7540.02 - DIGITAL CONTENT AND ACCESSIBILITY
- Creating Digital Content
The Board authorizes staff members and students to create content for the District's website and District-approved/affiliated apps and services (see Bylaw 0100 - Definitions) ("digital content").
District-generated and school-related digital content must comply with applicable State and Federal laws (e.g., copyright laws, Children's Internet Protection Act (CIPA), Section 504 of the Rehabilitation Act of 1973 (Section 504), Americans with Disabilities Act (ADA), Student Online Personal Protection Act (SOPPA), and Children's Online Privacy Protection Act (COPPA)) and reflect the professional image/brand of the District, its employees, and students. District-generated digital content must be consistent with the Board's Mission Statement and is subject to prior review and approval of the District Administrator before being published on the District's website or District-approved/affiliated apps/services.
School-related student-created content for the Board's website or District-approved/affiliated apps/services are subject to Policy 5722 - School-Sponsored Publications and Productions.
Creation of school-related content by students for the Board's website or District-approved/affiliated apps/services must be done under the supervision of a District staff member.
- Purpose of Digital Content
The purpose of digital content covered by this policy is to educate, inform, and communicate. The following criteria shall guide the development of District-generated digital content:
- Educate
Digital content should be suitable for and usable by students and teachers to support the curriculum and the Board's Objectives as listed in the Board's Strategic Plan. - Inform
Digital content may inform the community about the school, teachers, students, or departments, including information about curriculum, events, class projects, student activities, and departmental policies. - Communicate
Digital content may communicate information about the plans, policies, and operations of the District to members of the public and other persons who may be interested in and/or affected by District matters.
- Educate
The information published on the Board's website and District-approved/affiliated apps/services should reflect and support the Board's Mission Statement, Educational Philosophy, and School Improvement Process.
When the digital content includes a photograph or personally identifiable information relating to a student, the Board will abide by the provisions of Policy 8330 - Student Records.
Under no circumstances is District-generated digital content to be used for commercial purposes, advertising, political lobbying, or to provide financial gains for any individual. Included in this prohibition is the fact that no digital content published on the District’s website or District-approved/affiliated apps/services may:
- include statements or other items that support or oppose a candidate for public office, the investigation, prosecution, or recall of a public official, or passage of a tax levy or bond issue;
- link to a website of another organization if the other website includes such a message; or
- communicate information that supports or opposes any labor organization or any action by, on behalf of, or against any labor organization.
Under no circumstances shall a staff member post on their personal web pages/websites or private digital accounts (i.e., non-District-approved/affiliated apps/services) student progress reports, grades, class assignments, or any other similar class-related material. Employees are required to use the Board's website or District-approved/affiliated apps/services (e.g., Infinite Campus) for the purpose of conveying information to students and/or parents.
Staff members are prohibited from requiring students to go to the staff member's personal web pages/websites and/or private digital accounts (i.e., non-District-approved/affiliated apps/services) (including, but not limited to, the staff member's personal accounts on Facebook, Instagram, Pinterest, YouTube Channel(s), or TikTok sites) to check grades, obtain class assignments and/or class-related materials, and/or to turn in assignments.
If a staff member creates digital content related to their class, it must be hosted on the Board's website or a District-approved app/service.
The Board’s website, including school-specific websites, shall be generally open/available to the public unless specific digital content is unique to a specific child and/or includes student personally identifiable information, in which case the information must be password-protected or access to it must be otherwise restricted. When digital content involving student personally identifiable information or information concerning coursework, particularly a specific student’s classes/assignments, is password-protected/access is otherwise restricted, the student’s parent(s)/guardian(s) will continue to have access to that digital content.
Digital content published on the Board's website should reflect an understanding that both internal and external audiences will be viewing the information.
The Board retains all proprietary rights related to the design of and content for its website(s) and any apps/services it operates and/or is affiliated with, absent written agreement to the contrary.
In order for a student's school work (i.e., work that is created in or for a class or as part of a school-sponsored extracurricular activity) to be displayed on the Board's website, the student (who is eighteen (18) years of age or older) or the student's parent (if the student is seventeen (17) years of age or younger) must provide written permission and expressly license its display without cost to the Board.
Likewise, prior written permission from a student (who is eighteen (18) years of age or older) or the student's parent (if the student is seventeen (17) years of age or younger) is necessary for a student to be identified by name on the Board's website.
