American with Disabilities Act (ADA) Website Policy
The bank aspires to ensure equally effective access to its websites, www.bradfordbank.com, www.bnblending.com, www.bradfordagservices.com, and bradfordnational.bank in accordance with Title II of the Americans with Disabilities Act (ADA), the Rehabilitations Act of 1973, and the Department of Justice web accessibility directives regarding individuals with disabilities. The bank recognizes that its many beneficial services provided to its customers are also critically important and beneficial to customers with disabilities. Therefore, this policy addresses the need for the websites, www.bradfordbank.com, www.bnblending.com, www.bradfordagservices.com, and bradfordnational.bank to be accessible to this significant set of customers. The bank seeks to create this accessibility without making it unreasonable difficult to do so.
To these ends we have established this American Disabilities Act Website Accessibility Accommodations Policy as approved by the Board of Directors on March 8, 2017.
ADA WEBSITE ACCESSIBILITY ACCOMMODATIONS POLICY STATEMENT
The bank is committed to the principles of the Americans with Disabilities Act. It respects and values the business of all its customers regardless of ability or access method. As such it is our policy to provide equal access for individuals with disabilities, which includes our websites, www.bradfordbank.com, www.bnblending.com, www.bradfordagservices.com, and bradfordnational.bank. We will take all necessary steps to make our website accessible and accommodating. To that end, the bank will conform its website to the World Wide Web Consortium (W3C) Web Accessibility Initiative’s (WAI) Web Content Accessibility Guideline (WCAG) 2.0, Level AA and the United States Access Board’s Section 508 Standards.
APPLICATION OF THE ADA WEBSITE ACCESSIBILITY ACCOMMODATIONS POLICY
The application of our ADA website accessibility accommodations policy (“Policy”) is to be apparent throughout the organization. This will show itself in our plans, practices and procedures.
More specifically, this means we will:
- Designate one or more individuals to manage the website’s accessibility testing, repairing, implementing, maintaining and reporting
- Ensure that our website content editors, whether in-house or third-party, will be trained in and understand the functions of web accessibility tools and techniques
- Make use of the industry-standard techniques and preferred practices to provide the highest possible level of ADA website accessibility accommodations for our users, including but not limited to the characteristics of usability for screen readers, keyboard only users with low/impaired vision, users who are deaf and users who are color blind
- Regularly run compliance scans of our website using software tools to detect WCAG 2.0 and Section 508 violations
- Require that any services procured and performed by third-party developers and other relevant service providers conform to our prevailing WCAG 2.0 Level AA and Section 508 compliant accessibility accommodations standards and this policy
- Periodically conduct an internal audit in which we will require a manual examination of the website and the incorporation of user tests by qualified professionals and ideally by individuals with disabilities
- Implement other related policy, technology and programming, monitoring and training measures as they are identified and needed
- Establish and maintain a formal complaint process for any individual who has complaints, comments and suggestions regarding the website
ROLES AND RESPONSIBILITIES
In order to fulfill each of these applications immediately above, the bank’s executive management in consultation with the bank’s board has assigned the following roles and responsibilities with regard to this policy.
