Digital Accessibility Policy Implementation

Implementation Procedure


On April 30, 2019 Harvard University announced the adoption of a Digital Accessibility Policy (the “Policy”), which sets forth the University’s accessibility expectations for University Websites and the content posted to them, starting on December 1, 2019. The Policy calls for the University to promulgate “Web Accessibility Implementation Procedures” (the “Procedures”) to provide interpretation and guidance; identify resources, support, and infrastructure relating to digital accessibility; and explain how members of the University community can meet the Policy’s requirements.

This iteration of the Procedures was developed by the University Accessibility Committee’s Digital Accessibility Working Group (DAWG) and formally adopted by the Accessibility Steering Committee (ASC). The DAWG and ASC will update the Procedures regularly to reflect new technological and structural developments at the University, as well as feedback from the University community.

Policy Requirements

The Policy applies to University Websites, which it defines to mean “any public-facing website or web-based application within a Harvard-controlled domain used to conduct University Business by Harvard faculty and staff.” The Policy in turn defines University Business to include “activities carried out under the auspices of Harvard University,” except for “activities organized or conducted by students or student organizations.”

These Procedures give further definition to “University Websites” and “University Business,” with supporting examples, below.

The Policy’s requirements of University Websites are as follows:

  1. Starting on 12/1/2019, “University Websites that are created or undergo substantial revisions or redesign … are expected to conform to the Standards with respect to their platform and infrastructure.”

  2. Starting on 12/1/2019, 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 is not technically feasible, they should consider how to make content available in an alternative format to individuals with a disability.

The “Standards” in the Policy are the Web Content Accessibility Guidelines, version 2.1, Level AA Conformance (“WCAG 2.1 AA”). These Procedures elaborate on key concepts (“created or produced at Harvard,” “substantial revisions or redesign” in the Policy and Procedures Terms and Phrases section below.

Identifying a Site Owner for a University Website

A Site Owner is the designated role or individual responsible for a University Website. Site Owners are responsible for the accessibility of their sites and must hold content creators, developers and other necessary parties accountable for ensuring the site’s accessibility. Site Owners are determined by the unit's Dean, Vice President, Chair and/or Director. Site Owners may not have the technical knowledge and expertise needed to ensure that their “owned” websites conform to the Policy. While a Site Owner is an individual person, these Procedures recommend that Site Owners be assigned based on their role, as individuals tend to change roles at the University over time.

Examples of Site Owners

  • Three different labs each have their own website. Organizationally, the Labs report up to a Department. The Department reports up to a Division. The Division reports into a School. The School is responsible for holding an appointed individual on behalf of the Division and Department accountable. Appointed individuals may be the Director of Communications, a specified Associate Dean, or the PI of the lab, as appointment structure may vary across Harvard schools.

  • An interfaculty initiative (IFI) creates a site to promote their annual event. Organizationally, the IFI reports up to The Office of the Provost. The Provost is responsible for holding the IFI accountable. The appointed Site Owner may be the Director of the Initiative or a designated Associate Provost but should not be ”the Office of the Provost.”

Reporting and Responding to Accessibility Issues

The Policy expects University Websites to indicate commitment to accessibility by including a link to the Harvard Digital Accessibility Policy from each website. The “Report a Web Accessibility Concern” form will be linked to from the Policy page, providing the primary means for users to submit requests or express concern about a particular University Website.

The Digital Accessibility Services (DAS) team within Harvard University Information Technology (HUIT) will triage requests submitted via this form and route them to the relevant Site Owner and Digital Accessibility Liaison (DAL) for follow-up. Site Owners who learn of a user accessibility issue through other channels also should submit the issue using the “Report a Web Accessibility Concern” form so that all such concerns can be catalogued centrally. Site Owners should ensure that prompt efforts are undertaken to address any reported barriers to access. If Site Owners are unable to address the issue promptly, the Site Owner and the Digital Accessibility Liaison should contact University Disability Resources to discuss options for an accommodation.

Site Remediation

Under the Policy, the Accessibility Steering Committee may require a Site Owner to establish a plan to improve some or all non-conforming portions of an existing University Website. This may include websites that would not otherwise be required to conform, such as a site created or revised prior to December 1, 2019. In evaluating websites that require remediation, the ASC will consider several factors, such as:

  • How essential the website or its content is to University functions (i.e., is it functional or informational?);

  • Whether the Site Owner is already planning a redesign;

  • Target audience (i.e., is the website directed to internal or external users?); and

  • Size of audience.

