Effective Date: August 30, 2019
Last Reviewed: August 30, 2019


Stonehill College is committed to providing equal and integrated access for community members and guests with disabilities to its academic, social, cultural and recreational programs. This includes ensuring that our website is accessible such that any site visitor can find, understand and use all the content there. All webpages within the Stonehill College external-facing website, subject to the exceptions enumerated in this Policy, must be made accessible to the widest number of users, including those with the more common sensory, motor, and cognitive disabilities.

This Policy sets forth the goals and methods for achieving our objective for equal access for all. Our goal is that all site visitors can navigate through, search and find relevant content (information about Stonehill’s programs, policies and events). Since we are creating an intentional Stonehill community we are committed to ensuring web content that is accessible to all members of that community.

Definitions

Americans with Disabilities Act (ADA): Law since 1990 that addresses the civil rights of People with Disabilities (PWD). The goal of the law is to ensure that PWD enjoy equal opportunities. Sections of the law address employment, purchasing of goods and services, and participation in all levels of government activities.

Information and Communication Technology (ICT): An umbrella term that refers to all internet- enabled devices and systems and additionally includes landline phones, smartphones, cloud computing, hardware, software and more. In the context of this Policy it refers to any electronic or digital resource that the College uses to pursue its goals of teaching, informing, and supporting electronically the students, staff and faculty.

Legacy Web pages: All webpages located on www.stonehill.edu before the date of this Policy.

Person or People with a Disability (PWD): An individual or a group of people who have one or more physical or mental impairments that substantially limit one or two major life activities. Sometimes the term Individual with Disabilities (IWD) is used.

Section 508: Part of the U.S. Federal Government Rehabilitation Act of 1973 and recently updated in January 2018. The Act sets expectations of which standards must be adhered to when creating and purchasing ICT for Federal agencies. The law applies to federal agencies, but its guidelines should be followed by all websites.

WCAG 2.0 Level A & AA: Technical standards for web content developed by the W3C working group.

Stonehill College Main Website – The Stonehill website which is the central location for current and prospective students to learn about Stonehill College offerings, classes, events, and links to other resources the College promotes and regulates.

Responsible Office

Primary: Marketing

Secondary: Office of Accessibility Resources

Tertiary: Joint oversight by the Office of the General Counsel and Information Technology

Complaints

For complaints related to Section 504 of the Rehabilitation Act of 1973 and/or the Americans with Disabilities Act or to file a formal grievance, please contact:

Thomas V. Flynn

Stonehill College

Office of the General Counsel

320 Washington Street

Easton, MA 02357

(508) 565-1404

This email address is being protected from spambots. You need JavaScript enabled to view it.

OR contact the U.S. Department of Education - Office for Civil Rights Regional Director

Office of Civil Rights

U.S. Department of Education

5 Post Office Square

Boston, MA 02109

(617) 289-0111

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Members of the Stonehill College community who encounter inaccessible web technology at the College should notify This email address is being protected from spambots. You need JavaScript enabled to view it. for assistance. This email address shall be posted on the website and in any other places deemed useful, such as in the Office of Accessibility Resources and via social media as the responsible departments deem acceptable. Messages delivered to this email address will be accessed by a small group of designated accessibility professionals within Stonehill. A “Core Oversight Team” consisting of the Director of Marketing, Director of Accessibility Resources, and the Chief Information Officer (or designee) shall create and maintain procedures for the evaluation and resolution of matters received at this email address, including expected response time and manner of reply. This information shall be provided through an automated email response or be posted on the website.

Recommended Review Frequency

The College shall review the overall accessibility of its website annually, unless there are compelling reasons to do so more frequently.

Who is governed by this Policy?

Staff, faculty, student employees, and consultants who contribute to the http://stonehill.edu website. Contributors will be monitored by the Marketing Department. Third-party vendors who create content for Stonehill’s public website shall be required to make content accessible. Members of the Core Oversight Team and additional staff as needed, in consultation with the Accessibility Resources Committee, will supplement monitoring of the site and answering any questions or issues that may arise.

