Overview
- Statement of Commitment
- Purpose and Objective
- Scope and Application
- Principles
- Responsibilities
- Accessibility Standards for Customer Service Requirements
- Integrated Accessibility Standards Regulation (IASR)
- Definitions
- Requirements
- Related Information
- Multi-Year Accessibility Plan for Hollandia Gardens Ltd.
1. Statement of Commitment
Hollandia Gardens Ltd. is committed to service excellence, and strives at all times to provide products and services in a way that respects the dignity and independence of people with disabilities. The organization is committed to meeting the needs of people with disabilities in a timely manner, and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the Accessibility for ration (Ontarians with Disability Act, 2005 (AODA).
2. Purpose and Objective
Our objective with the Accessibility Standards for Ontarians with Disabilities Policy (“Policy”) is to ensure any persons acting on behalf of this company comply with the AODA to provide products and services to its customers and stakeholders in a manner that respects the dignity and independence of people with disabilities. It is also the objective of this Policy to comply with the Integrated Accessibility Standards under Ontario Regulation 191/11 for general standards, information and communication, and employment.
3. Scope and Application
The Policy encompasses the practices and procedures governing the provision of products and services to people with disabilities, including company employees, and includes the following procedures and guidelines in support of the Customer Service Standards and Integrated Accessibility Standards Regulation (IASR):
- Use of Assistive Devices
- Use of Service Animals and Support Persons
- Disruptions in Service;
- Feedback Process;
- Individualized Workplace Emergency Response Information for Disabled Employees; and
- • Our Standards for developing web content/digital properties guide (WCAG2.0).
This Policy applies to employees and other people acting on behalf of this company who interact with the public. It may be revised as other standards are introduced under the AODA.
4. Principles
To use reasonable efforts to ensure that the policy, practices and procedures developed hereunder will be consistent with the following principles:
Dignity – People with disabilities are valued as deserving of our products and services as any other customer or stakeholder.
Independence – The capabilities of people with disabilities will be acknowledges and respected.
Integration – The provision of products or services to people with disabilities and others will be integrated, unless an alternate measure is necessary, whether temporarily or on a permanent basis, to enable them to obtain, use or benefit from our products or services.
Equal Opportunity – Where a uniform response is inappropriate, individual needs will be taken into account when providing products and services. This is to ensure there are no barriers to access or participation, and that individuals are treated in a manner similar to other customers and stakeholders.
Implementing these principals will ensure the Customer Service Standards become part of the everyday product and service delivery. Practices and procedures will be adopted to remove barriers to the overall customer experience of people with disabilities.
5. Responsibilities
5.1 Employees and other persons acting on our behalf will
- adhere to this Policy.
5.2 Accessibility Act Committee (AAC)
- implement universal accessibility standards to support the regulation requirements;
- provide advice and guidance on specific initiatives undertaken by this company in order to prevent, identify and remove barriers that restrict people with disabilities from accessing our services and facilities; and
- review the Policy on an ongoing basis and recommend improvements to the Policy to the Director, Employee Relations and Programs.
5.3 Supervisor/Department Head/Manager
- model behavior through decisions, actions and interactions that are consistent with the provisions of this Policy;
- respond to and provide input into Policy changes;
- ensure that the Policy is communicated to all employees;
- ensure employees maintain compliance with this Policy; and
- act on non-compliant issues within their area of responsibility
5.4 Management
- direct changes to the Policy as required;
- establish and deliver a training program for all employees on accessibility standards;
- ensure that the corporation meets its obligations under this Policy; and
- recommend amendments to this Policy to the President and Chief Administrative Officer.
5.5 President and Chief Administrative Officer
- ensure that all direct reports comply with this Policy; and
- approve this Policy and any subsequent amendments or revisions.
6. Accessibility Standards for Customer Service Requirements
Hollandia Gardens Ltd. will ensure compliance with the AODA to identify, remove and prevent barriers to accessibility by developing, implementing and enforcing accessibility standards as outlined below.
Ongoing reviews of accessible customer service requirements and changes thereto will be implemented to improve the delivery of accessible customer service. The following are the Accessibility Standards for Customer Service as outline in the AODA:
- Establish policies, practices and procedures to provide products or services to people with disabilities.
