HMC Policy on Electronic and Information Technology Accessibility
This policy sets forth standards that Harvey Mudd College (“College”) has adopted in connection with its ongoing effort to make the content of its website and web-based programs accessible to persons with disabilities in a manner that is consistent with applicable local, state and federal laws.
The requirements set forth in this policy apply to:
- All College offices and all staff, faculty and students who administer, manage and maintain websites or electronic resources to conduct College business.
- All software procured by the College or its agents.
- Third parties acting as agents of the College in the activities described above.
Harvey Mudd College is fully committed to ensuring that its websites and web-based programs are accessible to all users, including persons with disabilities.
Benchmarks for Measuring Accessibility
For purposes of this policy the accessibility of online content and functionality will be measured according to 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) 1.0 for web content.
All electronic resources should bear a notice to persons with disabilities regarding how to request that the webmaster or other appropriate person provide access to (or notify the College regarding) online information or functionality that is currently inaccessible. For the approved College notice, see Appendix C.
New Electronic Resources
New electronic resources are those that are newly created, substantially revised or repurposed (e.g. for a new offering of a course) on or after July 1, 2017. All new electronic resources will be made accessible in accordance with this policy.
Legacy Electronic Resources
Legacy electronic resources are those that were created before July 1, 2017, or that are more than two years old, or that are no longer in use but are being retained pursuant to the College’s document retention policy. Where possible, legacy resources should be made accessible, or strong consideration should be given to their removal.
Upon specific request, information in legacy electronic resources is to be made available to any individual needing access to such content, by revision or otherwise.
Prioritization of Efforts
Priority should be given to creating accessible web pages and resources for core institutional information such as admission, catalogs, student services, registration, course work and advising information. Units with large web sites and resources containing core institutional information should establish priorities for ensuring access to these according to the pages and resources being used or requested most often. See Appendix D for further guidance about prioritization.
Training and Resources
The College will establish annual training programs for all electronic content editors. The CIS Educational Technology Services unit will provide consultation to faculty, staff and students regarding the use of specific software tools. The Office of Communications and Marketing will provide guidance to content editors responsible for developing content for the main College website at www.hmc.edu. See Appendix A for more information about training, consulting and technological tools.
The College will conduct at least quarterly automated scans of its websites in order to identify materials that are not yet accessible. After appropriate prioritization of the results, the Accessibility Task Force will assist departments and individuals that are owners of the inaccessible content in order to make the content accessible or to remove or archive it.
College departments should take appropriate steps to ensure they invest in technologies that are accessible to individuals with disabilities and should when possible avoid procuring products that do not meet the benchmarks for measuring accessibility.
Exclusions and Special Circumstances
Conformance to standards may not always be feasible due to the nature of the content, the purpose of the resource, the lack of accessible solutions, or an unreasonably high administrative or financial cost necessary to make the resource accessible. However, these difficulties do not relieve College programs or services from their accessibility obligations. Managers of programs and services must be prepared to provide content and/or services in a suitable alternative format (e.g., electronic text file or audio description) upon request and in a timely manner.
Narrowly tailored exceptions to this policy may be granted by the chief communications officer in consultation with the chief information officer (CIO), the Title IX coordina.tor and Section 504 coordinator for students, and director for human resources and Section 504 coordinator for staff and faculty. To make a request when compliance is not possible or would constitute an undue administrative or financial burden, please complete the form found on the Disabilities Resources page.
Students, faculty or staff who create personal web pages that are hosted by the College, but which do not conduct College related business, are encouraged to adopt the accessibility standards. However, such pages fall outside the jurisdiction of this policy.
If you have questions about how to ensure that electronic resources meet the requirements or you have concerns about adherence to this policy, please contact either a member of the president’s cabinet, the chief communications officer, or the CIS Help Desk at 909.607.7777 or email@example.com.
Approved by: HMC President’s Cabinet
Approved on: October 26, 2016
Effective on: Pending OCR Approval
Related Policies: HMC Information and Records Management Policy
|Policy||Annual (as needed)|
|Appendix A, Resources and Contact Information||Annual|
|Appendix B, Laws and Regulatory Environment||As needed|
|Appendix C, Website Accessibility Notice||As needed|
|Appendix D, Prioritization||As needed|
|Appendix E, Grievance Procedures||As needed|
<mm/dd/yyyy: Approved by; Short description of action>
Appendix A. Resources and contact Information
The CIS Educational Technology Services group can provide the following services:
- Consulting to faculty and staff regarding the use of specific tools recommended by ETS
- Consulting on instructional design
- Consulting regarding the Claremont Colleges Learning Management System, Sakai
The Office of Communications and Marketing can provide the following services:
- Account creation and training for content editors using WordPress for the main www.hmc.edu site.
- Automated scanning of websites to provide reports on compliance
Appendix B: Laws and Regulatory Environment
Title III of the Americans with Disabilities Act of 1990, as amended, 42 U.S.C. § 12181 et. seq.
Section 504 of the Rehabilitation Act of 1973, as amended, 29 U.S.C. § 794.
California Government Code, section 11135.
Appendix C: Website Accessibility Notice (for all HMC sites)
It is the goal of Harvey Mudd College that the information on its website is accessible to individuals with disabilities, and to that end we are in the process of redesigning our website in accordance with the requirements of Section 504 of the Rehabilitation Act of 1973 and Title III of the Americans with Disabilities Act of 1990.
If you have difficulty accessing information on our website due to a disability, please contact the Office of Communications and Marketing by emailing firstname.lastname@example.org or calling 909.607.9298 and provide the URL (web address) of the material you tried to access, the problem you experienced and your contact information. Be sure to include your name, email address and phone number so that we may contact you to provide the information in another format.
