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Captioning Policy Guide Draft
 

Captioning Policy Guide Draft

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A draft guide for developing college policies and procedures for ADA compliance and more broadly on captioning media content and complying with HEAO.

A draft guide for developing college policies and procedures for ADA compliance and more broadly on captioning media content and complying with HEAO.

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    Captioning Policy Guide Draft Captioning Policy Guide Draft Document Transcript

    • Wisconsin Postsecondary Captioned Media Policy Guide<br />In 2010 a workgroup comprised of staff from the University of Wisconsin, private colleges and Wisconsin Technical College campuses convened to address the issue of media used at their institutions that limited or prohibited access for staff, students and the public. Although federal law mandates this accessibility, institutions are often unaware of their responsibility and the risk of civil litigation related to using uncaptioned media. It was agreed that the first priority for this workgroup would be to develop a guide to assist Wisconsin postsecondary institutions in establishing captioned media policies and procedures that ensure compliance.<br />Although the legal support for this policy addresses accessibility for persons with disabilities, research clearly shows captions benefit a much wider audience. Captioning facilitates note taking, enhances understanding and recall and provides access to auditory content when variations of sound quality or surrounding noise creates distractions.<br />For more information on this guide or other captioned media issues, please contact a member of the Wisconsin Postsecondary Captioned Media Workgroup.<br />Ginny Chiaverina, PEPNet<br />Sarah Fishbach, Northeast Wisconsin Technical College<br />Susan Gordon, University of Wisconsin-Milwaukee<br />Sandy Hall, Madison Area Technical College<br />Tom Heffron, Wisconsin Technical College System<br />Jana Hicks, Madison Area Technical College<br />Anna Johnson, University of Wisconsin-Milwaukee<br />Laura Keller, Carroll University<br />Barb Kiedrowski, Northcentral Technical College<br />Jodi Landowski, University of Wisconsin-Whitewater<br />Donna Langwasser, Waukesha County Technical College<br />Fran Lorenz, University of Wisconsin-Milwaukee<br />Erin Poeschel, Chippewa Valley Technical College<br />Bambi Riehl, PEPNet<br />Kelly Schumacher, Northeast Wisconsin Technical College<br />Todd Schwanke, University of Wisconsin-Madison<br />Kate Skarda, University of Wisconsin-Madison<br />Renee Thomas, Madison Area Technical College<br />Contents<br />
      • Policy Statement Template
      • Definitions
      • Considerations for Establishing Campus Procedures
      • Campus policy oversight
      • Obtaining copyright permissions
      • Captioning existing media
      • Purchasing new media
      • Equipment to view captions
      • Frequently Asked Questions
      • What is the turn-around time to get a piece of media captioned?
      • What is the cost of adding captions to media?
      • What should I consider when deciding to perform captioning services at my institution or send media out to a captioning vendor?
      • What should I look for when choosing a captioning vendor?
      • How do I get permission to add captions to materials that are copyrighted?
      • How do I know if a piece of traditional media is captioned and for web-based media players, how do I turn on the captioning?
      • Doesn’t the Fair Use Law allow educational institutions to make multimedia content accessible by adding captions?
      • Where should we start?
      • Are there other ways to make media presentations accessible?
      • How can I legally use a video recorded from broadcast television?
      • Appendices
      • Sample letter to obtain copyright permission
      • Sample campus specific procedures for obtaining and/or producing new captioned media
      Policy Statement Template<br />This institution is committed to the fundamental academic principles of equity and accessibility by providing all students and staff with equitable access to the College's programs, services, events, and staff development activities. The aim of this policy is to support an inclusive academic environment by incorporating design concepts that reduce or remove barriers. This institution will achieve this goal by endorsing a policy on the use of captioned media.<br />Course of action<br />All media resources purchased and/or used after (date) at this institution must be captioned.<br />All new instructional, informational, marketing, and promotional audiovisual materials produced by this institution, including content posted on websites, will be produced with captions to ensure all subsequent copies will be captioned.<br />Legal support<br />The Americans with Disabilities Act (ADA), signed into law in 1990, protects persons with disabilities from discrimination through barriers to communication. Communications with individuals with disabilities must be as effective as communications with others. The use of captioned media breaks down these barriers and equalizes communication access.<br />Section 504 of the Rehabilitation Act of 1973 also prohibits discrimination and mandates accessibility to individuals with disabilities. Individuals may not be excluded from participation or denied the benefits of educational programs.<br />Summary<br />
      • Purchase and produce captioned media.