- Accessibility of Web Content and Mobile Apps
The District is committed to providing persons with disabilities an opportunity equal to that of persons without disabilities to participate in the District’s programs, benefits, and services, including those delivered through electronic and information technology, except where doing so would impose an undue burden or create a fundamental alteration. The District is further committed to ensuring persons with disabilities are able to acquire the same information, engage in the same interactions, and enjoy the same benefits and services within the same timeframe as persons without a disability, with substantially equivalent ease of use; that they are not excluded from participation in, denied the benefits of, or otherwise subjected to discrimination in any District programs, services, and activities delivered online through the web or a mobile app, as required by Section 504 and Title II of the ADA and their implementing regulations; and that they receive effective communication of the District’s programs, services, and activities delivered in-person or online.
This policy reflects the Board's commitment and intention to comply with the requirements of Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. Section 794, 34 C.F.R. Part 104, Title II of the Americans With Disabilities Act of 1990, 42 U.S.C. Section 12131, and 28 C.F.R. Part 35 in all respects. For purposes of this policy, “web content” means the “information and sensory experience to be communicated to the user by means of a user agent, including code or markup that defines the content’s structure, presentation, and interactions.” Examples of web content include text, images, sounds, videos, controls, animations, and conventional electronic documents (e.g., web content or content in mobile apps in the following electronic file formats: portable document formats (PDF), word processor file formats, presentation file formats, and spreadsheet file formats). Additionally, “mobile applications" (“mobile apps”) means “software applications that are downloaded and designed to run on mobile devices, such as smartphones and tablets.”
- Technical Standards
Web content and mobile apps that the District provides and/or makes available, directly or through contractual, licensing or other arrangements, shall comply with the World Wide Web Consortium’s Web Content Accessibility Guidelines (WCAG) 2.1, Level AA standards, unless the Board can demonstrate that such compliance would result in a fundamental alteration in the nature of its programs, services, or activities, or an undue financial and administrative burden.
Notwithstanding the preceding, Federal regulations provide for the following content types to have limited exceptions to the WCAG 2.1, Level AA requirements:
archived web content (provided all four (4) Federal criteria in 28 C.F.R. 35.104 are met);
certain preexisting conventional electronic documents (with specific restrictions);
third party content that is not created pursuant to a contract, license, or other arrangement between the Board and a third party;
password-protected or otherwise secured documents pertaining to a specific student, their property, or their account; and
preexisting social media posts.
Even when the preceding exceptions apply, the District, however, will still provide effective communication and reasonable modifications in accordance with the ADA.
Content maintained for any purpose other than reference, research, or recordkeeping does not qualify as one of the listed exceptions above, regardless of the date it was created. If the content is labeled "archived" or stored in an area clearly identified as being "archived" it still has not risen to the level required to fall into an exception.
When a person with a disability cannot access District-generated or -affiliated web content or mobile apps that meet WCAG 2.1, Level AA standards, the District will: (1) provide alternate means of access to the same information and functionality; (2) make reasonable modifications to policies, practices, or procedures; (3) ensure effective communication through appropriate auxiliary aids and services; and (4) respond to accommodation requests. Such accommodations may include: (a) alternative document formats (large print, Braille, audio); (b) telephone or in-person assistance for online services; and/or (c) email or mail delivery of information typically accessed online.
- Digital Accessibility Coordinator
The Board designates its Technology Director as the District's Digital Accessibility Coordinator(s). That individual is responsible for coordinating and implementing this policy.
The District’s Digital Accessibility Coordinator(s) can be reached at Pardeeville Area School District- District Office, 120 Oak Street, Pardeeville, WI, 53954, (608) 429-2153 - Third Party Content
Links included on the Board’s website(s) and District-approved/affiliated mobile apps that pertain to its programs, activities, and/or services must also meet the above criteria and comply with State and Federal law (e.g. copyright laws, CIPA, Section 504, ADA, SOPPA, and COPPA). The District's Digital Accessibility Coordinator(s) or designee(s) will vet online content available on the Board’s website and through District-approved/affiliated mobile apps that are related to the District’s programs, activities, and/or services for compliance with this criteria for all new content published on the District's website and mobile apps after adoption of this policy.
Content posted by third parties (e.g., members of the public) on District platforms is exempt from the WCAG 2.1, Level AA requirements unless the third party is posting due to contractual, licensing, or other arrangements with the District. Those platforms, however, along with content posted by the District staff or contractors, must be fully compliant.