Board Audit Committee
The bank’s board audit committee will serve as the board-level oversight committee for this policy. It will:
- Ensure the bank and the bank’s executive management are complying with this policy
- Serve as the communication conduit between the board and the bank’s executive management on matters associated with this policy
- Regularly review this policy including any amendments and changes to this policy
- Recommend appropriate actions related to this policy to the bank’s board
Bank Executive Management
- Designate authority and direct actions by bank’s respective departments, committees and employees to implement this policy
- Review the work of the committee assigned to implementing this policy on a regular basis
- Set policy including amendments and changes to this policy and recommend to the bank’s board audit committee
- Make final authoritative interpretations of this policy
- Engage and retain subject matter experts on ADA website accessibility accommodations as needed
- Assign at least one executive member to the Bank Internal Committee and if more than one member designate which member will chair the committee
Bank Internal Committee
The bank’s internal committee will have frontline responsibility for implementing this policy and for reporting such efforts on a regular basis to the bank’s executive management. It will comprise of Randy Alderman, Cathy Eyman, Jace Keaster, Mike Ennen, Doug Stroud. To that end it will:
- Manage and review authorities and actions directed by the bank executive management
- Set bank-wide standards and procedures for following WCAG 2.0 Level AA guidelines and Section 508 standards, including by not limited to training, internal audits and testing, evaluation and complaints processing and reporting
- Establish processes and procedures to ensure the bank complies with this policy
- Make interim interpretations of this policy and resolve internal discrepancies that might arise in the bank
- Recommend best practice and shared services
- Ensure employees under its charge to implement this policy are well trained and informed about ADA, WCAG 2.0 and Section 508
ADA Website Accessibility Accommodations Officer
This employee will have direct responsibility for ensuring the bank’s website complies with this policy. The employee should have officer-level status in the bank and be a member of the bank internal committee. This officer will:
- Have responsibility and accountability for the website’s compliance to ADA, WCAG 2.0 Level AA and Section 508 and for implementing this policy
- Manage staff and resources assigned to support the website and implement this policy
- Support the development, issuance, maintenance and oversight of the procedures supporting this policy
- Develop and monitor testing strategies to measure the website’s compliance to this policy
- Ensures that the bank implements and maintains the training and education of employees with respect to this policy, ADA, WCAG 2.0, Section 508 and related directives by the DOL
- Recommend and recruit the necessary staff, including the ADA Website Accessibility Accommodations Coordinator, to the Bank Internal Committee and Bank Executive Management
ADA Website Accessibility Accommodations Coordinator
This employee will interface with the website on a daily basis to ensure it complies with this policy.
The Coordinator reports to the ADA Website Accessibility Accommodations Officer and is a member of the Bank Internal Committee. The Coordinator will:
- Coordinate and implement changes to the website to keep it in compliance with this policy
- Implement and monitor tests of the website for compliance to WCAG 2.0 and Section 508
- Research and provide training materials, information and programs about website accessibility accommodations to staff responsible for implementing this policy and for keeping the website in compliance to this policy
- Surface policy and procedural interpretations to the Officer as necessary
- Coordinate staff support and logistics to keep website compliant with this policy
- Resolve informal concerns regarding the accessibility of the website
- Act as primary receiver of general inquiries and questions regarding the website and facilitate their documentation and resolution
- Facilitate and have primary responsibility for communication among all employees and third-party vendors supporting the website, the Officer and Bank Internal Committee
ADA Website Accessibility Accommodations IT Technician
This employee will provide technical assistance and advice as needed to the Officer and Coordinator. For the purposes of keeping the website compliant, the Technician will report to the Officer and Coordinator. The Technician will:
- Accept instruction and requests from the Officer and Coordinator in implementing this policy with respect to the website
- Provide technical assistance and oversight of third-party vendors supporting the website including quality control assessments
- Educate the Officer and Coordinator on the important technical aspects of coding and using content management software that will make the website more user friendly to individuals with disabilities
The bank will establish an informal process for collecting complaints, concerns and suggestions to improve the accessibility of its website to individuals with disabilities. Submissions to this process will be acknowledged, compiled and summarized on an annual basis by the ADA Website Accessibility Accommodations Coordinator.
The bank will ensure that all employees who interact with customers and the public are aware of how to assist concerned parties with documenting any complaints, concerns and suggestions about the website. The availability of the complaint process and the way to file a complaint will be communicated to the public on the bank’s website.
INFORMATION AND ASSISTANCE
ADA Website Accessibility Accommodations Coordinator is responsible for handling inquiries and questions regarding this ADA Website Accessibility Accommodations Policy. Please direct questions comments, suggestions and requests for information and assistance to:
Randy Alderman, Vice President
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