and tools (e.g., videos, images, documents, mobile applications, student response systems [“clickers”]) are required to be Accessible. All third-party content (e.g., publisher content, linked materials) used in a course must be Accessible. It is the responsibility of the School or faculty member providing the materials to ensure Accessibility of third-party content. To this end:

1. 1. Faculty are required to use College-approved learning management systems (LMS), instructional tools (such as plagiarism detection tools), and captioning tools for all instructional activities. Personal or faculty websites are not to be used for the dissemination of any instructional materials.
   2. ITS and the Center for Teaching and Learning Excellence (CTLE) will assist faculty in evaluating the Accessibility of other instructional systems, applications, software, video servers, student response systems, and/or equipment upon request. Should a student require Accessible ICT accommodations, any non-Accessible items must be replaced with Accessible alternatives. As faculty redesign and update courses, non-Accessible programs and tools should be replaced with Accessible options.
   3. Students with disabilities may require textbooks and instructional materials (including electronic content and services) in an alternate format to ensure equal access. Alternate formats of materials for students with disabilities must be provided at the same time that other students are able to access the material through regular means. Production of alternate formats can be time-intensive; while some files can be provided within a matter of days, others can take several months to procure and format for use. Given this, faculty should give preference to course materials with an alternate format already available.
   4. If the DRC approves captioning or audio description as an accommodation in a particular course, faculty will cooperate with the DRC to arrange for any essential existing course audio-visual materials to be captioned or audio described. If providing a captioned or audio-described version of a video at the same time that the audio-visual content is shown to the larger class or audience is problematic, alternate Accessible materials must be substituted. When designing and updating courses, faculty shall ensure videos used for participation in a course (including shown during class or used as part of an assignment) are captioned and/or described.
   5. In the event that software or services known not to be Accessible are essential to a course, the instructor must provide the following notice to students in the syllabus: “This course requires the use of [name and description of tool], which is currently not accessible to students using assistive technology. If you use assistive technology to access course materials, please contact me immediately.”
   6. When an Accessible ICT is not available, students with documented disabilities are able to receive Equally Effective Alternate Access to curricular materials converted to alternative format or made Accessible in a timely manner (as determined by the DRC Director). The student must request the accommodation and participate in DRC procedures to identify an equally effective communication format.

B. Audio-Visual Materials: Individuals who are Deaf or hard of hearing may require closed captioning of video media and individuals with visual impairments may require audio description of video content. Reasonable accommodations for students, faculty, and staff must be provided at the same time that the multimedia is shown to the larger class or audience. Units/departments must collaborate with the Office of Marketing and Events, the Office of Information and Technology Serivices (ITS), the Disabilities Resource Center, and/or other relevant offices on campus to ensure closed-captioning is available on materials related to their programs and/or services when access to such materials is unrestricted (e.g., video content available to the general public).

1. 1. Closed-captioning and/or audio-describing must ensure accuracy (words are spelled correctly), synchronicity (ensuring captions do not lag behind or race ahead of the dialogue), completeness (ensuring everything is captioned and that shorthand or truncations are not used unless absolutely necessary), and placement (ensuring that captions do not obscure visual material on screen and, where possible, help convey soundstage and positioning—e.g., putting the captions on the left and right side of the screen to distinguish between two speakers).

C. Classroom, Class Labs, Computer Labs, and Meeting Spaces: The College provides information, training, and support to ensure that ICT used in classrooms, class labs, and meeting spaces is Accessible. Assistive technology is made available in computer labs as appropriate, based upon consultation with the Disability Resource Center (DRC).

D. Websites and Web Content: All websites, web pages, web-based applications, and social media published, adopted, or Significantly Updated by the College on or after the policy effective date must be in compliance with the ICT Accessibility Policy. This includes externally hosted sites and content provided for official College business or instruction. Official College websites must contain a method to report barriers and/or to receive Equally Effective Alternate Access. Each NSC website must contain contact information for the webmaster for those with Accessibility needs.

E. Other Digital Content: Schools and units must ensure communications intended for large audiences (e.g., emails, digital signs, promotional materials, maps, materials in PDF format) related to their programs and/or services are Accessible. Official content that represents the College and is available to the general public must be Accessible.

��������. Requesting Accommodations

Students who require accommodations for Accessible ICT must contact NSC’s Disability Resource Center (DRC) at 702-992-2180 or drc@nsc.edu well in advance of the beginning of classes or the event for which they need accommodations but in no event later than the deadlines set forth in DRC policies. The DRC will explain required documentation for determining eligibility for reasonable accommodations.

Faculty, staff, and other non-students who require accommodations must submit a request to the Office of Information and Technology Services.

NSC will provide a rationale for denying a request for Accessible ICT.