      • Before using an existing legally obtained video currently in inventory or recorded from a broadcast, obtain copyright permission to caption. The video may not be used unless it has been captioned. It will not be captioned without copyright permission. Be aware the process of obtaining copyright permission to caption a video is lengthy.
      • When using audiovisual media, view with captions turned on.
      Definitions<br />For the purposes of this policy, the following terms are defined:<br />Media includes VHS video, DVD, digitally streamed video and audio files in web-based environments and any other format that includes an audiovisual component.<br />Captioned media displays the audio content of the program as text. Captions not only display spoken dialogue or narration but also include speaker identification and sound effects. It is important that captions are synchronized and equivalent in content to that of the audio.<br />Captioned media is produced in a variety of ways:<br />Closed captioned media provides the option of having the captions appear on the screen through a decoder, which is built into the television.<br />Open captioned media does not require a decoder, as the captioning is permanently part of the picture and cannot be turned off.<br />English subtitles are included on many DVDs and may be turned on using the remote control to access the subtitle list.<br />Subtitles for the deaf and hard of hearing (SDH) are subtitles that also contain non-verbal cues. SDH subtitles tend to be used on video formats that do not support closed captioning, such as Blu-Ray disks.<br />Closed captions are usually the preferred method for making videos accessible.<br />Further explanation and examples of captioning may be found at: http://www.dcmp.org/captioningkey/types_methods_styles.html <br />Considerations for Establishing Campus Procedures<br />Campuses will need to develop specific procedures to ensure all media resources purchased and/or used will be captioned. The following are some of the decision points that campuses should consider when implementing a policy requiring captioned media. See Appendix B for two examples of campus-specific procedures for obtaining and/or producing new captioned media.<br />Campus Policy Oversight:<br />
      • Who will oversee compliance of the captioning policy?
      • What if media used with a curriculum is not captioned? Will the instructor be required to change the course curriculum? What if the instructor refuses?
      • Who will oversee the quality of captions added to media to ensure the captions follow DCMP guidelines?
      • Who on campus will assist teaching staff in locating captioned materials?
      Obtaining Copyright Permissions for Adding Captioning: (See Appendix A for a sample letter to obtain copyright permission)<br />
      • What is the procedure for obtaining copyright permission from the copyright owner?
      • Who is responsible for securing and maintaining copyright permissions?
      • What if copyright permission is not obtained and a video cannot be legally captioned?
      Captioning Existing Media:<br />
      • Who will be responsible for adding captions to existing media: Instructors? Disability Services? Another unit? How will captioning be funded?
      • Will your campus perform captioning on-site or will you send media to an outside vendor?
      • Which captioning vendors are recommended? Are there existing college system contracts with a specific captioning vendor to obtain the most cost-effective service? If not, is it possible to establish such a contract?
      Purchasing New Media:<br />
      • What role does the institution’s purchasing department have in ensuring that any purchased media will be captioned?
      • Are there specific guidelines for instructors/departments when purchasing new media?
      Equipment to View Captions:<br />
      • Does the campus have the necessary equipment to view captioned media? Where is it housed?
      • How does one arrange for specialized equipment that may be necessary to display captioned media?
      Frequently Asked Questions<br />
      • What is the turn-around time to get a piece of media captioned?
      The process to obtain permission to caption videos can be very lengthy and time consuming. The process may take several days or several months. Additionally, copyright owners may not always respond to requests for permission. It is recommended that you plan possible alternatives.<br />
      • What is the cost of adding captions to media?
      • There is much variance in the cost of adding captioning to media. Cost depends on whether the captioning is done in-house or sent out to a captioning vendor. If the captioning is done in-house, the cost depends on the sophistication of the software used.
      • The cost charged by outside vendors depends on the type of media captioned, whether a transcript is provided by the school or is generated by the vendor, and if the vendor is providing complete captioning service or just providing the time-stamping of a digital audio file that will be sent back to the school for synchronization with the video. Some examples of costs are:
      Sending VHS/DVDs to captioning vendor: $500/hr. for media with transcript provided; additional $3/min. if vendor must produce transcript.<br />Sending audio files to online service if school provides transcript: $70/hour<br />Sending audio files to online service if vendor produces transcript: $160/hour<br />Purchasing your own captioning software/hardware: $8,000-$12,000<br />
      • What should I consider when deciding to perform captioning services at my institution or send media out to a captioning vendor?
