Administrative Procedures for Website Accessibility

The School District of Philadelphia (“District”) is committed to making all of its website programs, benefits, and services fully accessible to all, including to individuals with disabilities. This commitment extends to accessibility to the District’s website. Our goal is to accommodate parents, students, patrons, employees, and all others members of the public by adopting and conforming to the World Wide Web Consortiums Content Accessibility Guidelines 2.0 Level AA and the Web Accessibility Initiative Accessible Rich Internet Applications Suite 1.0 for web content.

The District’s goal is to make its site useful to all patrons by adopting the four WCAG 2.0 principles: perceivable, operable, understandable, and robust.

1. Perceivable – Presenting our website and its information in a way that anyone can interact with it. In other words, making it accessible to begin with.
2. Operable – Making it so all required actions can be used by anybody.
3. Understandable – Ensuring that our content also makes sense.
4. Robust – Allowing access to our content via screen readers and other assistive technologies.

In the context of this policy, the following definitions apply:

• Accessibility – The degree to which the site is available to as many people as possible, including people with disabilities.
• Benchmark – The World Wide Web Consortiums (W3C) 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.
• Content Developer – The person, position, office or school that owns the content in question.
• Content Management System (CMS) – A content management system (CMS) is an application that allows users to create, edit and manage online content, including html pages, documents and images.
• Primary Domain – The District’s website domain, www.philasd.org.
• District Third Party Websites – Any website that is associated to the District, but is not using the philasd.org domain, and is controlled by a Content Developer who is authorized to do so by the Web Administrator.
• URL – URL stands for uniform resource locator – the unique address that identifies a page on the website.
• Website – Intranet or Internet

Web Administrator-The Chief of External Relations shall designate a Web Administrator who is responsible for maintaining and developing District websites under the primary domain. The Web Administrator is not responsible for maintaining third party websites. The Web Administrator ensures that web updates and developments are done in a timely manner and will ensure benchmarks are met using the W3C WCAG 2.0 Level AA and the WAI-ARIA 1.0 for web content for all District websites, this includes all approved District Third Party Websites. The Web Administrator will utilize a Department of Education approved auditor as well as training of Content Developers in order to ensure benchmarks are met on both the District websites and the approved District Third Party website content.

Content Developers– Content Developers are responsible for creating, maintaining and publishing content relevant to their office or school’s webpage or site. Content Developers are responsible for creating accessible content for all electronic documents using the W3C WCAG 2.0 Level AA and the WAI-ARIA 1.0 for web content as a benchmark. Content Developers shall be trained in the creating and publishing of accessible content prior to adding any new content to a District or School webpage or site or an approved District Third Party Website.

Video and Audio shall only be added to the website when a transcript is provided or the video has closed captions unless otherwise permitted under the applicable accessibility guidelines.

District web management is the responsibility of the Web Administrator in collaboration with Content Developers within the District. The District’s primary CMS will be used on all new websites unless the Web Administrator determines that the District’s CMS cannot fulfill or meet the required need. When a school or office believes that the District website cannot fulfill a required need, the school or office is required to obtain approval to use a third party website from the Web Administrator.  All requests to use a third party website must be emailed to webadmin@philasd.org. Third party websites that do not meet the required web content benchmarks will not be approved.

Quality Assurance – While the District strives to meet all accessibility benchmarks, inaccessibility issues may arise. To ensure that inaccessibility issues are reported and to facilitate prompt remediation, the District shall prominently post on its website a notice containing the procedure and contact information to provide feedback or report a concern.

When fundamental alteration or undue burden defenses apply, the District shall provide an equally effective alternate access to ensure that to the maximum extent possible, individuals with disabilities receive the same benefits or services as their nondisabled peers.

Grievance – Anyone who wishes to file a complaint alleging a failure to accommodate and/or discrimination on the basis of disability in the provision of website services, activities, programs, or benefits by the School District may use the grievance procedure established by the School District.

The complaint should be in writing and contain information about the alleged website accessibility discrimination. Specifically, the complaint must include:

1. the name, address, phone number of the complainant;
2. the URL address of the webpage against which the complaint is filed; and,
3. a statement of the problem.

Upon request, an alternative method for filing grievances such as personal interviews or a tape recording of the complaint will be made available for persons with disabilities.

The complaint should be submitted by the grievant and/or his/her designee as soon as possible, but no later than 60 calendar days after discovery of the alleged violation to:

ADA Website Compliance Administrator
School District of Philadelphia
Office of General Counsel
440 North Broad Street, Suite 313
Philadelphia, PA 19130
webcompliance@philasd.org

As may be appropriate in a given case, and within 48 hours after receipt of the complaint, the School District’s ADA Website Compliance Administrator will begin an investigation. As may be necessary, the ADA Website Compliance Administrator or the assigned liaison will meet with the complainant to discuss the complaint and the possible resolutions. The School District will provide for an adequate, reliable, and impartial investigation, including the opportunity to present witnesses and other evidence.

As a general process, within 45 calendar days from receipt of the complaint, the School District’s ADA Website Compliance Administrator or the liaison (whoever investigates the grievance) will respond in writing to the complainant; and, where necessary, in a format accessible to the complainant, such as large print, or audio tape. The response will explain the position of the School District and may include options for resolution of the complaint. The School District will also take steps to prevent recurrence and correct discriminatory effects on a complainant.

If the response by the School District’s ADA Website Compliance Administrator or liaison does not satisfactorily resolve the issue, the complainant and/or his/her designee may appeal the decision within 15 calendar days after receipt of the response to the ADA Website Compliance Administrator (contact information above).

If the School District’s ADA Website Compliance Administrator or liaison investigates and responds to the grievance appeal, and the response does not satisfactorily resolve the issue, the complainant and/or his/her designee may report the complaint to the U.S. Department of Education Office for Civil Rights.