Privacy Policy

I. Policy Statement

The Louisiana Department of Health (LDH) is committed to ensuring that all individuals, including people with disabilities, have equal access to information, services, and programs provided through LDH web properties. In accordance with Louisiana PPM 74 – Web Accessibility Compliance, this policy establishes LDH's approach to achieving and maintaining digital accessibility in compliance with applicable federal and state laws and standards.

II. Applicability

This policy applies to all LDH offices. Whether centralized under or independent of the LDH.la.gov website, all websites or additional Web Properties representing an LDH Office or Program shall comply with the following policy requirements.

III. Definitions

Web Properties

The various web presences an LDH Office uses to represent itself. This may include websites, mobile applications, and social media accounts that serve different purposes or audiences.

Web Content

The information and sensory experience communicated to the user of a website or mobile application. This may be achieved through text, images, sound, video, linked documents, and social media posts.

Web Content Accessibility Guidelines (WCAG)

A set of technical standards for web content and mobile applications so that they are accessible by people with disabilities.

LDH Web Accessibility Coordinator

The LDH Digital Media Director within the Bureau of Media and Communications (BMAC) also serves as the LDH Web Accessibility Coordinator, overseeing and providing support to LDH Offices on web accessibility.

Web Accessibility Designee

The primary individual designated by each LDH Office to oversee its web content and ensure compliance with these procedures. The name, email address, and telephone number of this individual shall be identified in the Accessibility Statement that is linked directly from the website home page. A list of the current Designee for each LDH Office is located in Appendix A.

Content Managers

Individuals who have access to create or modify web content on behalf of an LDH Office. This may or may not be the same as the Web Accessibility Designee.

Web Vendor

The third-party vendor that designed and/or supports an LDH Office's website(s).

OTS Webmaster

The Louisiana Office of Technology Services designee who works closely with the LDH Digital Media Director on technical website needs. All questions and requests directed to the OTS Webmaster must include the LDH Digital Media Director.

IV. Policy Provisions

A. Content Standards

At a minimum, all LDH Web Properties shall comply with WCAG 2.1, Level AA.

B. Accessibility Statement

There shall be an Accessibility Statement linked directly from the home page or footer that includes the following:

1. A non-discrimination statement and a commitment to making web content accessible for people with disabilities; and,
2. Contact information, including the name, email address, and telephone number, for the LDH Web Accessibility Coordinator, so that people with disabilities know how and whom to contact if they experience accessibility issues.

C. Internal Controls

Each LDH Office shall adhere to the Web Accessibility Procedures so that web content is screened, monitored, and corrected as necessary for accessibility.

1. Web Content Managers – LDH will maintain a reasonable and manageable content manager group to ensure best practices are followed and to avoid added risk of human error. Each Office/Bureau must designate one (1) primary and one (1) secondary user based on needs and skill level. All website needs shall be coordinated through these Web Content Managers. Exceptions to add additional Web Content Managers may be granted on a case-by-case basis by the LDH Digital Media Director.
2. Siteimprove (www.siteimprove.com) – This is a cloud-based platform used to monitor and improve websites by automatically scanning (or "crawling") for issues related to accessibility and quality assurance.
   1. Online Training – All Web Accessibility Designees and Content Managers shall complete online training through the Siteimprove Learning Hub located at https://learninghub.siteimprove.com/. Required training shall be completed within 60 days of the effective date of this procedure or assignment as a Web Accessibility Designee or Content Manager, whichever is later. Upon completion, a copy of the four (4) training certificates (located under the My Profile tab) shall be emailed to the LDH Web Coordinator for recordkeeping purposes. The required courses include:
      1. Siteimprove Onboarding: Introduction and Accessibility
      2. Accessibility with WCAG 2.1
      3. Accessibility for Documents
      4. Accessibility for PDFs
   2. Weekly Siteimprove Crawls and Corrections – Siteimprove automatically crawls LDH's websites every five (5) days. In turn, Web Accessibility Designees shall complete the following weekly:
      1. Log in and review any issues identified in the Accessibility Dashboard and Quality Assurance Dashboard for their applicable LDH Office's website(s) in Siteimprove and make the corrections (such as adding alternative text, fixing broken links, misspellings, or header issues).
      2. For issues that cannot be accessed in the Content Management System (CMS) — (such as color contrast, restricted page zoom, or hidden element issues), the Web Accessibility Designee shall report these to the LDH Digital Media Director and Web Vendor.
      3. Accessibility-tested PDFs: For machine readability, PDF tags, or other issues, the Web Accessibility Designee shall ensure the necessary corrections are made as soon as reasonably possible. Based on the volume of linked PDFs, the Web Accessibility Designee shall consider:
         1. Permanently removing any PDF documents that are outdated or no longer relevant;
         2. Converting PDF documents to an alternative format, such as Microsoft Word or HTML;
         3. Temporarily removing PDF documents that are still active and used by the public until they can be fixed and replaced on the website. In the meantime, a note can be added on the website advising the public that they can request such PDF documents by emailing the Web Accessibility Designee. (NOTE: When emailed rather than linked to the website, PDFs are not subject to the Web Content Accessibility Guidelines.)
3. Manual Accessibility Checks – As of the effective date of this procedure, all staff must ensure accessible design and development practices are incorporated into all new and updated web properties.
   1. All webpage text must be proofread for grammar, spelling, and readability by a second party (e.g., another colleague or supervisor).
   2. No new or replaced documents shall be linked to an LDH Office's website unless:
      1. It is formatted as an Adobe PDF, Microsoft Word, or Microsoft Excel document type; and
      2. The built-in Accessibility Checker available in these software packages has been executed, and any flagged accessibility issues have been resolved before linking it to the website.