      • Don’t underestimate the labor costs of adding captioning to media. It is estimated that one hour of media requires 8-10 hours of labor to add captioning.
      • Does your institution have technicians available to do captioning in-house?
      • What is the volume of media needs to be captioned? Can this volume be handled in-house or will you need to send the media out to an outside vendor?
      • How quickly do you need the captioning? Sending media to a vendor may or may not have a longer turnaround time as compared to doing the captioning in-house. Some vendors offer online services that allow schools to submit the audio files of digital media via the internet. The vendor creates transcripts that are digitally time-stamped and returned to the school for synchronizing with the video. These services can offer a quick turnaround time.
      • Some educational systems have established a contract for discounted captioning services with specific vendors.
      • What should I look for when choosing a captioning vendor?
      • The Captioned Films and Videos Program (CFV), now the DCMP, was given the responsibility by the U.S. Department of Education to develop a list of approved captioning service vendors. DCMP looks at captioning aspects that ensure captioning comprehension such as:
      • Spelling accuracy
      • Number of captioned words per minute displayed on-screen
      • Sound effects (e.g., “buzz” or ♫)
      • Explanations of audio (e.g., thinking/dreaming)
      • On-screen placement of captions
      The following is a link to captioning agencies approved by the U.S. Department of Education and Described and Captioned Media Program (DCMP). These companies meet the DCMP standards of quality: http://www.cfv.org/caai/nadh11.pdf <br />
      • How do I get permission to add captions to materials that are copyrighted?
      • Look over the material to find the publisher’s or owner’s information.
      • Call or email the publisher or owner to ask permission to add captions their work.
      • Give a brief explanation of what, where, when and why you need permission to copy their work.
      • If they verbally agree to allow permission to copy the material, ask to follow up with a written agreement.
      • If they feel a verbal agreement is sufficient, thank them for their permission to copy their material.
      • Document the person’s name, date, and a brief description of your conversation.
      • Attach a copy of the written agreement or the verbal written description to the media you plan to have copied.
      • Maintain a copy for your files.
      • See Appendix A for a sample letter to obtain copyright permission.
      • How do I know if a piece of traditional media is captioned and for web-based media players, such as YouTube and Windows Media Player, how do I turn on the captioning?
      • For VHS and DVDs, catalogues and video containers/jackets often show the closed captioned symbol. It is usually displayed on the side or the bottom of the back cover. The symbol may look like one of the following:
      They are usually white letters encased in a black box on the screen.<br />Sometimes it is difficult to know if web-based video is captioned. Media players vary in their support for closed captions as well as in the steps users must follow to turn these features on when they are available.<br />Instructions for turning on captioning for various media players:<br />http://www.washington.edu/accessit/articles?1251 <br />Instructions for turning on captioning for YouTube videos:<br />http://www.google.com/support/youtube/bin/answer.py?hl=en&answer=100078 <br />
      • Doesn’t the Fair Use Law allow educational institutions to make multimedia content accessible by adding captions?
      No, captions cannot be added without permission of the copyright owner.<br />The copyright law may be found at: http://www.copyright.gov/title17 <br />
      • Our department has a lot of media that is not captioned. We want to make it accessible. Where should we start?
      The first priority must be to caption all media that is limiting or prohibiting access for those who have requested this accommodation. This is not optional. This is a legal mandate. A strategy for captioning the rest of your media should consider the content, shelf life and volume of the specific media. Often, it is most efficient to replace old media with a new captioned alternative. Two categories warrant special attention. Media accessible to the public is the community’s first impression of the accessibility of your institution. Distance learning course material should also be considered early. Many students register for online classes believing they will be more accessible. This is often not the case.<br />
      • Are there other ways to make media presentations accessible?
      • Providing a written transcript of the audio content or a sign language interpreter as access for a video offers only marginal access. It is not possible to read a transcript or watch an interpreter and view a video simultaneously. This results in missing the visual information featured in the video while reading the transcript or watching the interpreter or vice versa.
      • How can I legally use a video recorded from broadcast television? Will the recording be captioned?
      Television programs are protected by copyright laws. There are limited exceptions for educational use in nonprofit educational institutions. A set of guidelines known as the "Guidelines for Off-Air Recording of Broadcast Programming for Educational Purposes" was created to address this question. The guidelines do not have the force of law and have never been tested in the courts. A few relevant points are:<br />
      • A recording may be shown only during the first ten consecutive school days after it is made.
      • The recording may not be altered in any way.