Additionally, nothing herein shall prevent the District from including links on its website(s) and apps/services to:
- recognized news/media outlets (e.g., local newspapers' websites, local television stations' websites), or
- websites, services, and/or apps that are developed and hosted by outside vendors or organizations that are not part of the District’s program, benefits, or services.
The Board recognizes that such third party websites must contain age-appropriate advertisements that are consistent with the requirements of Policy 9700.01, AG 9700B, and State and Federal law.
- Regular Audits
The District will, under the direction of the Digital Accessibility Coordinator(s) or designee(s), at regular intervals, audit the District's digital content to ensure it meets the required technical standards.
This audit will occur at least annually, with quarterly monitoring of high-priority content and newly published materials.
If problems are identified through the audit, such problems will be documented, evaluated, and if necessary, remediated within a reasonable period.
- Reporting Concerns or Possible Violations
If a person accessing the District's web content and/or District-approved/affiliated mobile apps (e.g., a student, prospective student, employee, guest, or visitor) ("user") believes that specific web content and/or a mobile app has violated the WCAG 2.1, Level AA standards, the user may contact the Digital Accessibility Coordinator with any accessibility concerns. The user may also file a formal complaint utilizing the procedures set out in Board Policy 2260.01 relating to Section 504 and Title II.
- Instructional Use of Apps/Services
A teacher who elects to supplement and enhance student learning through the use of apps/services is responsible for verifying/certifying to the District Administrator that the app/service has a FERPA‑compliant privacy policy, and it complies with all requirements of the COPPA, CIPA, and Section 504/ADA, including the WCAG 2.1, Level AA accessibility standards.
The Board further requires the use of a Board-issued e-mail address in the login process for District-approved/affiliated apps/services.
- Training
The District will provide periodic training for its employees who 1) create web content, documents, or multimedia materials, 2) manage the Board's website and digital services, 3) select and contract with technology vendors, and 4) work on online communications.
The training should cover this Policy and responsibilities associated with the specified staff members’ roles related to the implementation of this policy and ensuring the District’s digital content is appropriate and accessible.
Such training shall be facilitated by qualified individuals with demonstrated knowledge, skill, and experience concerning the accessibility standards and ADA compliance.
- One-Way Communication Using the District Website and/or District-Approved/Affiliated Apps/Services
The Board approves the use of its website and District-approved/affiliated apps/services to promote school activities and inform stakeholders and the general public about District news and operations.
Included in this approval is the use of Short Message Service (SMS) texting for official District communications. The District SMS service will include:
- Consent and Privacy for SMS Communication
The District is committed to protecting the privacy of all recipients. The following terms govern the use of SMS communication:
- Explicit Consent (Opt-in): The District shall obtain explicit, verifiable permission (opt-in) before sending any SMS texts to students,parents, staff, or community members.
- Data Sharing: Information obtained as part of the SMS consent process will not be shared, sold, or rented to third parties.
- Data Collection: The District will not collect or save personal data or information from its SMS users beyond what is strictly necessary to maintain the opt-in list.
- Confidentiality: No confidential or personally identifiablestudent/staff information will be exchanged through SMS text messaging.
- Types of SMS Communications
If an individual has consented to receive school-related text messages from the District, they may receive messages related to:
- Emergencies and Cancellations
- General Reminders (e.g., deadlines, schedule changes)
- District and School Events
- Attendance Notifications
- Transportation Updates
- Meal Balance Reminders
- Standard Messaging Disclosures
Message and data rates may apply. Message frequency may vary.
- Consent and Privacy for SMS Communication
Such communications constitute public records that will be archived.
When the Board or District Administrator designates communications distributed via the District's website and/or District-approved/affiliated apps/services to be one-way communication, public comments are not solicited or desired, and the website or app/service is to be considered a nonpublic forum.
If the District uses an app/service that does not allow the District to block or deactivate public comments, the District’s use of that app/service will be subject to Policy 7544 – Use of Social Media unless the District is able to automatically withhold all public comments.
If unsolicited public comments can be automatically withheld, the District will retain the comments in accordance with its adopted record retention schedule (see AG 8310A – Public Records, and AG 8305 - Collection, Classification, Retention, Access and Security of District Data/Information), but it will not review or consider those comments.
Revised 12/7/15
Revised 3/6/17
Revised 4/19/21
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