Accessibility Plan
Accessibility for Ontarians with Disabilities Act, 2005
INTEGRATED ACCESSIBILITY STANDARDS - MULTI-YEAR PLAN
PART I – GENERAL REQUIREMENTS
| Section | Initiative | Description | Action | Status | Compliance Date |
|---|---|---|---|---|---|
| 3 | Establishment of Accessibility Policies | 3. (1) Every obligated organization shall develop, implement and maintain policies governing how the organization achieves or will achieve accessibility through meeting its requirements under the accessibility standards referred to in this Regulation. | Develop policy | Complete | January 1, 2014 |
| 3 | Statement of Commitment | 3. (2) Large organizations shall include a statement of organizational commitment to meet the accessibility needs of persons with disabilities in a timely manner in their policies. | Include in policy | Complete | January 1, 2014 |
| 4 | Statement of Commitment | 4. (1) Large organizations shall, a. establish, implement, maintain and document a multi-year accessibility plan, which outlines the organization‘s strategy to prevent and remove barriers and meet its requirements under this Regulation; b. post the accessibility plan on their website, if any, and provide the plan in an accessible format upon request; and c. review and update the accessibility plan at least once every five years. | Multi-year plan draft 1 completed To be posted via IT once approved HR will review Jan 1, every year | Complete | January 1, 2014 |
| 7 | Training | 7. (1) Every obligated organization shall ensure that training is provided on the requirements of the accessibility standards referred to in this Regulation and on the Human Rights Code as it pertains to persons with disabilities to, a. all employees, and volunteers; b. all persons who participate in developing the organization c. all other persons who provide goods, services or facilities on behalf of the organization | Online eLearning during onboarding. | Complete | January 1, 2018 |
| 7 | 7. (4) Every obligated organization shall provide training in respect of any changes to the policies described in section 3 on an ongoing basis. | Develop training as needed | Complete | January 1, 2018 | |
| 7 | 7. (5) Every obligated organization shall keep a record of the training provided under this section, including the dates on which the training is provided and the number of individuals to whom it is provided. | Develop tracking system | Complete | January 1, 2018 |
PART II – INFORMATION AND COMMUNICATIONS STANDARDS
| Section | Initiative | Description | Action | Status | Compliance Date |
|---|---|---|---|---|---|
| 11 | Feedback | 11. (1) Every obligated organization that has processes for receiving and responding to feedback shall ensure that the processes are accessible to persons with disabilities by providing or arranging for accessible formats and communications supports, upon request. | Conduct a review of all feedback processes across the organization (internally and externally). Consult with all functional areas to make sure all feedback processes are captured. Determine what accessible formats and communication supports we will provide upon request. Ensure staff and management are aware of the need to accommodate upon request (to be part of training). | Ongoing | January 1, 2015 |
| 12 | Accessible Formats & Communication Supports | 12. (1) Except as otherwise provided, every obligated organization shall upon request provide or arrange for the provision of accessible formats and communication supports for persons with disabilities, a. in a timely manner that takes into account the person‘s accessibility needs due to disability; and b. at a cost that is no more than the regular cost charged to other persons. | Determine what accessible formats and communication supports we will provide to persons with disabilities upon request. Ensure these formats and supports can be provided in a timely manner (ex. Same time, 24 hours) Communicate to staff and management that no additional charge is required (to be part of training) | Ongoing | January 1, 2016 |
| 12 | 12. (2) The obligated organization shall consult with the person making the request in determining the suitability of an accessible format or communication support. | Communicate to staff and management this requirement (to be part of training) Develop protocol for situations where a suitable agreement cannot be made | Ongoing | January 1, 2016 | |
| 12 | 12. (3) Every obligated organization shall notify the public about the availability of accessible formats and communication supports. | Have a sign posted in reception area (Ops) Post on website (IT) Include notice on certain print materials | Complete | January 1, 2018 | |
| 14 | Accessible Websites & Web Content | 14. (2) Designated public sector organizations and large organizations shall make their internet websites and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG)2.0, initially at Level A and increasing to Level AA, and shall do so in accordance with the schedule set out in this section. | No new content has been added therefore no further action to take at this time unless requested regarding WCAG 2.0 Level A | Complete | January 1, 2014 New internet websites and web content on those sites must conform with WCAG 2.0 Level A. January 1, 2021 All internet and web content must conform with WCAG 2.0 Level AA, other than, success criteria 1.2.4 Captions (Live) success criteria 1.2.5 Audio Descriptions (Prerecorded). |
PART III – EMPLOYMENT STANDARD
| Section | Initiative | Description | Action | Status | Compliance Date |
|---|---|---|---|---|---|
| 22 | Recruitment - General | 22. Every employer shall notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment processes. | Identify where we advertise – paper, website, bulletin board etc. Example: We are committed to providing accommodations for persons with disabilities. If you require accommodation, we will work with you to meet your needs. | Complete | January 1, 2018 |
| 23 | Recruitment, Assessment or Selection Process | 23. (1) During a recruitment process, an employer shall notify job applicants, when they are individually selected to participate in an assessment or selection process, that accommodations are available upon request in relation to the materials or processes to be used. 23. (2) If a selected applicant requests an accommodation, the employer shall consult with the applicant and provide or arrange for the provision of a suitable accommodation in a manner that takes into account the applicant‘s accessibility needs due to disability. | Identify the language we will use Identify barriers: location of interview room, format of tests, room set up for in-person interviews, interviewing timelines, supports, paperwork Develop interview guidelines |
Complete | January 1, 2018 |
| 24 | Notice to Successful Applicants | 24. Every employer shall, when making offers of employment, notify the successful applicant of its policies for accommodating employees with disabilities | Input a statement in hire letter (Notification to Successful Applicants) | Complete | January 1, 2018 |
