The Accessibility for Ontarians with Disabilities Act (AODA) Policy

Rationale
ACCES is committed to providing a barrier-free workplace where employees can participate fully in all aspects of their job.

Purpose

This policy outlines ACCES’s compliance with The Accessibility for Ontarians with Disabilities Act, 2005 and approach to workplace accommodation, accessibility, customer service standards and communication.

Policy

ACCES will seek to provide accommodation and accessibility both individually and systemically to provide a workplace that is accessible to all employees, stakeholders and people.

ACCES complies with The Accessibility for Ontarians with Disabilities Act, 2005 (AODA) in ensuring that its programs and services are fully accessible to people with disabilities. Most importantly, the core principles of the Act – independence, dignity, integration, equality of opportunity for people with disabilities – are aligned with inclusion, one of our organizational values, that help us achieve our mission. We support initiatives that remove barriers and promote or increase equitable access to social and economic participation in community life.

Scope

This policy applies to all ACCES employees, volunteers, third party contractors who work on behalf of ACCES, stakeholders and to members of the general public in their interactions with the organization, whether in person or in services offered remotely.

Our AODA program entails our communications, client service, employment and design of public spaces.

Policy Guidelines
In accordance with the Customer Service Standards, this policy addresses the following:

1. The Provision of Goods and Services to Persons with Disabilities
2. The Use of Assistive Devices
3. The Use of Guide Dogs, Service Animals and Service Dogs
4. The Use of Support Persons
5. Notice of Service Disruptions
6. Client Feedback
7. Training
8. Notice of Availability and Format of Required Documents

The Provision of Goods and Services to Persons with Disabilities
ACCES will make every reasonable effort to ensure that its policies, practices, and procedures are consistent with the principles of dignity, independence, integration, and equal opportunity by:

• Ensuring that all clients receive the same value and quality.
• Allowing clients with disabilities to do things in their own ways, at their own pace when accessing goods and services if this does not present a safety risk.
• Using alternative methods, when possible, to ensure that clients with disabilities have access to the same services, in the same place and in a comparable manner.
• Considering individual needs when providing goods and services.
• Communicating in a manner that considers the client’s disability.

The Use of Assistive Devices

Persons with disabilities may use their own assistive devices as required when accessing goods or services provided by ACCES.

The Use of Guide Dogs, Service Animals and Service Dogs

A client with a disability that is accompanied by guide dog, service animal or service dog will be allowed access to premises that are open to the public unless otherwise excluded by law. “No pet” policies do not apply to guide dogs, service animals and/or service dogs.

The client is responsible for the care and control of the animal at all times.

The Use of Support Persons
If a client with a disability is accompanied by a support person, ACCES will ensure that both persons are allowed to enter the premises together and that the client is not prevented from having access to the support person.

In situations where confidential information might be discussed, consent will be obtained from the client, prior to any conversation where confidential information might be discussed.

Notice of Service Disruptions
Service disruptions may occur due to reasons that may or may not be within the control or knowledge of ACCES. In the event of any temporary disruptions to facilities or services that clients with disabilities rely on to access or use ACCES services, reasonable efforts will be made to provide advance notice. In some circumstances such as in the situation of unplanned temporary disruptions, advance notice may not be possible.

If a notification needs to be posted the following information will be included unless it is not readily available or known:

• Services that are disrupted or unavailable.
• Reason for the disruption.
• Anticipated duration; and
• A description of alternative services or options.

When disruptions occur ACCES will provide notice by:

• Posting notices in conspicuous places including at the point of disruption, at the main entrance and the nearest accessible entrance to the service disruption and/or on the ACCES website.
• Contacting clients with appointments.

Feedback Process
ACCES has established processes for receiving and responding to feedback on services. For persons with disabilities, the feedback processes are provided in accessible formats and with communication support upon request. Clients who wish to provide feedback on the way ACCES provides services (and/or goods) to people with disabilities can do so in any of the following ways:

• By email to our general mailbox, [email protected]
• In person, by telephone or in writing to the client’s primary contact at ACCES, the site or program manager or to the person with whom they are interacting.

All feedback and/or complaints will be directed to the appropriate department for review.

Complaints will be addressed according to our organization’s regular complaint resolution process as detailed in the ACCES External Complaint Policy.

Accessible Client Service Training

Training will be provided to:

• Every person who is an employee.
• Every person who participates in developing policies.
• Every other person who provides goods, services, or facilities on behalf of the provider.

Regardless of the format, training will cover the following:

• A review of the purpose of the Accessibility for Ontarians with Disabilities Act, 2005.
• A review of the requirements of the Customer Service Standards.
• Instructions on how to interact and communicate with people with various types of disabilities.
• Instructions on how to interact with people with disabilities who:
  • use assistive devices.
  • require the assistance of a guide dog, service dog or other service animal; or
  • require the use of a support person (including the handling of admission fees).
• Instructions on how to use equipment or devices that are available at our premises or that we provide that may help people with disabilities.
• Instructions on what to do if a person with a disability is having difficulty accessing your services.
• ACCES policies, procedures and practices pertaining to providing accessible client service to clients with disabilities.