Remediation Process

The ASC will refer identified sites to DAS for further evaluation. The DAS will in turn contact the Site Owner and the applicable DAL to provide information about their site and identify resources available to support remediation. DAS can assist Site Owners in deciding what to improve first and how to approach the work, such as through incremental updates made by existing staff, contracted work, and/or platform migration. Site Owners must provide an evaluation report to the ASC.

Evaluating a University Website for Accessibility

Automated testing tools speed up the process of evaluation and allow for regular monitoring. However, human evaluation is also required to assess a website’s accessibility since no tool alone can determine whether a site conforms to the Standards.

Automatic scanning

The use of an automatic testing tool licensed by the University, such as Siteimprove, is recommended as a first step to scan and assess the broad level of accessibility for a University Website.

Manual testing

Assistive technology and/or browser plug-ins should be used as part of manual testing. The University’s Digital Accessibility Services unit provides simple quick start guides to identify the most common accessibility issues. Manual testing includes the use of keyboard-only testing, assessing accurate page titles and screen reader testing, among others.

Expert review

An experienced professional can perform a deeper evaluation, which typically results in a detailed listing of issues and specific recommendations for improvements. DAS can assist with identifying reputable third-party service providers to conduct an expert review as needed.

Available Assistance

We all have a role to play in making Harvard’s digital information more accessible. In addition to the recommended manual testing tools and other self-service resources detailed above, the University has established networks of experts available to the community for consultation.

HUIT Digital Accessibility Services (DAS)

Harvard University Information Technology’s Office of Digital Accessibility Services (“DAS”) supports the University in creating and sustaining a culture of commitment at Harvard. DAS is a team of accessibility professionals that provides training, guidance, and information on accessibility standards and best practices, working directly with Site Owners, Digital Accessibility Liaisons, and their technical partners to advise or augment their efforts towards adopting the Standards. DAS oversees enterprise tools and services used at Harvard for monitoring or improving digital accessibility. Also, guided by ASC priorities, DAS tracks and supports remediation efforts throughout Harvard. DAS can be contacted by emailing

Digital Accessibility Liaisons (DAL)

In accordance with the Harvard University Digital Accessibility Policy, the University has established a network of Digital Accessibility Liaisons (DAL) to coordinate local efforts, facilitate training, and monitor progress. The DALs are appointed by Senior Leadership from within each school and administrative unit to monitor and assist accessibility efforts for their unit’s web pages and web applications. DAL are local contacts for digital accessibility and are available to assist their local communities in identifying resources to ensure the accessibility of their unit’s web pages and web applications. They work in concert with HUIT’s Digital Accessibility Services (DAS) team. DAL will be notified by DAS when an accessibility request is received regarding a University Website or application overseen by a Site Owner in their unit. DAS oversees accessibility issue reporting, and they may assist Site Owners and DAL in preparing appropriate responses or action plans if necessary.

Accessible Procurement

Site Owners, product owners, or web application owners are responsible for accessibility by ensuring that contracts with vendors or suppliers seeking to develop or provide University Websites hold those vendors and suppliers accountable to the Standards. 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 address accessibility in accordance with the Accessible Technology Procurement and Development Policy (ATPDP) adopted by HUIT and the CIOs.

Training and Support

To assist the Harvard community in meeting the responsibilities described here — spearheaded by DAS but offered by many local teams across campus — training and support resources are readily available to those responsible for creating or maintaining a University Website. The training and supports include information about Harvard’s policies, along with instructions on how to make websites and web-based applications accessible, how to perform manual checks and use automated tools for evaluation, and how to get help.

University Disability Resources (UDR)

The University Disability Resources (UDR) office within Central Administration serves as a University-wide resource on disability-related information, procedures, and services for the Harvard community, digital and otherwise. DAS collaborates closely with UDR, considering many dimensions of accessibility to make Harvard a more inclusive and welcoming campus to persons with disabilities.

Requesting a Temporary Exception

In order to request a temporary exception to the Harvard University Digital Accessibility Policy (Policy), site owners are required to submit a Policy Exception Request Form to the ASC for approval.