      After the ten-day classroom use period expires, the recording may be used only for evaluation -- that is, to determine whether it should be bought or licensed for permanent inclusion in the teaching curriculum. Not later than 45 calendar days after the material was recorded, it must be destroyed.<br />A copy is subject to all the provisions governing the original recording.<br />Only programs broadcast to the general public may be recorded. The guidelines do not apply to programs available only from cable television services such as Showtime, HBO, The Disney Channel, C-Span and ESPN.<br />Further explanation of these guidelines may be found at: http://www.copyright.gov/circs/circ21.pdf<br />Most broadcast television shows must be captioned by law. If you record shows onto VHS media, captioning should automatically be captured. However, if you use a digital video recorder or a DVD recorder, the closed captioning will not be captured unless your equipment has the capability and you turn on the feature to do so.<br />If you have recorded a show that is not captioned, you must request copyright permission to add captions.<br />Appendix A: Sample Letter to Obtain Copyright Permission<br />Letterhead from Your College Campus<br />(Insert Date)<br />(Insert Name/Address of the Copyright Owner Attn: Permissions Department)<br />Dear (Insert Name of the Contact Staff in the Company’s Permissions Department):<br />The purpose of this letter is to request authorization to modify instructional audiovisual material to include captioning for students attending public postsecondary education at the (insert name of college) in (insert city), Wisconsin.<br />Please complete the statement that appears on the bottom portion of this correspondence and return it to:<br />(Insert Name, Title, Address, and Contact Information of College Staff Seeking Permissions)<br />This request is time sensitive and requires an immediate response. Please reply on or before (insert date).<br />Title of Publication and Publishing Details: <br />Copyright/Trademark Owner: <br />Address/Contact Information for Copyright/Trademark Owner:<br />The (insert name of college) requests authorization to modify the audiovisual material to include captioning for the purpose of ensuring access for students with disabilities within the instructional setting for education purposes. The (insert name of college) presently owns _____ copies of the material. The material is used in conjunction with classroom instruction for educational purposes. The audiovisual material will be used until such time the material is removed from (insert name of college) collection (unless the Copyright/Trademark Owner specifies an expiration date).<br />Your signature on this document confirms that permission has been authorized. This authorization will be clearly placed on the audiovisual material, along with the date that permission was authorized.<br />Permissions Department AuthorizationDate<br />(Printed Name, Title, and Company of Individual Granting Authorization)<br />Appendix B: Sample Procedures for Obtaining and/or Producing Captioned Media<br />College #1<br />College Representatives:<br />
      • Will purchase the open and/or closed-captioned version of new instructional media and other audiovisual materials.
      • If a particular product is not available with captioning, and the College requires that particular product, the purchaser will obtain written permission from the copyright owner to add captions to the video. The purchaser may contact Disability Services for assistance with this process. Please note that permission must be obtained prior to purchase, as a condition of purchase. In the event that permission is denied, a suitable captioned alternative will be sought.
      Faculty Members:<br />
      • Will only show captioned media in the classroom and will only assign captioned media as a course requirement.
      • Faculty utilizing media from their own personal or departmental collections (original or commercial productions) are responsible for ensuring it is captioned. In the case of commercially produced videos, appropriate public performance rights and licenses must be available for viewing at the College. Three years after the effective date of this policy, all captioning costs are to be built into departmental budgets. For further information and assistance, contact Disability Services.
      Library:<br />
      • Will maintain a library of captioned media resources that are available for faculty, staff, and student use.
      • Will maintain a record of all permissions for captioning and the digitization of copyrighted media resources.
      • Will assist faculty by:
      • Identifying materials that are captioned prior to purchase.
      • Finding suitable, alternative media products that are captioned.
      Disability Services:<br />
      • Will assist with obtaining permission to caption.
      • Will coordinate the process for captioning media resources for which permission to caption has been obtained.
      • Will maintain a list of approved vendors to perform captioning.
      IT Department:<br />
      • Will ensure all classroom and presentation equipment is caption-compatible and the default on all TVs, etc., is set to provide open captioning.
      • Will provide specific instructions on the existing instruction sheets for faculty so it will be easier for them to show captioned media in their classroom.
      • Will ensure this information is incorporated into faculty training on AV equipment.
      Purchasing Department:<br />
      • Will forward all purchase orders for media resources to Library for review to ensure all resources acquired are captioned or captionable.
      All Departments of the College:<br />
      • Will support this policy by ensuring all college employees are made aware of the policy, their obligations, and the supports available to assist them.