| 25 | Informing Employees of Supports | 25. (1) Every employer shall inform its employees of its policies used to support its employees with disabilities, including, but not limited to, policies on the provision of job accommodations | Circulate policy Training Posters All staff emails Brochures | Ongoing | January 1, 2018 |
| 25 | 25. (2) Employers shall provide the information required under this section to new employees as soon as practicable after they begin their employment. | Communicate this to employees upon being hired | Complete | January 1, 2017 | |
| 25 | 25. (3) Employers shall provide updated information to its employees whenever there is a change to existing policies on the provision of job accommodations that take into account an employee‘s accessibility needs due to disability. | See 25. (1) | Ongoing | January 1, 2016 | |
| 26 | Accessible Formats & Communication Supports for Employees | 26. (1) In addition to its obligations under section 12, where an employee with a disability so requests it, every employer shall consult with the employee to provide or arrange for the provision of accessible formats and communication supports for, a. information that is needed in order to perform the employee‘s job; and b. information that is generally available to employees in the workplace. | Functional audit of information specific to departments Audit of regular communications | Ongoing | January 1, 2016 |
| 26 | 26. (2) The employer shall consult with the employee making the request in determining the suitability of an accessible format or communication support. | List what the employee will require – i.e. Policy, communication supports that are available (text-to-speech, braille, large print, accessible PDFs, plain language versions, closed captioning) | Ongoing | January 1, 2016 | |
| 27 | Workplace Emergency Response Information | 27. (1) Every employer shall provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary and the employer is aware of the need for accommodation due to the employee‘s disability. | Develop process | Complete | January 1, 2012 |
| 27 | 27. (2) If an employee who receives individualized workplace emergency response information requires assistance and with the employee‘s consent, the employer shall provide the workplace emergency response information to the person designated by the employer to provide assistance to the employee. | Part of process with employee’s consent | Complete | January 1, 2012 | |
| 27 | 27. (3) Employers shall provide the information required under this section as soon as practicable after the employer becomes aware of the need for accommodation due to the employee‘s disability. | Part of process | Complete | January 1, 2012 | |
| 27 | 27. (4) Every employer shall review the individualized workplace emergency response information, a. when the employee moves to a different location in the organization; b. when the employee‘s overall accommodations needs or plans are reviewed; and c. when the employer reviews its general emergency response policies. | Part of process | Complete | January 1, 2012 | |
| 28 | Documented Individual Accommodation Plans | 28. (1) Employers, other than employers that are small organizations, shall develop and have in place a written process for the development of documented individual accommodation plans for employees with disabilities. | Develop process | Complete | January 1, 2017 |
| 28 | 28. (2) The process for the development of documented individual accommodation plans shall include the following elements: 1. The manner in which an employee requesting accommodation can participate in the development of the individual accommodation plan. 2. The means by which the employee is assessed on an individual basis. 3. The manner in which the employer can request an evaluation by an outside medical or other expert, at the employer‘s expense, to determine if and how accommodation can be achieved. 4. The manner in which the employee can request the participation of a representative from their bargaining agent, where the employee is represented by a bargaining agent, or other representative from the workplace, where the employee is not represented by a bargaining agent, in the development of the accommodation plan. 5. The steps taken to protect the privacy of the employee‘s personal. 6. The frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done. 7. If an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee. 8. The means of providing the individual accommodation plan in a format that takes into account the employee‘s accessibility needs due to disability. | Accommodation Process Individual Accommodation Plan Functional Ability Form | Complete | January 1, 2017 | |
| 28 | 28. (3) Individual accommodation plans shall, a. if requested, include any information regarding accessible formats and communications supports provided, as described in section 26; b. if required, include individualized workplace emergency response information, as described in section 27; c. identify any other accommodation that is to be provided. | See section 26 & 27 | Ongoing | January 1, 2016 | |
| 29 | Return to Work Process | 29. (1) Every employer, other than an employer that is a small organization, a. shall develop and have in place a return to work process for its employees who have been absent from work due to a disability and require disability-related accommodations in order to return to work; and b. shall document the process | Process in place | Complete | January 1, 2017 |
| 29 | 29. (2) The return to work process shall, a. shall develop and have in place a return to work process for its employees who have been absent from work due to a disability and require disability-related accommodations in order to return to work; and b. use individual documented accommodation plans, as described in section 28, as part of the process. | Involve managers, HR and employee to solidify plan | Ongoing | January 1, 2016 | |
| 29 | 29. (3) The return to work process referenced in this section does not replace or override any other return to work process created by or under any other statute. | Part of checklist | Ongoing | January 1, 2016 | |
| 30 | Performance Management | 30. (1) An employer that uses performance management in respect of its employees shall take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when using its performance management process in respect of employees with disabilities. | Need to keep individual accommodation plan in mind | Ongoing | January 1, 2016 |
| 31 | Career Development & Advancement | 31. (1) An employer that provides career development and advancement to its employees shall take into account the accessibility needs of its employees with disabilities as well as any individual accommodation plans, when providing career development and advancement to its employees with disabilities. | Need to keep individual accommodation plan in mind | Ongoing | January 1, 2016 |
| 32 | Redeployment | 32. (1) An employer that uses redeployment shall take into account the accessibility needs of its employees with disabilities, as well as individual accommodation plans, when redeploying employees with disabilities. | Need to keep individual accommodation plan in mind | Ongoing | January 1, 2016 |