Harvard University is committed to making its websites accessible. In accordance with this commitment, and with the knowledge that accessible digital content generally enhances usability for everyone, this Policy is established to improve the user experience for those with disabilities. The University recognizes that websites and web-based applications are often integral to the academic and administrative work of the University. This Policy addresses the needs of individuals with disabilities who seek to use University Websites to participate in University programs and activities and/or conduct University Business.
This policy applies to University Websites.
For the purposes of this policy, Harvard University will use The Worldwide Web Consortium’s Web Content Accessibility Guidelines version 2.1, Level AA Conformance (WCAG 2.1 Level AA) as “the Standards.”
The Path Forward
University Websites that are created or undergo substantial revisions or redesign after December 1, 2019, are expected to conform to the Standards with respect to their platforms and infrastructure. Where conformance with the Standards is not technically feasible or may require extraordinary measures due to the nature of the information or the purpose of the University Website (e.g., it would create an undue hardship by fundamentally altering the site), a request for exception can be made. Insufficient funds of a particular unit will not be considered a valid reason for an exception except in extraordinary circumstances and as approved by the Accessibility Steering Committee (ASC). Site Owners requesting an exception may be required to submit an accommodation plan detailing how the unit will make information from its University Website available in an alternative format to individuals with a disability. Details on how to submit an exception request will be found in the Web Accessibility Implementation Procedures.
In addition, beginning no later than December 1, 2019, all Site Owners of University Websites should aim to make any new digital content created and produced at Harvard and posted on those sites conform to the Standards, to the extent technically feasible. Where conformance with the Standards is not technically feasible, Site Owners should consider how to make the content available in an alternative format to individuals with a disability.
The Accessibility Steering Committee
As further outlined in the Web Accessibility Implementation Procedures, the Accessibility Steering Committee (ASC) will establish and recommend to Senior Leadership a prioritization schedule for improving accessibility on certain existing University Websites. Priority shall be given to University Websites that are among the most highly trafficked and to those that contain core institutional information.
The ASC, at the direction of and in coordination with Senior Leadership, periodically shall review this Policy, its associated procedures, and the governance model and, as appropriate, recommend changes. The review will help ensure that the Policy continues to align with the University’s mission, including its commitment to accessibility.
Responsibility and Commitment
Senior Leadership is responsible for establishing mechanisms to ensure that University Websites within their areas conform to this Policy and have an identified Site Owner. University Websites should indicate commitment to accessibility by including a link to this Policy.
The ASC may require that some or all non-conforming portions of a University Website be brought into conformance by designated staff or Suppliers, and the expense of that work may be charged to the unit that is responsible for assuring the accessibility of that information. If the ASC is unable to determine who is responsible for the content of a non-conforming University Website, then the ASC may ask that HUIT remove the non-conforming University Website from the Harvard domain registry until it can be brought into conformance.
Upon a specific request by an individual who is unable to access specific content on a University Website, either the requested content must be updated to conform to the Standards, or the requested content otherwise must be made available in an alternative format in a timely manner. The unit responsible for the creation and maintenance of the content on this website is responsible for making it accessible or providing the alternative.
A Site Owner is an individual designated by Senior Leadership as responsible for one or more University Website(s).
A Supplier is any third party with which Harvard contracts to supply information technology products, software, or services.
A University Website is any public-facing website or web‐based application within a Harvard-controlled domain used to conduct University Business by Harvard faculty and staff.
University Business includes activities carried out under the auspices of Harvard University but does not include activities organized or conducted by students or student organizations.
Governance, Roles and Responsibilities
Senior Leadership: The University’s President, Provost, Executive Vice President, and Vice Presidents, the Deans of the several Schools, their Department Chairs, and the Directors of University and School Centers or their designees (“Senior Leadership”) each are responsible for: (1) promoting awareness of this Policy; (2) identifying Harvard employees to serve as Site Owners of University Websites within their areas; and (3) ensuring that such University Websites conform to this Policy.
Accessibility Steering Committee: The President and/or Provost shall convene the Accessibility Steering Committee. The ASC shall be responsible for: (1) providing periodic review of this Policy and its implementing procedures, with recommendations going to the President and/or Provost; (2) establishing and recommending to Senior Leadership a prioritization schedule for bringing certain existing University Websites into conformance with the Standards or making them accessible in an alternative manner; (3) working with Senior Leadership to assure general awareness of this Policy; (4) assessing and reporting to the President and/or Provost the University’s accessibility efforts as outlined in this Policy; and (5) reviewing and deciding on requests for Policy exceptions.
HUIT Digital Accessibility Services: Harvard University Information Technology’s Office of Digital Accessibility Services (“DAS”) shall be responsible for supporting Senior Leadership in creating and sustaining a culture of commitment at Harvard. DAS shall provide training, guidance and information on accessibility standards and best practices and will work with Site Owners and their technical partners to advise or augment their efforts towards adopting the Standards. Guided by ASC priorities, DAS shall track and support remediation efforts throughout Harvard.
University Disability Resources: The University Disability Resources office within Central Administration serves as a University-wide resource on disability-related information, procedures and services for the Harvard community, digital and otherwise.
Digital Accessibility Liaisons: Each member of Senior Leadership shall designate a staff member as a Digital Accessibility Liaison to coordinate local efforts and report on progress to the ASC and DAS.
Procurement: The office of Strategic Procurement, the HUIT Vendor Management Office, the procurement managers reporting to the several Schools’ Chief Information Officers, and other website or web application product owners shall assure that contracts with Suppliers seeking to develop or provide University Websites hold Suppliers accountable to the Standards.
Site Owner: Site Owners have primary responsibility for: (1) ensuring that the University Websites for which they are responsible conform to this Policy; and (2) educating and training those who contribute to those sites on the requirements of this Policy and the tools and methods for securing conformance with it.
Adopted: April 30, 2019