      Marketing Department:<br />
      • Will ensure all new communications and promotional materials produced under its own auspices and, on behalf of and by College departments, will be captioned.
      College #2<br />The College is obligated to comply with sections 508 (Electronic Formats) and 504 (Print Materials) of the Rehabilitation Act and the Americans with Disabilities Act (ADA) by using videos, digital, and print forms of instructional material only if they are provided in accessible formats.<br />Legal opinion concerning Section 508 from this institution’s Chancellor’s Office recommends the following options concerning video materials:<br />Purchase video materials that are already captioned.<br />Obtain copyright permission to caption and caption a legally-obtained video currently in inventory.<br />Obtain loan of captioned media.<br />Provide alternate selection of materials.<br />New Purchases<br />Purchase only accessible materials. The College will not purchase new video materials that are not captioned. If faculty chose to purchase videos that are not captioned, it will be the faculty member’s responsibility to receive copyright permission to caption the videos and the cost of captioning the videos will be borne by the faculty members’ division.<br />Obtaining Copyright Permission to Caption Legally Obtained Videos<br />In order to comply with copyright laws, videos should not be captioned without the copyright owner’s permission. The process to obtain permission to caption videos can be very lengthy and time consuming. The process can take anywhere from two weeks to several months. Additionally, copyright owners may not always respond to requests for permission. It is recommended that you plan possible alternatives. Contact Instructional Media Services (IMS) staff to get advice on how to obtain copyright permission. Once copyright permission has been obtained, IMS will take the necessary steps to have the video captioned. Videos will not circulate until permission to caption and captioning have been completed.<br />Videos Currently in IMS Inventory:<br />Faculty should not use video materials that are not obtained legally. Faculty should also not use legally copied videos that are not captioned. Copied videos that are not used, nor captioned, will be taken out of circulation. The Director of the LRC will work with all departments to prioritize which video titles need to be purchased and/or captioned (using circulation and requests as criteria).<br />Videos Currently in Division/Department Collections:<br />The best approach would be to replace the uncaptioned video with a captioned version. If the video is an integral part of curriculum, the division or department must obtain permission to caption from the copyright owner. Contact IMS staff to get advice on how to obtain copyright permission.<br />Captioning funds are available to divisions and departments on a first-come, first-served basis. Once copyright permission has been obtained, contact IMS staff to request funding to caption. Once funding has been approved, IMS will take the necessary steps to have the video captioned.<br />Videos Owned by Faculty:<br />The best approach would be to replace the uncaptioned video with a captioned version. Faculty would need to request the purchase of the captioned version through their academic division. If the division is unable to purchase a captioned replacement, faculty should contact the Director of the LRC to explore purchase through IMS.<br />If a captioned version cannot be obtained and the video is an integral part of the curriculum, the district will pay to have a video captioned provided the faculty member who owns the video donates/transfers ownership to this institution. Faculty must obtain permission to caption from the copyright owner. Contact IMS staff to get advice on how to obtain copyright permission. Once copyright permission has been obtained, IMS will take the necessary steps to have the video captioned. Videos will be kept in IMS collection so that it will be available for use by other personnel of the district.<br />If a captioned version is not available, and transfer of ownership is not possible, find an alternative selection. Please see the Sources for Captioned Media webpage or contact the Director of the LRC or the Distance Education Coordinator for help finding an alternate selection.<br />Recording and Using Videos from Broadcast Sources:<br />Broadcast shows may be recorded and retained for a maximum of 45 days after the recording date. The video may not be used unless it has captioning. Most broadcast television shows must be captioned by law. If you record shows onto VHS media, captioning should automatically be captured. However, if you use a digital video recorder or a DVD recorder, the closed captioning will not be captured unless your equipment has the capability and you turn on the feature to do so. Review your digital recording equipment manuals to learn how to capture the captioning. If your equipment does not have the capabilities to capture the closed captioning, contact the IMS Department to have them record the show for you. Faculty are responsible for complying with the law which requires broadcast shows NOT to be shown after the 45-day limit is up.<br />If you have a recorded show that does not have captioning, it will not be captioned without copyright permission. Contact the IMS Department to get advice on how to obtain copyright permission. Once copyright permission has been obtained, the IMS Department will take the necessary steps to have the video captioned once copyright permission is granted. Please be aware that the process of obtaining copyright permission and captioning a video is lengthy and may not be obtained before the 45-day limit for using a video copied from a broadcast.<br />