Exception requests must include a detailed description as to why conformance with the Policy is not technically feasible or would cause undue hardship. Site owners requesting an exception will be required to submit an Equally Effective Alternate Access Plan (EEAAP) detailing how information will be made available to individuals with disabilities until conformance with the Standards is achieved. According to the Policy, “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 [ASC].” All exception requests will be reviewed by the ASC within 30 days. Documentation of exception requests and their disposition will be retained by the ASC, which will undertake periodic review of the exceptions process. Examples of content that could be appropriate for a Policy exception, depending on the circumstances and resources available at the time of the request, include (but are not limited to):

  • Computational spreadsheets containing program modules or macros that were developed to perform automated analysis or draw data from external or legacy databases.

  • Third-party licensed documents from scientific journals or conferences (e.g., where the license agreement does not allow the user to modify the file or where the files are hosted and updated by the journal on its server).

  • Scanned written or poor image/text quality historical documents or publications that are in a digital archive and/or Archived historical legacy files.

  • Complex dynamic visualizations such as medical diagnostic or research imaging technologies, 3D models, virtual environments, computer-aided design (CAD) software.

  • Complex math, physics, and chemistry notations.



All videos posted to University Websites must include synchronized closed captions. Audio files, such as podcasts, that are posted to University Websites must be accompanied by transcripts.

Harvard-owned and managed channels on third-party platforms (YouTube, Facebook, Twitter, Vimeo, Kaltura, Brightcove, SoundCloud, etc.) do not meet the definition of a University Website and are not subject to the Policy. However, content owners who control these channels are strongly urged to make content on these channels accessible, using any available platform features such as descriptions for images and high-quality captions for audio or video. In the case of videos produced for cross-posting on multiple platforms, a best practice is to integrate captions into a video asset promptly after its production, so that the captions are done once and easily propagated across the platforms used. Note that if any such content is embedded on a University Website (such as embedding a YouTube video on a department’s website), then the Policy will apply to the content.

The benefits of captioning and transcribing digital content include:

  • Access for Individuals with hearing loss or impairments

  • Support for those for whom English is a second language

  • Enhanced searching and findability of multimedia content

  • Access for anyone in a noisy environment

  • Access for people with learning disabilities

A note about machine-generated captions: Videos and audio must be captioned upon upload to a University Website at an accuracy rate equal to that offered by a third-party vendor captioning service such as 3PlayMedia or Rev, and in a manner consistent with industry standards regarding synchronicity, completeness, and placement. While captions auto-generated by platforms like YouTube, IBM Watson, and Microsoft are improving, they are not sufficient to meet this standard and therefore are not recommended without additional procedures in place for verification and correction. High-quality captions include highly accurate transcription, proper punctuation, speaker identification, and the identification of sounds other than speech.

Audio captioning:

Audio segments and podcasts posted on University Websites and covered by the Policy must be accompanied by a full transcript. These transcripts either must be available on the same page as the audio player or linked directly to the transcript in the description text.

Because audio transcripts do not need to be time stamped or synchronized, they may be easier to generate than video captions. To enhance clarity and ensure access, speakers should be identified within these transcripts.

Live video captioning:

Harvard events that are live streamed through third party platforms are not subject to the Policy. However, events streamed on a third-party platform but embedded within a University Website would fall under the Policy.

The University live streams a wide range of content ranging from massive events such as Commencement to small activities within labs or departments. For live-streaming that is covered by the Policy:

  • University-wide events (such as Commencement, ceremonies for special honorands, and presidential installations) for which video and/or audio are live-streamed over the Internet must be live-captioned to industry standards.

  • For School-wide events or other larger events that are advertised and expected to generate substantial audiences, and for which video and/or audio are live-streamed over the Internet, the University strongly urges that industry-standard live captioning be provided as a matter of course.

  • For smaller events for which video and/or audio are live-streamed over the Internet, the University recommends in all cases that the hosting department offer in advance the opportunity for individuals with disabilities to request an accommodation. See the University’s captioning resource page for further instructions on how to obtain live captioning or CART services for a particular event.

In all cases where video of a live event is later posted to a Harvard website, such videos must be captioned as required by the Policy.


Policy and Procedures Terms and Phrases

The following descriptive and scenario-based guidance is provided to aid in the interpretation of certain terms and phrases within the Policy and this Implementation Procedure.

Note: Although this Section defines the digital content subject to the Policy’s requirements, the University strongly urges faculty, staff, and students to bring all digital materials into conformance with the Standards, wherever they reside. Among other reasons, Standards conformance — for example, video captions or transcriptions of audio — provides wide-ranging benefits to all users.