IV. ICT Procurement Procedures

Online content and functionality created by a third party and used for critical transactions (e.g., websites used for student applications, campus housing, campus dining, registering for classes, paying bills, obtaining transcripts) or to complete required training must be Accessible. Regarding the procurement of ICT from third parties (e.g. vendors), NSC requires that:

• The third party commits to providing a product that meets WCAG 2.0 Level AA Standards or details how the third party will support the College in providing Equally Effective Alternate Access for non-conforming products; and
• NSC obtains, reviews, and evaluates the third party’s most recent Accessibility testing results.

Individuals procuring ICT should review Accessibility early in the process of evaluating third-party products. Contracts involving third-party web connections follow normal contract routing and review; this process ensures required language regarding accessibility is included in all agreements. Submit questions or draft contracts to contracts@nsc.edu for evaluation.

V. Implementation Period for Pre-Existing Content

This section defines the deadlines for remediating each category of pre-existing content. The ICT Accessibility Committee shall develop an Accessibility Plan that includes remediation priorities within each category. Priority for implementation will be given to programs, services, or activities that are either highly critical to or are broadly used by the campus, a School, or a unit.

The Accessibility Plan will include procedures, resources, and training necessary to support compliance, as well as implementation deadlines for prioritized content. Support and resources will be made available to faculty and staff, including how to make ICT accessible, how to use automated tools to ensure the accessibility of content, and how to get assistance.

The ICT Accessiblity Committee shall provide an annual report to the President documenting progress toward completing the remediation project.

A. Essential Content and Functionality: Within two (2) fiscal years of the adoption of the NSC ICT Accessibility Policy, all essential (i.e., used to conduct official College academic and business activities or to complete required training) online content and functionality created by NSC must be Accessible.

B. Pre-existing Content and Functionality: Within three (3) fiscal years of the adoption of the NSC ICT Accessibility Policy, all pre-existing (i.e., in use before the date of Policy approval) non-Legacy Content and functionality must be Accessible.

C. Legacy Content and Functionality: Upon request by a qualified person with a disability, any Legacy and Archive content must be Accessible. Equally Effective Alternate Access may be provided until compliance is accomplished.

VI. Exceptions

Exceptions include but are not limited to:

A. Archive Content on websites or web pages, unless specifically requested to be made Accessible by an individual with a disability. If such a request is made, NSHE or the institution must provide Accessible content or Equally Effective Alternate Access;

B. Web pages and websites designed solely to conduct research or created for developmental or test-site purposes, unless specifically requested to be made Accessible by an individual with a disability who has authorization to access those web pages or websites. If such a request is made, NSHE or the College must provide Accessible content or Equally Effective Alternate Access;

C. ICT utilized and intended solely for internal institutional operations, except to the extent that an individual with a documented disability requires Accessible content;

D. Electronic documents posted to College or NSHE websites and subdomains or within their web applications that meet all of the following requirements:

1. 1. 1. The documents are of interest to a specific and limited audience (e.g., researchers in a particular academic discipline);
      2. The set of documents requiring remediation to be Accessible is voluminous (i.e., the total page count of the electronic documents that reside on a single webpage exceeds 100 pages) or making the documents Accessible is Technically Infeasible;
      3. The documents are presented in such a way that individuals with disabilities are able to identify documents or sections of documents of particular interest and request remediation of those documents.

E. Single-instance, specialized software purchased for individual use;

F. Student work that will not be Archive Content;

G. Instructor-made videos that record feedback to an individual student unless an accommodation is requested per Section III (Requesting Accommodations) of this policy;

H. Web pages, web applications, or web content when making them compliant with WCAG 2.0 Level AA would result in a Fundamental Alteration or Undue Burden.

The NSC President (or designee who has budgetary authority) may approve additional exceptions to this policy. Such exceptions must only be made after considering all resources available for use in the funding and operation of the service, program, or activity. If an exception is approved, the President (or designee) must provide a written statement of the reasons for the exception, including the estimated cost of meeting the requirement, available funding and other resources, and the plan for providing Equally Effective Alternate Access.

FORMS/INSTRUCTIONS

Accessibility Checklist for Faculty

CONTACTS

Disability Resource Center (DRC)
Phone: 702-992-2180
Email: drc@nevadastate.edu

Information & Technology Services
Phone: 702-992-2410

Center for Teaching & Learning Excellence (CTLE)
Email: ctle@nevadastate.edu

RELATED INFORMATION

• (ADA) of 1990, as Amended
• NSC Disability Resource Center policies on requesting accommodations
• NSHE Policy for Information and Communications Technology (ICT) Accessibility (NSHE Handbook 4.8.15; effective September 1, 2017)
• (WCAG) 2.0 AA Technical Standards

HISTORY

Development of policy mandated by NSHE September 1, 2017.

