Online Accessibility

Background

The American School for the Deaf (ASD) is committed to ensuring equal access to opportunities to learn and communicate for people with disabilities, including but not limited to deaf and hard of hearing individuals. Consistent with its mission and communication approach, ASD will remove and prevent barriers to accessibility of online content it creates and/or maintains by complying with the accessibility of online content and functionality standards included in the World Wide Web Consortium’s (W3C’s) Web Content Accessibility Guidelines (WCAG) 2.0 Level AA, and the Web Accessibility Initiative Accessible Rich Internet Applications Suite (WAI-ARIA). If, at any point in time, content is inaccessible, prompt action shall be taken to ensure access. In the event that provision of access would be impossible without fundamentally altering the content or imposing an undue burden on the School, the School shall provide an equally-effective alternate method of access.

Scope

This policy sets forth required protocols and procedures regarding web content on ASD’s website (located at www.asd-1817.org), and third party content and/or applications on the ASD website (e.g. YouTube videos, forms implemented on web pages, etc.). The requirements of this policy apply to all members of the ASD community responsible for creation of online content and/or publication of online content for the ASD website. This policy also provides information about ASD’s efforts to ensure access to web-based content to ASD community members (e.g., students, employees, family members, visitors, and prospective students/employees).

Procedures

List of 5 items.

Content Standards

Web-based content will be developed and maintained in accordance with ASD’s content management system and shall comply with the World Wide Web Consortium’s (W3C’s) Web Content Accessibility Guidelines (WCAG) 2.0 Level AA and the Web Accessibility Initiative Accessible Rich Internet Applications Suite (WAI-ARIA), as updated. Content shall be current and relevant, and outdated, irrelevant, or obsolete content shall be promptly deleted.

ASD is committed to ensuring the accessibility of multi-media content. Photos and graphics should be accompanied by alternative text, unless used solely for decorative purpose and not needed as an essential descriptor on the page. Video and audio files shall include closed-captioning and a text title and, when appropriate, an accompanying script and/or description.

Third-party content or applications to be used on the ASD website must comply with the standards set forth in this policy. ASD will contract and/or partner with third party vendors who provide content, applications, or products that meet this policy’s accessibility standards.
Content Creation and Use of Approved Templates

The Administration of ASD shall establish approved templates for the creation of web-based content. Any approved templates shall be created in conjunction with ASD’s content management system. The content management system provider (currently Final Site) shall ensure that any approved templates are certified to meet the standards established in this policy (i.e., World Wide Web Consortium’s (W3C’s) WCAG 2.0, Level AA and the Web Accessibility Initiative Accessible Rich Internet Applications Suite (WAI-ARIA) 1.0 for web content).

All new content produced by ASD community members or third party contractors for use on ASD’s web site or web-based platforms shall be created using approved templates, unless otherwise exempted by the Administration, and must conform to the standards established in this policy (i.e., World Wide Web Consortium’s (W3C’s) Web Content Accessibility Guidelines WCAG 2.0, Level AA and the Web Accessibility Initiative Accessible Rich Internet Applications Suite (WAI-ARIA) 1.0 for web content).
Review and Publication of Content

ASD’s Information Technology Manager shall be responsible for establishing procedures for the review and evaluation of new content created by ASD community members and/or third party contractors to ensure that all new content is evaluated for compliance with the accessibility standards set forth in this policy. New content shall only be published to the ASD web site in accordance with the content review and evaluation procedures. The content review and evaluation system shall also employ, as appropriate, a web governance platform or other method to periodically conduct scans to identify content violating the accessibility standards set forth in this policy.
Training

Initial training of all individuals in the ASD community with responsibility for creation of web-based content will be conducted as soon as practicable (and, in any case, no later than December 26, 2017). Training shall be provided to such community members annually thereafter. Any community members who are hired or are given authority to develop and/or publish online content after the initial training shall be promptly trained. Training conducted in accordance with this policy shall include will include information regarding the use of the ASD content management system and web accessibility training. The web accessibility portion of the training may cover topics including but not limited to: an overview of this policy and the importance of web accessibility; creating content with web accessibility in mind; real-world examples of accessible content creation, including alternative text, link text and titles, and video/audio content creation.
Accessibility Audits