University Website

A “University Website” has four elements:

  1. It is a “website or web-based application;”

  2. It is “public-facing;”

  3. It resides “within a Harvard-controlled domain;”

  4. It is “used to conduct University Business by Harvard faculty or staff.”

To the extent that any digital material does not meet all four requirements, it is not a University Website subject to the requirements of the Policy.

NOTE: Although the policy refers to “websites,” it is the University’s intention that the Policy’s requirements apply at a more granular level, to any specific area, content, or page of a website that would itself meet the four elements of a University Website, even if the entire website does not. In such cases, only the areas, content, or pages that meet the elements of the definition are subject to the Policy.


  • A single department website has both public-facing pages and pages behind HarvardKey. The Policy’s requirements apply only to the public-facing pages.

Website & Web-Based Application (definitions from Oxford English Dictionary)

A website is a collection of related and linked web pages hosted under a single domain name, typically produced by a single person, organization, etc.; the notional “location” on the World Wide Web at which such a collection of web pages can be accessed.

A web-based application is a piece of software designed to perform a specific function other than one relating to the operation of the computer itself and that is accessed over a network connection using HTTP, rather than existing with a device’s memory. Web-based applications typically run inside a web browser.

Public Facing

The Policy only applies to websites or web-based applications that are public-facing. By “public-facing,” the University means sites that are:

  1. not subject to any access restrictions, such as login requirements, and

  2. located at URLs ascertainable by the general public, either through links from other public-facing pages or because they are indexed for search.


  • Content posted behind Harvard Key is not public-facing and not subject to the Policy.

  • Content posted on course websites made available only to enrolled or registered students is not subject to the Policy, even if members of the public are able to register for the course.

Harvard-Controlled Domain

The Policy only reaches websites and web applications “within a Harvard-controlled domain.” This is because Harvard cannot manage the coding infrastructure of a third party’s online platform and therefore cannot ensure that a third-party website conforms to the Standards. Likewise, Harvard is unable to eliminate barriers to accessibility or aspects of a third-party website that preclude users from posting content that conforms to the Standards. However, while this Policy does not bar faculty or staff from posting content to third-party platforms that do not conform to the Standards and are outside the University’s control, the University strongly urges all faculty, staff and students (1) to make accessible all digital content they create at the time it is produced; (2) to ensure that all content they post on third-party platforms is accessible; and (3) to post content only on accessible third-party platforms.

A “Harvard-controlled domain” includes domains registered to the University and domains that Harvard departments, laboratories, centers, and offices or members of the University community have registered in connection with University Business. Additional information can be found in the Use of Harvard Names and Insignias in Electronic Contexts policy, which is overseen by the Harvard Trademark Program. Domains registered by vendors on behalf of Harvard, to host web content posted by Harvard, are also Harvard-controlled domains.

Examples of Sites Within Harvard-Controlled Domains:

  • Any URL within the or domains is “within a Harvard-controlled domain.”

  • The director of a Harvard research center decides to move the center’s website outside of the subdomain assigned to her Harvard school. She registers a unique domain name for the center (“”); that domain name is Harvard-controlled, and web content posted within that domain is subject to the Policy.

  • A Harvard academic department contracts with a vendor for web hosting services. At the department’s request, the vendor registers a unique web domain for the department’s website (“”). Although neither Harvard itself nor any member of the Harvard community is the named registrant for the domain, the domain is Harvard-controlled.

Examples of Sites Outside Harvard-Controlled Domains:

  • Sites on domains registered by corporate affiliates of Harvard, such as the Harvard-affiliated hospitals, are not within Harvard-controlled domains.

  • Third-party platforms — such as YouTube, Facebook, and Twitter — are not “Harvard-controlled domains” under the Policy. However, if Harvard undertakes to embed content posted on a third-party platform on a webpage with a URL within a Harvard-controlled domain, then that content is considered to be posted within a Harvard-controlled domain, under the Policy.

University Business

The Policy defines “University Business” as “activities carried out under the auspices of Harvard University.” Accordingly, University Business includes:

  • work done by or at the direction of Harvard employees acting within the scope of their employment; and

  • work done by Harvard vendors acting within the scope of their engagement by Harvard.

As defined by the Policy, “University Business” does not include:

  • personal matters and personal business; or

  • activities organized or conducted by students or student organizations.


  • A Harvard professor who posts content online that describes a recently completed research project is engaged in “University Business.”