APPROVALS

Approved by Faculty Senate Chair Dr. Abby Peters, April 4, 2019.
Approved by Provost Dr. Vickie Shields, April 16, 2019.
Approved by President Bart Patterson, May 9, 2019.

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POLICY STATEMENT

This Information Security Plan describes 91��ɫ College’s safeguards to protect Sensitive Information in compliance with institutional, state, and federal guidelines. These safeguards are provided to:

• Protect the security and confidentiality of Sensitive Information;
• Protect against anticipated threats or hazards to the security or integrity of Sensitive Information;
• Protect against unauthorized access to or use of Sensitive Information that could result in substantial harm or inconvenience to any student, employee, or customer.

The purpose of this plan is to:

• Identify the risks that may threaten Sensitive Information maintained by 91��ɫ College;
• Designate individual(s) responsible for coordinating the plan;
• Establish and maintain a safeguards program;
• Establish and maintain an incident response plan;
• Adjust the plan to reflect changes in technology, sensitive information, or threats related to information security.

DEFINITIONS

Data Owner: An individual, entity, or office that is authorized to collect, view, or manage the data.

Sensitive Information: Any information or data associated with an individual that is considered personal or confidential, including but not limited to Social Security Numbers, individually-identifiable health information, education records, non-public information, and data that is protected by Board policy, state, or federal law.

Third Party: Any individual or entity contracted by 91��ɫ College.

PROCEDURES

I. Identification of Risk to Sensitive Information

91��ɫ College recognizes that it faces both internal and external risks regarding Sensitive Information. These risks include, but are not limited to:

• Unauthorized access of Sensitive Information by someone other than the Data Owner;
• Compromised system security which can result in unauthorized access to Sensitive Information;
• Interception of Sensitive Information during transmission;
• Loss of data integrity;
• Physical loss of Sensitive Information in a disaster;
• Corruption of data or systems;
• Unauthorized access of Sensitive Information by employees;
• Unauthorized access of Sensitive Information through hardcopy files or reports;
• Unauthorized transfer of Sensitive Information through a Third Party.

������. Information Security Plan Coordinator

The appointed Information Security Officer, in cooperation with the Chief Information Security Officer at the Nevada System of Higher Education, is responsible for the implementation and maintenance of this policy.

III. Safeguards Program

A. Employee Management and Training: Upon selection for hire, background checks are conducted when deemed appropriate. During onboarding, each new employee who may handle or encounter Sensitive Information shall receive information security training highlighting the importance of confidentiality and protecting Sensitive Information.

B. Physical Security: 91��ɫ College has addressed physical security of Sensitive Information by limiting access to only those employees who have a business reason to know such information and requiring acknowledgement of the requirement to keep Sensitive Information private.

C. Information Systems: Information systems housing Sensitive Information shall be secured behind network firewalls, physically accessible only to key personnel, electronically accessible only via controlled access, kept up-to-date with security patches, backed up on a routine basis, and shall transmit Sensitive Information in a secured manner such as via encrypted channels. Additionally, 91��ɫ College will maintain systems to prevent, detect, and respond to attacks or intrusions. This includes maintaining anti-virus protection, a network intrusion detection/alert system, and tools to secure systems in the event of a breach.

D. Selection of Service Providers: In the process of selecting a service provider that will maintain or regularly access Sensitive Information, the evaluation process shall include the ability of the service provider to safeguard such data. Contracts with service providers should also include the following provisions:

1. 1. A stipulation that the Sensitive Information will be held in strict confidence and accessed only for the explicit business purpose of the contract;
   2. An assurance from the contract partner that the partner will protect any Sensitive Information it receives.

IV. Incident Response Plan

91��ɫ College shall maintain an incident response plan. Per the incident reporting and response procedures, all suspected information security incidents must be reported as quickly as possible to the Office of Information & Technology Services. This includes, but is not limited to, security breaches, unintended exposure of Sensitive Information, suspected viruses or malware, or unauthorized requests for login information or Sensitive Information.

V. Evaluation and Adjustment

This information security plan will be subject to periodic review and adjustment due to constantly changing technology and evolving risks. The plan coordinator will recommend updates and revisions as necessary. It may be necessary to adjust the plan to reflect changes in technology, the definition of Sensitive Information, or internal/external threats to information security.

HISTORY

Revised 02/26/18

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Proper Conduct in Use of Computers

It is the policy of 91��ɫ that improper conduct regarding computers as set forth in this section is incompatible with the goals of honesty and academic freedom and is strictly prohibited. Improper conduct regarding computer use at the University falls into three categories:

1. academic dishonesty;
2. disruption and destruction of computer facilities; and
3. violation of licenses and copyright agreements, University policy, and state or federal laws.