- Use reasonable efforts to ensure that policies, practices and procedures are consistent with the core principles of independence, dignity, integration and equality of opportunity.
- Communicate with a person with a disability in a manner that takes into account his or her disability.
- Train employees, contractors and other people who interact with the public on company’s behalf on requirements outlined in the Customer Service Standard.
- Train employees, contractors and other people involved in developing policies, practices and procedures related to the provision of products or services as outlined in the Customer Service Standard.
- Establish a policy on the use of personal assistive devices to access our products and services, including equipment and services provided by us.
- Allow persons with disabilities to be accompanied by their guide dog or service animal in those areas of the premises company owns or operates that are open to the public, unless the animal is excluded by another law. If a service animal is excluded by law, other measures are used to provide services to the person with a disability.
- Permit people with disabilities who use a support person to escort that person while accessing products or services in premises open to the public or third parties. If a person with a disability is accompanied by a support person, we shall ensure that both people are permitted to enter the premises together and, that the person with a disability is not prevented from having access to the support person while on the premises. Management may require a person with a disability to be accompanied by a support person when on the premises, but only if a support person is necessary to protect the health or safety of the person with a disability, or the health or safety of others on the premises.
- Provide notice when facilities or services that people with disabilities rely on to access or use company’s products or services are temporarily disrupted.
- Establish a process to enable people to provide feedback on methods used to provide products and services to people with disabilities, as well as how responses to feedback will be managed and improvements implemented on any complaints, and to make this information readily available to the public.
6.1 Communication with Customers with Disabilities
The employees will communicate with people with disabilities in a manner that takes into account their disability for the purpose of using, receiving and requesting products and services. We will provide sufficient space in seating areas to accommodate service animals or support persons, or provide accessible meeting rooms to communicate with people with disabilities. Our Human Resources department will provide electronic information externally and internally in accessible formats, as required.
6.2 Service Delivery
Hollandia Gardens Ltd. is committed to providing people with disabilities the opportunities to and benefits of accessing products and services in the same place and similar manner as other customers. Company employees are trained to communicate with customers in clear language that respects the dignity and independence of people with disabilities.
Assistive Devices: A customer with a disability may use their own assistive device(s) for the purpose of obtaining and using our products and services. We will ensure employees are trained and familiar with various assistive devices that may be used by customers with disabilities to obtain or use products and services.
Service Animals: Service animals are permitted in public access areas in all offices, and adequate space/seating arrangements are made available for people with disabilities and their service animals.
Management will ensure all employees are trained to identify a service animal and effectively interact with people with disabilities who are accompanied by a service animal.
Service animals must be under the care and control of the person with a disability at all times.
Unless otherwise prohibited by law, service animals are permitted access to public areas within our locations.
Support Persons: Management will ensure any person with a disability who is accompanied by a support person will be permitted access to that support person while on company’s premises. Adequate seating arrangements will be made available. In situations where confidential information of a customer with a disability is to be discussed, we may require a signed statement of permission and/or consent from the customer with a disability to allow their support person to be present.
Notice of Temporary Disruption in Services and Facilities: We will make reasonable efforts to provide notice of a temporary disruption to public access, including information about the reason for the disruption, its anticipated duration and a description of alternate facilities or services, if any, that may be available.
Procedures for temporary service disruptions will be posted on our internal and external websites.
6.3 Document Requirements
Customers have been notified that all documentation relating to the Accessibility Standards for Ontarians with Disabilities is available upon request and will be provided in a format that takes into account a person’s disability.
7. Integrated Accessibility Standards Regulation (IASR)
This regulation sets out general standards as well as the standards for information and communications, employment and transportation. Please note that the transportation standards are not applicable to Hollandia Gardens Ltd.
7.1 General Standards
We will:
- establish, implement, maintain and document a multi-year accessibility plan;
- give regard to incorporating accessibility features when procuring or acquiring goods, services or facilities, where applicable;
- give regard to incorporating accessibility features when designing, procuring or acquiring self-service kiosks where applicable; and
- provide training on the requirements of the accessibility standards as referred to in the Regulation 191/11 and on the Human Rights Code, as it pertains to people with disabilities.