All web content providers of the Stonehill College Core Site will be expected to produce code that conforms to the WCAG Level 2.0 A & AA guidelines or the most current equivalent set of guidelines. All content linked to the Stonehill College main website are subject to accessibility audit, review and remediation. This will be conducted in an orderly manner, and they will be prioritized and updated as resources permit.

All staff and faculty who contribute content to the Stonehill College core site, as well as staff in the Information Technology Department, Office of Accessibility Resources, and the Library must receive accessibility training.

General users of the Stonehill College Core Site should have this Policy available to them via a link to a page where it will be posted. This should include information on how to contact the responsible group within Stonehill College so that any issues can be reported and fixed.

Exclusions

Sub-sites or third-party sites the College relies on that are very difficult to remediate are excluded from this Policy. However, the College will undertake the long-term goal of replacing, re-writing, or purchasing more accessible sites. If necessary, the College will retire nonconforming sub-sites as conforming sites become available.

Legacy sites will be identified and edited, removed, or updated in an ongoing manner.

The Accessibility Resources Committee is charged with educating the College community about the importance of building accessibility and inclusion into the cross-campus Stonehill experience. The Committee may undertake accessibility audits and reviews of Stonehill websites, advise in the creation of procurement guidelines that will result in the most favorable accessibility outcomes of ICT purchases and training about steps that will support the Accessibility Policy.

Remediation

The Core Oversight Team will create and maintain procedures for remediating web accessibility issues and concerns in a timely manner.

Procurement

Stonehill College requires vendors who develop and/or maintain Stonehill College websites, web- based applications and electronic information technology (EIT) to demonstrate that their products meet accessibility standards to the extent practicable. Vendors shall provide the results of accessibility testing or a description of the steps they are taking to bring their content into alignment with accessibility standards. Stonehill College groups working with outside vendors will need to include the web accessibility requirements within their Request for Proposal (RFP) or Scope of Work (SOW) documents.

Language to include in RFPs:

“Please confirm in this proposal that the product/service conforms to the Web Content Accessibility Guidelines (WCAG) 2.0 (minimum Level AA conformance) or its current equivalent, and describe how this compliance has been verified by providing a Voluntary Product Accessibility Template (VPAT) and/or written description of compatibility of the product/service with commonly used assistive technology products, such as screen readers, and a description of the process used to evaluate such compatibility.”

Language to include in SOWs:

“This product/service conforms to the guidelines for accessibility as set forth in the Web Content Accessibility Guidelines (WCAG) 2.0 (minimum Level AA conformance) or its current equivalent. This compliance has been verified by the written description of compatibility of the product/service with commonly used assistive technology products, such screen readers, and by an end-user test process used to evaluate such compatibility.”

Other procurement:

For some projects, there really are no good options which are fully compliant. This would typically be the case for complex web applications, as opposed to more simple, content-driven websites and EIT. Here is more nuanced language which may be useful in these cases:

“Please include in any proposal that the product/service conforms to the guidelines for accessibility as set forth in Web Content Accessibility Guidelines (WCAG) 2.0 (minimum Level AA conformance) or its current equivalent. If the product/service is not in compliance, please describe plans and a timeframe for achieving compliance by providing a VPAT and/or written description of compatibility of the product/service with commonly used assistive technology products, such as screen readers, and a description of the process used to evaluate such compatibility. It is expected that a Stonehill College vendor will promptly respond to and resolve any complaint regarding the accessibility of its platform.”

The SOW should then include language requiring the vendor to fulfill all commitments made in the RFP response. This language will vary based on the vendor's ability to meet the guidelines. Open-source/free EIT.

In this case, there may not be a VPAT, statement of compliance, or a person to contact regarding the accessibility of the software. It is the responsibility of the person who uses this product to test its compliance with Stonehill College’s Guidelines.