Academic Dishonesty Pertaining to the Use of Computers

Examples of this type of behavior regarding computers include, but are not limited to:

1. 1. Submitting another person’s programs, documentation, or program results as your own work;
   2. Obtaining or attempting to obtain unauthorized access to information stored in electronic form;
   3. Submitting false results of a program’s output for a class assignment or falsifying the results of program execution for the purpose of improving a grade.

Disruption or Destruction of Computer Facilities

Examples of this type of behavior include, but are not limited to:

1. 1. Damaging or stealing college-owned equipment or software;
   2. Causing the display of false system messages;
   3. Maliciously causing system slowdowns or rendering systems inoperable;
   4. Changing, removing, or destroying (or attempting the same) any data stored electronically without proper authorization;
   5. Gaining or attempting to gain access to accounts without proper authorization;
   6. Putting viruses or worms into a system

Violation of Licenses and Copyright Agreements

Most software used on University computers is covered by copyright, license or nondisclosure agreements. Violation of these agreements puts the University and the individual in jeopardy of civil penalties. Examples of such violations include, but are not limited to:

1. 1. Making copies of copyrighted or licensed software without proper authorization;
   2. Using software in violation of copyright, license or non-disclosure agreements;
   3. Using college computers for unauthorized private or commercial purposes;
   4. Use of computers or the internet in a manner that is against local, state, or federal laws.

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POLICY STATEMENT

Official email communications are intended to meet student, faculty, and staff academic and administrative needs within the campus community. Unless otherwise prohibited by law, the College and its faculty may communicate with students officially by email and will expect that such email messages will be received and read in a timely manner. This policy stipulates that all formal communication will be sent to students using the official issued College email address.

DEFINITIONS

Academic Activity: Defined by registering for a course, submitting an application for admission, or getting student status set to active.

Alumni: Former students who have graduated from NSC.

Discontinued: A period in which a student’s academic record is deactivated following a period of one (1) year since the last instance of Academic Activity.

PROCEDURES

I. Email Account Creation

Upon admission to 91��ɫ College, students are provided with access to Microsoft Office 365, which includes an email account. Access to Office 365 is provided through the NSC Portal (). Student email addresses are in the format of (name)@students.nevadastate.edu.

II. College Communications with Students

��With the exception of course-related communications from faculty to enrolled students, all NSC communications to students will be sent to NSC-issued student email addresses only. This includes non-course-related communications from faculty, staff, departments (e.g., Admissions, Registrar, Cashier, Financial Aid), Canvas (WebCampus) notifications, related third parties, such as facilities and housing, and groups organizing NSC events.

NSC faculty, staff, and departments must only respond to communications sent from NSC student email addresses starting August 24, 2020.

Faculty will primarily use the messaging system with Canvas (WebCampus) to communicate with students enrolled in their courses about course-specific information.

III. Student Responsibilities

A. Students must ensure that there is sufficient space in their accounts to allow for delivery of official email communications. Email users should exercise extreme caution in using email to communicate confidential or sensitive matters and should not assume that email is private or secure. Users must be careful to send messages only to the intended recipients.

B. Students are expected to check their email on a frequent basis in order to stay current with NSC-related communications and to recognize that certain communications may be time-critical. Failure to check email, errors in forwarding mail, or email returned to the college with “Mailbox Full” or “User Unknown” or other similar reasons are not acceptable excuses for missing official College communications via email.

IV. Faculty and Staff Responsibilities

To comply with this policy and the Family Educational Rights and Privacy Act (FERPA), upon receiving an email from a student, all faculty and staff must verify that the email account from the sender is an official NSC student email address that uses the (name)@students.nevadastate.edu format. If a non-NSC email is used, employees will reply stating only that correspondence must come from an official NSC email address and reminding the student to use their NSC email to re-send their message. Failure to do so could lead to a violation of FERPA.

V. Forwarding

If students wish to have email redirected from their official NSC email to another email address, they may do so at their own risk. The College is not responsible for the handling of email by outside vendors or departmental/unit servers, none of which are considered official student email accounts. Having email redirected does not absolve a student of the responsibilities associated with official communications sent to the official NSC [name]@students.nevadastate.edu account.

VI. Post-Enrollment

NSC alumni may maintain access to their NSC email indefinitely. If at any point the College has a need to discontinue the College email account, appropriate notice will be given to allow the student/ alumni to transition.

a. We do not recommend using NSC email accounts as password recovery addresses on other sites or for any similar purpose. Should a student’s NSC email account be deleted according to this policy, they may not be able to recover/reset passwords on those other sites. Students should use a personal email account for password resets and recover and forward that account to their NSC email account if desired.

APPROVALS

Approved by Dr. Vickie Shields, Provost, August 21, 2020.
Approved by Bart Patterson, President, August 21, 2020.

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