7.1.1 Multi-year Accessibility Plan
We will:
- develop, implement, document and maintain a multi-year accessibility plan, which outlines Hollandia Gardens Ltd’s strategy to prevent and remove barriers, outlining how we will meet requirements under the IASR;
- post the multi-year accessibility plan on our website ASAP;
- provide the plan in an accessible format upon request; and
- review and update the multi-year accessibility plan at least once every five years.
7.1.2 Procuring or Acquiring Goods, Services or Facilities
We are not required by the AODA to incorporate accessibility design, criteria and features when procuring or acquiring goods, services or facilities as a designated public sector organization.
We have decided that it is good business practice to incorporate accessibility design, criteria and features, whenever feasible, as determined by Management in its discretion.
7.1.3 Self- Service Kiosk Accessibility Features
Hollandia Gardens Ltd does not offer products and/or services through self-service kiosk at this time. If required in the future, we will consider accessibility features that could be built into self-service kiosks to best meet the needs of its customers. We will strive to include accessibility needs, preferences and abilities of the widest range of users.
7.1.4 Training
Training on all aspects of the Accessibility Customer Service Standards, the requirements in the Integrated Accessibility Standards Regulation, as well as the Ontario Human Rights Code as it relates to people with disabilities will be provided to:
- every employee and all persons acting on behalf of this company who interact with the public on service or product related enquiries; and
- every person who participates in developing Hollandia Gardens Ltd’s policies and procedures related to the provision of products and services to people with disabilities.
Training is provided to all new employees as soon as practical after they have assumed applicable duties and, on an ongoing basis when changes to the policies and practices and procedures occur that require additional training.
Training is provided in a way that best suits the duties of employees and all persons acting on our behalf.
As well, all internal training provided by a third party vendor must adhere to the company’s internal learning design standards that comply with AODA for the presentation of electronic media, including accessible design and development techniques.
Participants and dates of training are tracked and provided to the Director of Employee Relations and Programs.
Please note that the IASR does not replace or affect existing legal obligations under the Ontario Human Rights Code and other laws with respect to accommodation of people with disabilities. Organizations must comply with both pieces of legislation.
7.1.5 Filing Accessibility Reports
The AODA states that required Accessibility Reports are made available to the public, and that the report is to contain information as prescribed and include a statement certifying that all information required to be provided under the Act is provided and accurate.
7.2 Information and Communication Standards
7.2.1 Feedback Process
Hollandia Gardens Ltd strives for continuous improvement in this area and has established a process to solicit and respond to feedback from employees and customers/stakeholders.
7.2.2 Accessible Formats and Communication Support
Hollandia Gardens Ltd. ensures information and communications about its products, services and facilities are available and accessible to employees and customers/stakeholders with disabilities through an accessible format or support services. Appropriate timelines will take into consideration the availability of the format requested, the complexity and the amount of information, and the internal resources/capabilities at the company. Accessible formats and communication supports are provided at no additional charges other than what would be charged to anyone for the same information.
Examples of accessible delivery mechanisms may include:
- accessible electronic formats such as HTML and MS Word;
- plain language version;
- braille
- accessible audio formats;
- large print
- reading aloud to a person(s) directly;
- assistive listening systems;
- devices that speak out messages;
- captioning or audio description; and
- repeating, clarifying or restating information.
7.2.3 Emergency Procedures, Plans and Public Safety Information
We are committed to providing customers with publicly available emergency information in an accessible format upon request. This includes evacuation procedures in the event of emergency. We also provide employees with disabilities individualized emergency response information where necessary.
When assisting someone with a disability during an emergency evacuation employees will:
- always ask someone with a disability how they can help them, before giving any assistance or attempting any rescue procedure;
- offer an “area of refuge” i.e. an area that offers a greater protection against fire, smoke and/or inclement weather;
- assist people using wheelchairs or scooters to “stay in place” or be assisted to an “area of refuge” to await rescue;
- provide emergency instructions for people with hearing impairment where offices do not have fire alarms with strobe lights, or be writing a short explicit note to evacuate; and
- offer their elbow to people who are blind or visually impaired and guide them through the evacuation route.
7.3 Employment Standard
Hollandia Gardens Ltd. provides accessibility throughout all stages of the employment cycle to help create a workplace that is fully accessible and allows employees to reach their full potential, this includes:
- Recruitment and Selection
- Accessible Workplace Information for Employees;
- Performance Management;
- Career Development and Advancement;
- Workplace Health & Safety and Emergency Response;
- Accommodation Plans; and
- Return to Work Protocol.