Inquiries concerning our Section 504 complaint procedures may be directed to:
For Faculty, Staff and All Others
Appendix D: Prioritization
The College recognizes that it is not possible to immediately make all content accessible. The Accessibility Task Force recommends the following prioritization steps:
- All new and significantly revised web pages should be made accessible at the time of creation or revision.
- The top 20 percent of existing web pages and resources most frequently used (e.g. that get the largest number of hits) should be placed in the first priority for review, and made accessible as indicated.
- Pages and resources required for participation, funding, disability related services and other key information or functions needed by people with disabilities, not already in the top 20 percent, should also be placed in the first priority. Each department or College entity is responsible for determining the top 20 percent used and other first priority web pages and resources.
- Any remaining pages and resources providing core institutional information or functions should be reviewed, and made accessible.
- All other web pages and resources should be reviewed, and made accessible as indicated.
Appendix E: Harvey Mudd College Disability Grievance Policy and Procedure
Harvey Mudd College has adopted an internal grievance procedure for prompt and equitable resolution of complaints alleging any action prohibited by federal regulations implementing Section 504 of the Rehabilitation Act of 1973, as amended, Title III of the Americans with Disabilities Act of 1990 (ADA), and similar state laws. These laws provide that no otherwise qualified individual with a disability shall, by reason of such disability, be excluded from participation in or be denied the benefits of the services, programs, or activities of the College, or be subjected to discrimination by the College.
Issues that are grievable include, but are not limited to, a denial of a requested accommodation, the inadequacy of an accommodation, the inaccessibility of a program, benefit, service or activity (including those delivered through electronic and information technology) due to disability, or discrimination or harassment based on disability .
All such grievances should be addressed to the attention of:
For Faculty, Staff and All Others
For the purposes of this policy the individuals referenced above are referred to as Co-Section 504/ADA Coordinators. The following steps explain the procedure:
- The grievance should be submitted in writing or provided orally and include the grievant’s name and contact information, a clear and concise description of the problem which is the basis for the grievance (including relevant facts, any steps taken to resolve the problem, the names of and contact information for persons who may have relevant information concerning the grievance), and a statement of the remedy requested.
- A grievance must be filed within ninety (90) days after the grievant becomes aware of the alleged problem. Grievances received later than ninety (90) days after the grievant became aware of the alleged problem will be dismissed as untimely, unless exceptional circumstances prevented timely filing.
- An investigation, as may be appropriate, will follow the filing of a grievance. The investigation shall be conducted by one of the College’s Co-Section 504/ADA Coordinators, or other designee (“grievance officer”). These procedures contemplate a prompt and informal, but thorough investigation which afford the grievant, the party against whom the grievance or the proposed disposition is directed, and their representatives, if any, an opportunity to submit documents and information relevant to the consideration of and resolution of the grievance.
- A written determination as to the validity of the grievance and a description of the resolution, if any, shall be issued by the grievance officer and a copy forwarded to the grievant and the party against whom the grievance or the proposed disposition is directed no later than thirty (30) days after receipt of the grievance.
- The disposition proposed by the grievance officer will be put into effect promptly. The grievant or the party against whom the grievance or the proposed disposition is directed may appeal. An appeal will not suspend the implementation of the disposition proposed by the grievance officer, except in those circumstances where the appeal officer decides that good cause exists making the suspension of implementation appropriate.
- Within fifteen (15) business days of the receipt of the grievance officer’s determination, the grievant or the party against whom the grievance or the proposed disposition is directed may appeal the grievance officer’s determination. The appeal, which must be in writing, should state the reasons why the person believes the determination should be changed and state the change(s) sought. All appeals are to be submitted to the grievance officer who will direct the appeal and all appropriate records to the appropriate appeal officer (e.g., Vice President for Student Affairs and Dean of Students, Vice President for Academic Affairs and Dean of the Faculty or Vice President for Administration and Finance/Treasurer depending on the circumstances and issues involved) for review and disposition. A copy of the appeal officer’s written decision will be expected within 30 days of the filing of the appeal and will be sent to the parties, the grievance officer and appropriate College administrators.
- Whenever the application of any of the time deadlines or procedures set forth in this grievance procedure creates a problem due to the nature of the grievance, the urgency of the matter, or other circumstances (including for reasons relating to breaks in the academic calendar), the grievance or appeal officer will determine whether an appropriate expedited procedure can be fashioned or extensions of time are warranted, and the parties shall be advised.
- The College’s Co-Section 504/ADA Coordinators shall maintain the files and records relating to grievances filed.
- The availability and use of this grievance procedure does not prevent a person from pursuing other available remedies, including filing a complaint of discrimination on the basis of disability with a federal or state agency such as the United States Department of Education, Office of Civil Rights (50 United Nations Plaza, San Francisco, CA 94102, Telephone: 415.486.5555, TDD: 800.877.8339; Email: email@example.com), or pursuing a private right of action. Please note that these alternate avenues for relief may have separate time limits that may or may not be affected by using this grievance procedure.
- Retaliation against anyone who files a grievance or cooperates in the investigation under this grievance procedure is against the law and prohibited. Any concerns about retaliation related to this process should be disclosed immediately to one of the College’s Co-Section 504/ADA Coordinators.
Inquiries concerning HMC’s disability accommodation and discrimination policies, compliance with applicable laws, statutes and regulations (such as Section 504 and the ADA), and this grievance procedure (including requests for any accommodations needed to use this procedure) should be directed to one of the College’s Co-Section 504/ADA Coordinators identified above.