An accessibility audit shall be conducted as soon as practicable after adoption and publication of this policy (and, in any case, no later than April 12, 2018). An accessibility audit will be completed annually thereafter, under the direction of ASD’s Information Technology Manager, and shall judge compliance against the standards established in this policy (World Wide Web Consortium’s (W3C’s) WCAG 2.0, Level AA and the Web Accessibility Initiative Accessible Rich Internet Applications Suite (WAI-ARIA) 1.0 for web content). The audit shall include online content provided by third parties for which ASD is responsible. A report detailing the findings of the audit will be developed. ASD’s Information Technology Manager will review the list of pages or files that do not meet accessibility standards and create and execute an action plan to promptly address any identified accessibility concerns.

Inaccessible Content / Complaints

Consistent with its mission to remedy communication barriers, ASD is committed to take such steps as may be necessary to ensure that no individual with a disability is excluded from or denied access to, online content offered by ASD. To effectuate this commitment, ASD adopts the following procedures:

The Information Technology Manager, and all staff involved in the development and delivery of online content, are directed to take any and all steps as may be necessary to ensure access to online content offered by the School and to promptly remedy any and all instances of inaccessible content.
The School shall maintain a prominent and conspicuous notice on its web site informing visitors of the method for filing a notice of inaccessible content. Any notices of inaccessible content received by the School shall be promptly transmitted to the Information Technology Manager for review.
Upon receipt of such notice, the Information Technology Manager shall promptly remediate any inaccessible content. The provision of prompt remedy shall take priority upon receipt of a notice of inaccessible content. The content of the notice of inaccessible content and the remedy of the same shall be documented in writing, maintained by the School, and shared with the Executive Director. The requestor shall be promptly be informed that the inaccessible content has been remedied. Absent extenuating circumstances, provision shall be made for remedy of any inaccessible content within three (3) working days of notice of the same.
All instances of inaccessible web content shall be promptly and appropriately remedied. In a rare instance, content may not be able to be made accessible (e.g., due to technological or other limitations), may not be able to be rendered accessible without prohibitive expensive or difficulty, or may not be made accessible without fundamental alteration to the content itself. Should the Information Technology Manager determine that no alternative means of access is available (or that any potential means of access would result in substantial and unreasonable expense or difficulty) or that the content in question cannot be made accessible without fundamental alteration, the Information Technology Manager shall promptly submit written documentation of such determination, as well as a proposed alternative means of access, to the Executive Director for review. The Executive Director shall review and approve or deny such proposal within two (2) working days of receipt of the same. In the event of a denial of a proposal, the Executive Director shall instruct the Information Technology Manager to submit a revised plan for remedying the inaccessible content or providing a revised alternative means of access within three (3) working days.
Should the Executive Director affirm a determination of the Information Technology Manager that no means of access is available (or that any potential means of access would result in substantial and unreasonable expense or difficulty) or that the content in question cannot be made accessible without fundamental alteration, the requesting party shall be promptly notified in writing of such determination. Such written notice shall explain the impediments to providing access to the content in question and shall offer and describe alternative means of access to the requestor. Such written notice shall also include a copy of the School’s complaint procedures regarding inaccessible web content and information about filing a complaint with the Office for Civil Rights and any other appropriate state and/or federal agency.

Any individual who wishes to submit a complaint related to the accessibility of the ASD website may contact:

Gwynne C. Deveau
Human Resources Manager

P: 860-570-1808

F: 860-215-2891

Gwynne.Deveau@asd-1817.org

Complaints will be investigated by the Director of Human Resources, or his/her designee. An investigation of the complaint shall be completed within fifteen (15) working days. Extension of the timeline may be approved by the Executive Director. The investigator shall prepare a written report of the findings and conclusions within five (5) working days of the completion of the investigation. The investigator shall contact the Complainant upon conclusion of the investigation to discuss the findings and conclusions and actions to be taken as a result of the investigation. A record of each complaint made pursuant to the Website Accessibility Policy shall be maintained at the School offices and shall include a copy of the complaint filed, report of findings from the investigation, and information regarding the disposition of the matter.