7.3.1 Recruitment and Selection
Upon request, Hollandia Gardens Ltd. will notify its employees and the public on the availability of accommodations for all applicants with disabilities in its recruitment process. This process includes accommodations in relation to materials or processes to be used during the assessment and/or selection phase, as well as consulting with the applicant to ensure that accommodations provided are appropriate and effective. This will also ensure their participation in the recruitment process.
For new hires and existing employees with disabilities, management will provide options for accommodations as required. This includes provisions of job accommodations, taking into account the employee’s accessibility needs, and is provided as soon as practical upon employment.
7.3.2 Accessible Workplace Information for Employees
Through consultation with employees to determine appropriate accessible format or communication support, company will provide or arrange for provisions of accessible formats and communication supports for:
- information needed in order to perform the job; and
- general information available to all employees in the workplace.
7.3.3 Performance Management
Performance Management Program (PMP) focuses on:
- clear employee expectations and priorities;
- meaningful dialogue between managers and employees;
- achievement of outcomes and observable behaviors;
- measurement of performance against objectives; and
- development planning, future career and professional development.
Through ongoing communication and coaching between employees with disabilities and their managers, accommodation plans and needs are reviewed, including:
- reviewing accommodation plans to determine whether adjustments are required;
- determining whether accessible formats are required for documents relating to performance management; and
- assessing if informal or formal coaching and feedback occurs in a manner that takes into account the employee’s disability.
7.3.4 Career Development and Advancement
Career development opportunities are made available to all employees, and can include but are not limited to:
- participating in formal and informal training;
- participating in special projects, or as part of a project team;
- job shadowing, temporary developmental assignments in a different position; and
- promotions and lateral assignments.
7.3.5 Workplace Health & Safety and Emergency Response Information
If accommodations are requested and are not already included in the Emergency Response Plan (ERP), ERPs can be updated to include requested accommodations. Or, an ERP will be developed in cooperation with the individual requesting accommodation.
With employee consent, the company can assign a designated person to an employee who requires assistance due to disability during an emergency. This process is provided whenever management becomes aware of the need for accommodations due to an employee’s disability. This information is updated when:
- there is a change in employment for either the employee with a disability or the designated employee
- there are job changes;
- the employee accommodation needs are reviewed and changed; and/or
- the employer reviews its general policy on emergency response.
7.3.6 Accommodation Plans
Management documents accommodation requirements in the form of Modified Work Agreements/Duties, where both the manager and employee develop and sign-off in agreement of the accommodation plan. Accommodation plans are reviewed on an ongoing basis, with a specific review date in the agreement to ensure plans are up to date and meeting the accommodation requirements.
7.3.7 Return to Work Protocol
Our Occupational Health & Safety Policy has a documented process for supporting employees in a safe and early return to work. This Policy includes accommodation options to facilitate and support the return to work process.
Often, individualized accommodation plans are developed to support and document the specific restrictions/accommodation requirements to ensure all are aware of any restrictions or modifications required for an employee. Accommodation plans are reviewed on a regular basis to ensure information is current and up to date.
In addition, we have a Long Term Disability (LTD) Return to Work Protocol to ensure employees and managers are aware of the process for returning to work form LTD, including a return to work plan, which may include accommodations and plan review timeframes.
8. Definitions
| Disability | (a) 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 a wheelchair or other remedial appliance or device; (b) a condition of mental impairment or a developmental disability; (c) a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language; (d) a mental disorder; or (e) an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997. |
| Service Animal | Service animals may include dogs used by people who are blind, hearing alert animals for people who are deaf, deafened or hard of hearing, and animals trained to alert an individual to an oncoming seizure and lead them to safety. A “guide dog” as defined in section one of the Blind Persons’ Rights Act. |
| Support Person | An individual hired or chosen by a person with a disability to provide services or assistance with communications, personal care, medical needs or with access to products or services. Personal care needs may include, but are not limited to, physically transferring an individual to a location or using the washroom. |
9. Requirements
All employees and customers/stakeholders have been notified that all documentation relating to the Customer Service Standards and the Integrated Accessibility Standards are available upon request and will be provided in a format that takes into account the person’s disability.
