Captioning and American Sign Language Interpreter Policy [Effective 5/9/2025]

This policy provides an outline of the captioning and American Sign Language (ASL) requirements and processes per Section 504 of the Rehabilitation Act of 1973, as well as the Americans with Disabilities Act (ADA).

This policy applies to RISD faculty, staff, and students.

• Closed-Captioning: a text description, typically at the bottom of the screen, and is available and visible when turned on by the user (and can be turned off by any viewer). 
• Open-Captioning: a text description, typically at the bottom of the screen, and is available and visible to all viewers and cannot be turned off. 
• Communication Access Realtime Translation (CART):  instant translation of the spoken word into text by a human type-corrector using a stenotype machine, computer, and real-time software. The text appears on a computer monitor or other display.  CART services can be provided on-site or remotely via a web conferencing tool and are also referred to as Live Professional Captions. 
• Automatic Speech Recognition (ASR):  use of computer-based techniques to identify the words a person has spoken through a microphone, analyze it using an algorithm, and produce a text output.

CART or Live Professional Captions deliver highly accurate real-time captions. Their most significant benefits include their accuracy and quality. Unlike ASR technology, human captioners are trained professionals able to capture the speaker’s intent, ensuring that essential words are captioned correctly. Live professional captioning is the most accurate, legally compliant captioning service.

• There is a cost to live professional captioning. The costs associated with disability access (e.g., CART, ASL Services, clear masks) should be considered part of the overall operational expense of any event. Event planners should include the expense of any anticipated accommodations as a budget item in the event planning.
• Live professional captioning can also require more time to hire and schedule.

In accordance with Section 504 of the Rehabilitation Act of 1973, as well as the Americans with Disabilities Act (ADA), RISD is committed to making its classes, programs, events and services accessible to everyone. Reasonable accommodations, as defined by law and by the Disabilities Accommodations in the Workplace Policy and the Nondiscrimination Policy & Procedures, are made for people with disabilities or special needs who request assistance.

Rhode Island School of Design is committed to providing video and audio files that are accessible to all. RISD’s commitment to digital accessibility is grounded not only in principles of social equity and inclusion but also in the knowledge that accessible content enhances usability for everyone. English Language Captioning is a universal resource vital to a variety of users, including those who are deaf/hard of hearing, non-native English speakers, visual learners, individuals with disabilities, mobile users, or individuals in noisy environments.

All faculty, staff and students are to ensure

• All synchronous/asynchronous courses, events, and public-facing meetings using Zoom, Google, or similar platforms must enable the built-in captioning feature, which provides real-time automatic speech recognition (ASR) captions and transcripts for public-facing meetings and webinars. We recommend using any of the following tools:
  • Zoom
  • YouTube
  • PowerPoint
  • Google Docs
• Materials essential for RISD and/or other activities central to the college’s mission that are not posted for public consumption must be captioned using reliable auto-generated captioning technology as they become available. This also includes asynchronous courses offered through RISD Continuing Education.
• For any video widely distributed or featured on the RISD website, all auto-generated captions must be reviewed for accuracy by the content owner.
• Employees seeking reasonable accommodation to perform the essential functions of their job can learn more about the Human Resources Disability Accommodations process: Disabilities Accommodations in the Workplace Policy. Applicants requiring additional or alternative accommodations should communicate their request directly to the Human Resources (“HR”) Talent Partner recruiting for the desired position.
• Students, including student employees seeking reasonable accommodations, can learn more about Disability Support Services and the academic and non-academic accommodations processes here.

Instructional material and media:

Individuals should make every effort to use closed captioning in the following teaching and learning items (in order of priority):

• Material for use by students, faculty, or staff with a reasonable accommodation on file with either DSS or HR;
• Material which is in public-facing courses and/or web pages;
• Material that will be used multiple times or over an extended period of time (will be used for more than one class or semester);
• Material that will be re-used in new courses.

Events:

Communication Access Realtime Translation (CART)

While we encourage live captioning for all events and meetings, no matter the number of participants or size, there are scenarios where an event sponsor or meeting host must provide live captions:

• When a reasonable accommodation has been requested from an individual who plans to attend: All RISD events must publish an accommodation statement providing attendees with contact information to request additional captioning or other accommodations. If a request for captions is received from a prospective attendee, the event host should seek to provide live captions via a professional captioner. Any cost associated with providing a reasonable accommodation will be covered by the entity sponsoring the event. The accommodation preferred by the participant should be given primary consideration; however, in some circumstances, alternative accommodations may be offered as long as they are effective.

• Major Institutional Events: RISD requires that major events must be live-captioned by a professional captioner to industry standards. Such events include:
  • Commencement
  • Convocation
  • Martin Luther King, Jr. events
  • Presidential Addresses
  • Large, very public events (larger than 200 people that are open to RISD community members and/or the public)

• Events that are live-streamed on the RISD Website or Social Media: For RISD events that are live-streamed on RISD’s YouTube channel, websites, or other public accounts, RISD requires live professional captioning to be included as part of the overall video production. Captioning should be enabled for shorter video content, such as Instagram story videos. This can be coordinated with RISD Marketing & Communications.

Automatic Speech Recognition (ASR)

• Recorded Events: Captions must be made available for other recorded (but not live-streamed) events published to RISD's YouTube channel, websites, or other public accounts. Auto-generated captions from Panopto or YouTube are acceptable for this purpose. In some instances, such as for high-visibility videos, RISD Marketing & Communications may specify that a video be run through a post-event captioning service to ensure that proper names and other specific terms are accurately captioned.

ASL Interpreters

• Large, public events (larger than 200 people that are open to RISD community members and the public). If a reasonable accommodation is requested to an event organizer for an ASL interpreter, then an ASL interpreter must be contacted/scheduled for the event. For ASL interpreter resources, please refer to the RISD Event Planning Accessibility Guidebook linked under “Procedures”.

DigitalCommons@RISD: Accessibility Statement

Rhode Island School of Design has committed to Social Equity and Inclusion principles and practice. A campus accessible to all requires that we proactively plan events free of all barriers: physical, communication, or others, so that all individuals may meaningfully participate in campus activities and events. Under the Americans with Disabilities Act (ADA), RISD is required to provide access to programs and services to all qualified participants regardless of disability. Additional information on how to make events accessible and accessing resources such as ASL Interpreters, CART Resources, and captioning resources can be found in the RISD Event Planning Accessibility Guidebook

Policy Sanctions

Violations of this policy may result in applicable disciplinary procedures in accordance with Human Resources (employees) and Student Life (students) policies and procedures and applicable collective bargaining agreements. Sanctions will be determined on a case-by-case basis pursuant to applicable policies and procedures and may be determined based on multiple factors, including, but not limited to, past conduct, severity of the violations, the impact upon the community or others, or any combination of these factors.

Additionally, RISD reserves the right to review alleged violations of this policy in conjunction with other appropriate offices and under other applicable College policies and procedures, including but not limited to those listed under Related Policies.

• Disabilities Accommodations in the Workplace Policy
• Nondiscrimination Policy & Procedures 2023-24

This policy was approved as of: 4/23/2025

This policy was last reviewed/modified on: 4/24/2025

Next scheduled review: 4/23/2027

Issuing Office

Disability Support Services

Responsible Officer

Vice President, Student Life

Vice President, Human Resources

Individuals/offices required for review and changes

Senior Director, Digital Experience

Chief Information Officer

Equity & Compliance

Vice President, Social Equity & Inclusion

Provost

Chief Marketing & Communications Officer

Vice President, Institutional Advancement

RISD Museum

External Campus Conference and Events Services