ACCES provides training as soon as practicable. ACCES keeps a record of training that includes the dates training was provided and the number of employees who attended the training.

Notice of Availability and Format of Required Documents

ACCES shall notify clients that the documents related to the Customer Service Standards are available upon request and in a format that considers the client’s disability. Notification will be given by posting the information on the ACCES website.

Policy Administration

This policy and its related procedures will be reviewed as required in the event of legislative changes, or changes to company procedures.

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Integrated Accessibility Standards Regulation (IASR) Policy

Policy
ACCES is committed to providing high quality standards of service that can be accessed in a manner that respects the dignity and independence of persons with disabilities. ACCES ensures that persons with disabilities have the same opportunities to access and benefit from the ACCES services in ways like others.

ACCES policies and practices are based on the four underlying principles of dignity, independence, integration, and equal opportunity.

The implementation of this policy is a multi-year process. The timeline for the implementation of the commitments within this policy is outlined in Appendix A.

Scope

This policy applies to all employees as well as volunteers, contractors, any other individuals who interact with the public or third parties in Ontario, who represent or act on behalf of ACCES in any manner.

Statement of Commitment

ACCES is committed to treating all people in a way that allows them to maintain their dignity and independence. We believe in integration and equal opportunity that ensures persons with disabilities (“PWD”) have the same opportunities to access and benefit from our services. ACCES is committed to meeting the needs of people with disabilities in a timely manner and do so by removing barriers to accessibility and meeting accessibility requirements under the Integrated Accessibility Standards Ontario Regulation 191/11 (IASR) of the Accessibility for Ontarians with Disabilities Act, 2005 (AODA).

Training on AODA Accessibility Standards & Ontario Human Rights Code

Training is provided to employees and third-party contractors on the Ontario’s AODA Accessibility Standards and the Ontario Human Rights Code as it relates to people with disabilities (except for service providers whose contracts require that they have completed training prior to commencement of service). The Human Resources department maintains records on the completion of training.

Design of Public Spaces

ACCES takes persons with disabilities into consideration when designing new or making modifications to ACCES public spaces.

Information and Communications

ACCES is committed to making information and communications accessible to persons with a disability.

Accessible Websites and Web Content

ACCES’s public website and web content conform to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG 2.0), Level AA as of January 1, 2021.

In addition to conforming to WCAG requirements, the website includes functional accessibility features to allow website users with vision impairment, to adjust the website content, to adapt to their vision needs. This includes changing font size, contrast and colour.

The website compliance checker, “Siteimprove” is utilized to continuously check our website to identify conformance issues. This supports our website managers to fix any deficiencies to maintain compliance standards.

Accessible Emergency Information

ACCES provides emergency procedures and plan information available to the public in an accessible format, or with appropriate communication supports, as soon as practicable, upon request.

Feedback Process

ACCES has established processes for receiving and responding to feedback on services. For persons with disabilities, the feedback processes are provided in accessible formats and with communication supports, upon request.

Our feedback processes are further detailed in the Accessible Customer Service Policy.

Employment

ACCES is committed to fair and accessible employment practices.

ACCES will treat all persons equitably with respect to employment and provide employees with reasonable accommodation in employment as required. With reference to the Ontario Human Rights Code and AODA, the organization will, through the process of accommodation, enable employees to perform the essential requirements of their jobs in accordance with the principles of dignity, individualization, and inclusion. The organization will work cooperatively with all partners in the accommodation process and will assess and provide accommodation to employees on an individual basis.

Recruitment and Selection

ACCES provides notice to its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment and selection processes. This notification appears on each posting.

Arranging suitable accommodation is determined by ACCES in consultation with the candidate and considers the candidate’s accessibility needs due to disability. When making an offer of employment, the successful candidate is advised of ACCES policies for accommodating employees with disabilities.

Supports for Employees

ACCES employees are informed of policies used to support employees with disabilities, including policies on the provision of job accommodations that consider an employee’s accessibility needs due to disability. This communication is delivered as soon as practicable after commencement of employment and upon a request for accommodation.

Performance Management, Career Development, Advancement and Redeployment

The performance management process, including assessment, goal setting, talent management (also includes office relocation) considers the accessibility needs of employees with disabilities, as well as individual accommodation plans.

Accommodation Plans

ACCES maintains documented individual accommodation plans for employees with disabilities. As necessary and as requested, the individual employee plan could include information regarding accessible formats and communication supports.