10. Related Information
- Accessibility for Ontarians with Disabilities Act, 2005 (AODA)
- Ontario Regulation 191/11;
- Use of Assisted Devices;
- Use of Service Animals and Support Persons;
- Disruptions in Service Process;
- Feedback Process;
- Individualized Workplace Emergency Response Information for disabled employees
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Date Created: Dec 09 2019 Date Approved: |
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| AODA Standard | IASR Requirement | Due Date | Steps to Take | Anticipated Barriers and Plans for Barrier Removal | Target Completion Date | Completion Status |
|---|---|---|---|---|---|---|
| IASR General Requirements | ||||||
| Create policies and procedures for each standard | Jan. 1, 2014 | Develop a Statement of Commitment, create AODA policies and identify regulatory gaps | Apr 05 2019 | COMPLETE | ||
| Create Multi-Year Accessibility plans | Jan. 1, 2014 | Dec 31 2019 | COMPLETE | |||
| Consider accessibility features when designing, procuring or acquiring self-kiosks | Jan. 1, 2014 | include in policy & post policy | Apr 05 2019Dec 31 2019 | COMPLETE | ||
| Train all staff and volunteers (including Board Members) on what they have to do under the IASR and on aspects of the Human Rights Code that relate to accessibility | Dec 31,2019 | create list of seasonal employees that are not currently active to ensure training in new year | Seasonal employees will need to complete training in spring | Dec 20 2019 | PENDING | |
| Complete government accessibility report | Nov 04,2019 | review checklist and submit for approval | Nov 04 2019 | Revised & resent for approval | ||
| Update Multi-Year Accessibility Plan | Dec 31,2019 | Post plan to website to make available to customers | Dec 31 2019 | COMPLETE | ||
| Complete government accessibility report | Dec 31,2019 | complete necessary revisions, update documents/website , send out training to current staff | Nov 04 2019 | Revised & Resent Dec 20 2019 for approval | ||
| Information & Communications | ||||||
| When asked, make your emergency and public safety information accessible to the public | Jan. 1, 2012 | Review emergency and public safety information and develop a process for responding to requests and supports – post to website | COMPLETE | |||
| All new internet websites and web content on those sites must conform with WCAG 2.0 level A | Jan. 1, 2014 | complete new website will be created in 2020.. review current website with developer and ensure level A is achieved… | COMPLETE | |||
| Make your feedback processes, like surveys or comment cards, accessible when asked | Jan. 1, 2015 | review feedback processes and create alternative documents if applicable | COMPLETE | |||
| Make information about your organization’s goods, services and facilities accessible upon request | Jan. 1, 2016 | Develop a process for responding to requests for alternative formats and supports * Institute centre policy that all documents will be created using a structured electronic format to allow for easier conversion to alternative formats – post to website | COMPLETE | |||
| All internet website and website content conforms with WCAG 2.0 level AA (excluding live captioning and audio description) | Jan. 1, 2021 | |||||
| Employement | ||||||
| When necessary, provide individual plans to help employees with disabilities during an emergency, or emergency information that’s formatted so an employee with a disability can understand it. | Jan. 1, 2012 | Review emergency information, Determine which employees need help and prepare and provide information to these employees, in an accessible format if required (Follow up with employees periodically, if applicable) | COMPLETE | |||
| Notify employees, potential hires and public that accommodations can be made during recruitment, assessment and selection processes for people with disabilities | Jan. 1, 2016 | include in policy & post policy in office and on website | COMPLETE | |||
| Notify new hires and staff of policies for accommodating employees with disabilities | Jan. 1, 2016 | All new hires & staff must read policies and sign off once complete | COMPLETE | |||
| Have in place a written process to develop individual accommodation plans for employees with a disability | Jan. 1, 2016 | Develop a process and procedure for these requests | COMPLETE | |||
| Have a written return to work process in place for employees who have been absent due to a disability | Jan. 1, 2016 | include in employee manual | COMPLETE | |||
If your office uses performance management, career development and redeployment processes, take the needs of employees with disabilities into account |
Jan. 1, 2016 | COMPLETE | ||||
| Design of Public Spaces | ||||||
| Make new or redeveloped spaces accessible | Jan. 1, 2017 | COMPLETE | ||||
| Maintain accessible elements of public spaces | Jan. 1, 2017 | COMPLETE | ||||