Captioning Guidelines
Increasingly, universities across the country are facing legal challenges based on user complaints about inaccessible websites, instructional materials, products, and services.
CSU campuses are required by policy and law to ensure that their websites, instructional materials and electronic and information technology products and services are accessible to individuals with disabilities. Many of these resources, e.g., multimedia and video, require captioning to be considered accessible. This document is intended to provide general guidance for addressing your campus’s captioning efforts and point you towards resources that may be helpful.
Policy/Legal
CSU Executive Order 926(opens in new window) states that “It is the policy of the CSU to make information technology resources and services accessible to all CSU students, faculty, staff and the general public regardless of disability.” Information technology and resources includes voice and video programs and services. This applies whether the materials are created by individuals, acquired online at no cost, or purchased.
CSU Coded Memorandum AA2013-03(opens in new window) provides a framework for campuses to evaluate, prioritize, plan and incrementally implement this requirement through the CSU Accessible Technology Initiative (ATI). This framework includes reporting annually on progress towards achieving ATI goals and success indicators, including several that focus on multimedia.
The ATI goals and success indicators are based on applicable federal and state laws and standards, including, but not limited to, Sections 504 and 508 of the Rehabilitation Act of 1973; the Americans with Disabilities Act (ADA); California Government Code §11135; the U.S. Access Board’s Section 508 Standards; and the World Wide Web Consortium’s Web Content Accessibility Guidelines (WCAG).
Campuses not in compliance with applicable federal and state laws have found themselves in challenging situations and open to legal liabilities. Office for Civil Rights lawsuits and settlements(opens in new window) have resulted in universities across the country having to undertake major initiatives to such as ATI.
These guidelines are intended to help faculty, staff and students of CSU Chico achieve multimedia accessibility compliance and mitigate our risk to potential legal action.
Prioritization
Per CSU policy, Executive Order 926(opens in new window), the CSU is to make its programs, services, and activities accessible to students, faculty, staff, and the public, with disabilities. This includes, but is not limited to, multimedia programs and services as well as multimedia materials. Multimedia includes a combination of text, audio, still images, animation, or video regardless of delivery system.
Since the volume of captioning needed is immense, which make full compliance challenging (e.g., within semester or quarter time constraints), it is important for campuses to decide how to provide and support captioning. Prioritizing this effort is critical; decisions need to be based on the impact towards students, faculty, staff, and the public.
Prioritization Guidance
High Priority
- An accommodation is requested from a student, staff member, or other person who requires captioning.
- The multimedia will be shared multiple times and/or over an extended period of time.
- The multimedia is reused in new courses and newly revised segments of existing courses.
- Multimedia is used in a course for more than one semester.
- If captioning is required for one semester, the quality must be clear enough to allow equivalent access (defined as the ability to infer the meaning of whole sentences). Note that at this time, dictation software (e.g., YouTube automatic captioning) is not acceptable due to the tendency for errors, unless manually fixed by the content owner.
- Multimedia is on a public facing web page (e.g. commencements or other public-facing streamed or recorded events, news and marketing videos).
Other prioritization considerations
- Any multimedia that is purchased should be delivered in a captioned state. If not, the campus must ensure that captioning will be done upon receipt.
- Archived materials are to be captioned upon request. Caption frequently requested materials.
- If the campus cannot provide the resources or cannot support specific technical concerns, then captioning should be outsourced. This requires funding, so each campus budget must accommodate it.
- Commencements or other public-facing events that are streamed or recorded, news and marketing videos may require outside services.
- Captioning is a low priority if Lecture capture is used to post a lecture that is a review of a face-to-face class, and will only be available for one semester, and you have verified that you do not have an accommodation request.
Internal Services
IT Support
Web Services provides web technology strategies and solutions that facilitate openness and sharing, encourage collaboration, and enhance communication.
- Content Managers, owners and editors are responsible for facilitating the captioning in real time in-house or as needed from approved CSU vendors.
- Instructional Design and Information Technology Support offices provide consultation and training to faculty regarding the inclusion of captioned media into their courses. These offices will also evaluate and determine captioning needs for each video and includes facilitating the captioning in real time as needed for the client.
Accessibility Resource Center
Accessibility Resource Center (ARC) provides resources and disability related accommodations to assist with educational goals and student success. ARC may also provide consultation and training to faculty on captioning media into their courses.
Academic Department
Academic departments consult with IT and/or ARC to determine needs for videos and ensure that all media that must be captioned is done prior to delivery.
Communication & Marketing
The Commencement Office or Coordinator will consult with IT and/or ARC to coordinate captioning for videos and streamed, live events. Events and videos may include graduations, sporting events, Convocations, etc. The Social Media Manager will coordinate captioning for social media sites as needed.
Additional Information
Common Problems and Accessibility Concerns:
Copyright: for campuses that want to caption content that they own copyright in is not an issue, but captioning content that you do not own can be problematic. In general, you need to obtain the permission of the copyright owner before you can caption material that you do not own. This applies to both uncaptioned media purchased for use on campus, and for online videos (e.g., YouTube videos) belonging to other owners that professors may reference in a class. Additional information about the CSU and copyright can be found in the Fundamentals of Copyright and Fair Use (PDF). Additional information may be obtained from the United States Copyright Office(opens in new window).
Inaccessible players: Support for captioning (and accessibility in general) should be a criterion in the selection process for video technology; campuses should avoid selecting (or even allowing) the use of technologies, players, or platforms that prevent or hinder production of accessible content.
*These guidelines are a collaborative effort of the following CSU Campuses: Channel Islands, Cal Poly, Northridge, Sacramento, Sonoma, and the Office of the Chancellor.
*CSU Chico has amended the original document, with permission from the Chancellor’s office, to fit the needs of our university.