Return to Work Accommodation Plans Following Disability Leave

ACCES return to work process is for employees returning from disability leave who require disability related accommodation to facilitate their return to work. This will include workplace emergency response information, where applicable.

Workplace Employee Emergency Response Information

ACCES provides employees individualized workplace emergency response information as requested or when made aware of the need for accommodation due to disability. ACCES provides this information as soon as practicable after becoming aware of the need for accommodation. Written emergency accommodation plans are documented for the individual and reviewed/assessed when:

• The employee moves to a new office.
• The employee’s overall accommodation plan is being reviewed.
• ACCES reviews overall emergency response policies.

Policy Administration

This policy and its related procedures will be reviewed as required in the event of legislative changes, or changes to company procedures.

Definitions

 

Assistive Device

An assistive device is a technical aid, communication device or other instrument that is used to maintain or improve the functional abilities of people with disabilities. Personal assistive devices are typically devices that clients/visitors bring with them such as a wheelchair, walker or a personal oxygen tank that might assist in hearing, seeing, communicating, moving, breathing, remembering and/or reading.

Disability

The term disability as defined by the Accessibility for Ontarians with Disabilities Act, 2005, and the Ontario Human Rights Code, refers to:

• Any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device;
• A condition of mental impairment or a developmental disability.
• A learning disability, or dysfunction in one or more of the processes involved in understanding or using symbols or spoken language.
• A mental disorder; or
• An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

Guide Dog

A guide dog is a highly trained working dog that has been trained at one of the facilities listed in Ontario Regulation 58 under the Blind Persons’ Rights Act, to provide mobility, safety and increased independence for people who are blind.

Service Animal

An animal is a service animal (including a service dog) for a person with a disability if:

1. the animal can be readily identified as one that is being used by the person for reasons relating to the person’s disability, because of visual indicators such as the vest or harness worn by the animal; or
2. the person provides documentation from one of the following regulated health professionals confirming that the person requires the animal for reasons relating to the disability:
   1. A member of the College of Audiologists and Speech-Language Pathologists of Ontario.
   2. A member of the College of Chiropractors of Ontario.
   3. A member of the College of Nurses of Ontario.
   4. A member of the College of Occupational Therapists of Ontario.
   5. A member of the College of Optometrists of Ontario.
   6. A member of the College of Physicians and Surgeons of Ontario.
   7. A member of the College of Physiotherapists of Ontario.
   8. A member of the College of Psychologists of Ontario; or
   9. A member of the College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario.

Support Person

A support person means, in relation to a person with a disability, another person who accompanies someone to help with communication, mobility, personal care, medical needs or access to goods and services.

Accessible Format, Communication Support and Assistive Devices
For the purposes of this Policy, accessible format, communication support and assistive devices may include large print, recorded audio and electronic formats, brail, and other formats useable by persons with disabilities; captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications; wheelchairs, walkers, and electronic communication devices and other devices.

Barrier
For the purposes of this Policy, a barrier is defined as anything that keeps someone with a disability from participating fully in society because of his or her disability, including a physical barrier, an architectural barrier, an information or communications barrier, an attitudinal barrier, a technology barrier, a policy, or a practice.

Integrated Accessibility Standards Regulation (IASR) Plan

 

Regulation/Topic	Target Date	Requirement	Status
Integrated Accessibility General	January 1, 2014	Develop Accessibility Policy for IASR including statement of commitment and post on website	UpdatedJune 2021
	January 1, 2014	Develop multi-year accessibility plan and post on website	Updated June 2021
	January 1, 2015	Develop and deliver training program on IASR & OHR as it applies to disabilities	Ongoingas required
	Next review January 2026…	Review accessibility plan every 5 years	Planreview completed June 2021
Build Environment Design of Public Spaces Standards	January 1, 2017, and ongoing	Follow accessibility standards for service counters, waiting areason new builds and renovations	Ongoingas required
Information and Communication	January 1, 2016, and ongoing	Provide accessible formats and communication supports	Ongoing as required
	January 1, 2014	New websites and significant refresh meet WCAG 2.0 Level A	Complete
	January 1, 2021	All websites and content meet WCAG 2.0 Level AA	Ongoing as required
	January 1, 2012	Emergency procedures, plans or public safety information accessible to public	Ongoingas required
	January 1, 2015 & ongoing	Feedback processes available in accessible format with communication supports	Ongoingas required
Employment	January 1, 2016 & ongoing	Recruitment and hiring processes provide accommodation	Ongoing as required
	January 1, 2016 & ongoing	Accommodation plans, RTW, Performance Management and Career development	Ongoingas required
	January 1, 2012 & ongoing	Employee Emergency Response Plans (CSR)	Ongoing as required

 

Plan Administration

This plan will be reviewed on an ongoing basis and as required in the event of legislative changes, or changes to company procedures.

ACCES Employment – AODA & IASR Policies