  • A Harvard graduate student working as a research assistant in a laboratory posts content on a website that relates to her work; this is considered “University Business.” The same graduate student’s online efforts to organize a kayaking trip are not “University Business.”

  • A Harvard employee with Harvard Key access creates a website on OpenScholar for colleagues who are interested in rock climbing and related meetups. The website is not “University Business.”

  • Harvard engages a vendor to produce videos that document events on campus. The vendor uploads those videos to a Harvard website. Although the vendor is not a Harvard employee, the videos are considered “University Business.”

New & Substantially Redesigned Website

An entirely new University Website launched on or after December 1, 2019 must conform to the Standards with respect to both its code/ infrastructure and its content. In addition, any existing University Website’s underlying code and infrastructure must conform to the Standards if the site is “substantially redesigned” after December 1, 2019. A site is “substantially redesigned” if it transitions to another hosting platform, is recoded from scratch, or meaningful changes are made to its design elements or overall structure.

Content that was posted on a University Website before December 1, 2019 and later moved to a new or substantially redesigned University Website is not subject to the Policy, though the University strongly urges Site Owners to make such content accessible.


  • A Harvard department contracts with an outside web developer to rebuild its website from scratch. The new code and content must conform to WCAG 2.1 AA.

  • The Libraries upgrade their website from Drupal 7 to Drupal 8 and apply a new visual design. The new code and content must conform, but content that was posted on the old website before December 1, 2019 is exempt.

  • A human resources office switches from one OpenScholar theme to another for its website. This does not mean that the website was “substantially redesigned.”

Content Created and Produced at Harvard and Posted on University Websites

The Policy’s requirement for accessibility of online content is as follows:

“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.”

Created and Produced at Harvard

These Procedures interpret the phrase “created and produced at Harvard” to describe content that Harvard faculty or staff conceived, authored or co-authored, and digitally generated, in connection with University Business. This is because Harvard may lack the practical means to ensure that content created and/or produced elsewhere conforms to the Standards. In addition, certain alterations of third party-authored content that Harvard might need to undertake to ensure conformance with the Standards could raise copyright issues.

However, the Policy’s use of the words “at Harvard” does not mean that the content must have been created and produced on Harvard’s campus. A research video created by a faculty member in the field and later posted on a University Website would fall within the Policy. Similarly, content created or produced by a vendor at the direction of Harvard faculty or staff is content “created or produced at Harvard.”

Conversely, content produced on Harvard property, but not by Harvard faculty or staff in connection with University Business, is not “created and produced at Harvard” for purposes of the Policy.


  • A Harvard researcher performing field work in South America blogs about her experiences on the project. Her blog posts are “created and produced at Harvard.”

  • A Harvard athletics team records digital video of an away game, for upload online. The recording is content “created and produced at Harvard.”

  • A Harvard communications office hires a production company to visit alumni at their places of work and shoot footage of interviews about their life at and after Harvard. The digital copy of this film is “created and produced at Harvard.”

  • A production company obtains permission to enter upon Harvard property to shoot a short film, which it uploads to the Internet as a digital file. This film is not “created and produced at Harvard.”

  • A Harvard website obtains a license from journal publishers to display Harvard-authored journal articles online, in .pdf files issued by the journals. Although the content in the articles may have been “created at Harvard,” the .pdf files were not “produced at Harvard” and so are not subject to the Policy’s content accessibility requirements.

  • A Harvard scholar gives a talk at another university, that university records the presentation and uploads it to the Internet, and the scholar’s department embeds the video on its web page. The content of the presentation may have been “created at Harvard,” but the video was not “produced at Harvard.”

Posted on a University Website

Content created and produced at Harvard, as described above, is subject to the Policy only if it is also “posted on” a University Website. Generally speaking, content posted only via user accounts on third-party platforms such as YouTube, Facebook, Tumblr, or WordPress is not “posted on a University Website,” except in cases where that content also appears within a Harvard-controlled domain. For example:

  • If a department embeds a YouTube video or SoundCloud audio file on a department web page, that video or audio is “posted on” that web page.

  • If a School uses the WordPress platform for its School-level website and locates the resulting web pages within the web domain, that content is “posted on” a University Website.

  • If a scholar uses Tumblr to host a website discussing his research and arranges for Tumblr to redirect associated Tumblr URLs to Tumblr hosted pages within a domain name registered by the scholar, the web content is “posted on” a University Website.

Last updated: Dec 1, 2019