Accessible
Communication and Information Policy
Classification: Corporate
Responsible: All Robertson Employees and Contractors
Executive Sponsor: CEO
Approval Authority: Robertson Leadership Team
Date First Approved: June 14, 2024
Date Last Reviewed: N/A
Scheduled Review Date: June 1, 2026
A. PURPOSE
Robertson is committed to identifying, preventing, and removing barriers that allow for the promotion of greater independence and inclusion for people with disabilities. This policy describes Robertson’s commitment and approach to communicating and providing accessible information to students, staff, instructors, and the Robertson Community.
B. SCOPE
This policy applies to all employees, instructional contractors, and students at Robertson College.
C. DEFINITIONS
WCAG Web Content Accessibility Guidelines
Alternate or Accessible Format Usage of adaptive or assistive technology that requires a certain format to access information in a specific manner for the user.
Communication Supports
Comparable Resource
Examples of Alternate or Accessible Format
Ways for people who can not access verbal or audio information to receive it visually or ways for people who are non-verbal to communicate with people who speak.
A resource that is comparable to the original educational material but is in a more accessible format for the user.
Large print, electronic, or digital documents formatted for use with a screen reader, braille, writing in plain language, text transcripts or visual and audio information, ASL (American Sign Language), close captioned interpreted documents and videos.
Examples of Communication Supports
Sign Language Interpretation (ASIL), video relay service (VRS), Deaf-Blind Accessibility Interpreters, captioning or audio description, note taking, reading written information aloud to the person.
Robertson Community Robertson students, instructors, employees, stakeholders and community members.
Learning Management System A software application used to deliver online courses.
Undue Hardship
Under the Manitoba and Alberta Human Rights legislation, postsecondary institutions have a duty to accommodate students with disabilities and/or protected characteristics to the point of undue hardship. Undue hardship refers to a situation where accommodating an individual's needs would impose significant
difficulty or expense on an organization or entity. This concept is often used in the context of employment law, particularly in relation to providing accommodations for employees with disabilities or religious beliefs. The assessment of undue hardship takes into account factors such as the nature and cost of the accommodation, the overall financial resources of the organization, the impact on the operation of the business, and any potential disruption to the workplace. Essentially, if providing the accommodation would require more than minimal cost or effort, or if it would fundamentally alter the nature of the business, it may be considered an undue hardship.
D. GUIDING PRINCIPLES
Robertson understands that providing accessible information and communication to ensure everyone has equal access to information involves considering the audience, including people with no vision/low vision, learning disabilities, dexterity disabilities, deaf or hard of hearing, and cognitive or intellectual disabilities. Accessible communication and information encompasses the following areas:
● Web content
● Duty to notify
● Responding to requests for accessible information and communication support
● Feedback processes
● Training for all staff
● Compliance
1. Web content
1.1 Robertson’s website information follows globally accepted WCAG (Web Content Accessibility Guidelines).
1.2 The website and web applications is based on four accessibility principles:
i. Perceivable (visible to senses)
ii. Operable (interaction that a user can perform)
iii. Understandable (informative and how to operate)
iv. Robust (used widely as technology evolves)
2. Duty to notify
2.1 Robertson has the duty to notify and inform the public and employees that they can request information through communication support or accessible formats.
2.1.1 Students, prospective applicants, applicants and guardians are informed that educational materials is available through a communication support or accessible format and can request alternative formats upon request.
2.2 Robertson includes a public statement on its website and within its Learning Management System that communicates the process to be followed for an individual to access communication supports and alternative formats.
3. Responding to a request
3.1 When responding to a request for alternative communication or information formats, Robertson is committed to consulting with the person requesting to identify a support or format that will remove the barrier and be sure to provide the required information or communication promptly.
3.1.1 When a comparable resource is provided to the person who requested the support or format, Robertson will ensure it includes the same information as the original material.
3.1.2 The College will not be required to provide the information through a communication support or accessible format if one or more of the following applies:
● It is not technically feasible to provide the information through a communication support or accessible format.
● Providing the information through a communication support or accessible format would result in undue hardship to the College.
● The technology required to provide the information through a communication support or accessible format is not readily available to the College.
3.2 Robertson College will not charge individuals who request information or communication in alternative formats.
4. Feedback
4.1 Robertson College has a process to receive and respond to feedback (including complaints) about accessible communication and information that is suitable for people with disabilities and the circumstances related to that disability.
4.2 The feedback mechanism for educational materials is found on our website and in our online Learning Management System.
4.3 Documentation of the resulting actions regarding feedback is the responsibility of the Vice President, Academic. A record of these actions is stored within Robertson’s operational drive.
5. Training
5.1 Robertson is committed to offering training on The Accessible Information and Communications Standard Regulation to internal team members and instructors who:
● develop and maintain web content.
● communicate directly with the public or other organizations on behalf of Robertson College.
● purchase or procure information technology or communication tools.
● develop or implement measures, policies, and practices on accessible communication
● are responsible for educational delivery and oversight at the institution.
5.2 Training encompasses how to identify, prevent, and remove barriers to accessible communication; how to provide information through a communication support or accessible format; a review of the Human Rights Code, the Accessibility for Manitobans Act and standards.
5.3 Training will occur as part of the initial instructor or employee onboarding process for new team members and periodically throughout the year for existing team members.
5.4 On-going training will be provided whenever there are updates or changes to policy, measures, or practices.
6. Compliance
Robertson understands that Manitoba’s Accessibility Compliance Secretariat will conduct audits to determine compliance with web content, web applications, and training. Robertson is committed to supporting all compliance activities.
E. RELATED LEGISLATION
Manitoba Human Rights Code
The Accessible Information and Communication Standard Regulation (Manitoba)
F. SUPPORTING DOCUMENTATION N/A
G. RELATED POLICIES
Accessible Employment Standards Policy
Accommodation and Accessibility Policy
Accessibility Standard for Customer Service
H. RELATED MATERIALS
Accessible Information and Communication Standard Handbook (January 2024)
Frequently Asked Questions: The Accessibility Standard for Information and Communication (ND)
Accessible Communication Internal Training Plan
I: POLICY AUTHORITY
The Manager of Culture and Human Resources is responsible for this policy.
Questions regarding the interpretation of this policy should be directed to robertsonpolicies@robertsoncollege.ca
J. POLICY HISTORY
Change Made
Version Number
Policy initially approved 1.0
Signing Authority Date of Signature
Terena Caryk VP, Operations and Academics
Paul Samra VP, Global Julian Hallett, June 14, 2024
Reference: Applicable language for this policy was adapted from the Accessible Information and Communication Standards, Province of Manitoba, August 25, 2023, retrieved: https://web2.gov.mb.ca/laws/regs/current/047-2022.php?lang=en