V. Responsibilities

The LDH Web Accessibility Coordinator shall ensure that each Office Communications Liaison automatically receives a Siteimprove Accessibility Report for each of their offices' websites on the first business day of each month. These reports shall include overall accessibility scores, identified errors, warnings, and review items, as well as trend data where available.

The LDH Web Accessibility Coordinator shall review reports for recurring issues and high-risk compliance concerns. The Coordinator is authorized to remove, unpublish, or update noncompliant content when necessary to mitigate legal risk, address critical accessibility barriers, or ensure continued compliance with state and federal accessibility requirements. When feasible, the Coordinator will notify the appropriate Office Communications Liaison before making substantial content changes.

A. The Office Communications Liaison is responsible for:

1. Reviewing the monthly Siteimprove Accessibility Report(s) promptly (within five business days of receipt).
2. Distributing relevant findings to designated Web Accessibility Designees and other responsible staff.
3. Prioritizing remediation of Level A and Level AA accessibility issues, or other issues that create significant barriers to access.
4. Ensuring accountability by establishing internal deadlines for corrective action.
5. Escalating persistent or resource-dependent issues to the LDH Web Accessibility Coordinator when necessary.

B. Web Accessibility Designees are responsible for:

1. Logging into SiteImprove weekly to review assigned accessibility issues and validate findings.
2. Correcting identified errors, warnings, and review items within established timelines.
3. Ensuring that new and updated content meets accessibility standards before publication.
4. Coordinating with content authors, developers, and third-party vendors as needed to remediate issues.
5. Documenting remediation efforts and noting any exceptions, technical constraints, or required long-term fixes.
6. All Web Accessibility Designees shall submit a written monthly status report to the LDH Web Accessibility Coordinator no later than the last business day of each month. This report shall:
   1. Confirm which issues have been resolved.
   2. Identify any outstanding issues and justify delays.
   3. Outline anticipated timelines for unresolved items.
   4. Document any recurring compliance challenges or training needs.

C. Records and Follow-up

The LDH Web Accessibility Coordinator shall maintain records of monthly reports and may conduct follow-up audits or targeted reviews to verify remediation efforts. Persistent non-compliance may be escalated to Office leadership for corrective action.

Accessibility monitoring and remediation are ongoing responsibilities. All Offices are expected to maintain compliance continuously, not solely at the time of monthly reporting.

VI. Violations

Violations of this policy may result in corrective action or disciplinary action. Corrective action includes Improvement Letters (Civil Service Rule 12.9), verbal counseling, documented counseling, and/or reprimand. Letters issued for corrective action are at the sole discretion of the Appointing Authority. Disciplinary actions are Suspension without Pay, Reduction in Pay, Involuntary Demotion, and Dismissal (Civil Service Rule 12.3). Any disciplinary action taken is at the sole discretion of the Appointing Authority.

VII. References

• Web Content Accessibility Guidelines (WCAG) 2.1, Level AA
• Louisiana PPM 74 – Accessibility of Information and Communication Technology
• Americans with Disabilities Act (ADA)
• U.S. Department of Justice, Civil Rights Division: Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments
• Section 508 of the Rehabilitation Act

VIII. Revision History