Accessibility Standards for Customer Service Policy and Procedure: Providing Services to People with Disabilities
Preamble:
Freeman is committed to excellence in serving all customers including people with disabilities.
Scope:
The following applies to all Freeman Branches across Ontario as well as any employee working in Ontario.
Policy:
We will strive at all times to provide our services in a way that respects the dignity and independence of people with disabilities. We are also committed to giving people with disabilities the same opportunity to access our services and allowing them to benefit from the same services, in the same place and in a similar way as other customers.
Procedure:
We will carry out our functions and responsibilities in the following areas:
Communication
We will communicate with people with disabilities in ways that take into account their disability. We will not make any assumptions of the individual’s disability without notice from the customer.
Assistive Devices
We are committed to serving people with disabilities who use assistive devices to obtain, use or benefit from our services.
Use of Service Animals and Support Persons
We are committed to welcoming people with disabilities who are accompanied by a service animal or support person on the parts of our premises that are open to the public. At no time will a person with a disability who is accompanied be prevented from having access to his or her support person or service animal while on our premises. If we cannot easily identify that the animal is a service animal, we will ask the person to provide documentation from a regulated health professional that confirms the person needs the service animal for reasons relating to their disability. We will respect that service animals are not pets and shall not be communicated with or touched. In certain cases, we may require a person with a disability be accompanied by a support person for health and safety reasons. Before making a decision, we will consult with the person with a disability to understand their needs, consider health or safety reasons based on available evidence and determine if there is no other reasonable way to protect the health or safety of the person or others on the premises.
Notice of Disruption
We will provide reasonable notice, when our facilities or services that people with disabilities rely on to access or use our services are temporarily disrupted.
Training:
Freeman will provide training to all employees or all others who deal with the public on their behalf. Training for the procedures above will include:
- An overview of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard
- Freeman’s Accessible Customer Service policy and procedure
- How to interact and communicate with people with various types of disabilities
- How to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person
- What to do if a person with a disability is having difficulty in accessing Freeman’s goods and services
Feedback process:
Customers who wish to provide feedback on the way Freeman provides its services to people with disabilities can do so by emailing Lesley Dolan at [email protected]. All feedback will be directed to Donovan Watson, Controller. Complaints will be addressed according to our regular complaint management procedures. Any policy of Freeman that does not respect and promote the dignity and independence of people with disabilities will be modified or removed. Revised June 13, 2016
Accessibility Policy Integrated Accessibility Standards
Statement of Commitment
Freeman Expositions, Ltd (“Freeman”) is committed to meeting the accessibility needs of people with disabilities in a timely manner. Freeman has established an accessibility policy and a multi-year accessibility plan to meet its obligations under Regulation 191/11, “Integrated Accessibility Standards” (“Regulation”) under the Accessibility for Ontarians with Disabilities Act, 2005.
The Freeman vision for accessibility is that people with disabilities, visible or invisible, are given the same opportunity as others to obtain and benefit from services offered by Freeman. Freeman’s goal is to make reasonable efforts to provide services in such a way that the key principles of independence, dignity, integration and equality of opportunity for persons with disabilities are respected.
Application
This policy applies to all employees, volunteers and agents of Freeman who interact with Freeman’s current and prospective employees, volunteers, agents, customers, clients, suppliers, and any other users of Freeman’s services.
Multi-Year Accessibility Plan
Freeman’s Multi-Year Accessibility Plan outlines a phased-in strategy to prevent and remove barriers and meet its requirements under the Regulation. Freeman will post the plan on its website and will provide it in an accessible format upon request. The plan will be reviewed and updated at least once every five years.
Training
By January 1, 2015, Freeman will ensure that training is provided to all employees, and volunteers, and all persons who participate in developing Freeman’s polices, on the requirements of the accessibility standards referred to in the Regulation and on the Human Rights Code as it pertains to persons with disabilities. Training will be provided as soon as practicable.
If any changes are made to this policy or the requirements, training will be provided to include those changes. Freeman shall maintain a record of the dates when training was provided and the number of individuals to whom it was provided. Freeman shall ensure that others that provide goods, services or facilities on behalf of the organization have had training.
Information and Communications Standard
Feedback Processes
By January 1, 2015, Freeman will ensure that its processes for receiving and responding to feedback are accessible to persons with disabilities by providing or arranging for the provision of accessible formats and with communication supports upon request. Freeman will notify the public about the availability of accessible formats and communication supports.
Accessible Formats and Communication Supports
By January 1, 2016, Freeman will, upon request, provide or arrange for accessible formats and communication supports for persons with disabilities as follows:
- In a timely manner that takes into account the person’s accessibility needs due to a disability;
- At a cost that is no more than the regular cost charged to other persons;
- Consult with the person making the request and determine suitability of an
accessible format or communication support; - Notify the public about the availability of accessible formats and communication
supports.
Unconvertible Information or Communications
If Freeman determines that information or communications are unconvertible, Freeman will provide the person requesting the information or communication with,
(a) an explanation as to why the information or communications are unconvertible; and
(b) a summary of the unconvertible information or communications. Information or communications are unconvertible if,
(a) it is not technically feasible to convert the information or communications; or
(b) the technology to convert the information or communications is not readily available.
Website Accessibility
Where practicable, by January 1, 2014, Freeman will make any new internet website and web content on those sites conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 initially at Level A and increasing to Level AA. By January 1, 2021 all internet website and web content backdated to 2012 will conform with WCAG 2.0 Level AA.
Employment Standard
Freeman will comply with the requirements of the Employment Standards in the Regulation by January 1, 2016. The Employment Standards apply in respect of employees, and not volunteers or other non-paid individuals.
Recruitment
Freeman will notify employees and the public about the availability of accommodations for applicants and employees, as the case may be with disabilities as follows:
- In its recruitment processes;
- During the recruitment process, when job applicants are individually selected to
participate in an assessment or selection process; - If a selected applicant requests an accommodation, Freeman will 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; - When making offers of employment to a successful applicant.
Employee Notification
Freeman 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 that take into account an employee’s accessibility needs due to a disability. Such information will be provided as follows:
- To new employees as soon as practicable after they begin their employment;
- To existing 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 a disability.
Accessible Formats and Communication Supports
Upon request by an employee with a disability, Freeman will consult with the employee to provide or arrange for the provision of accessible formats and communication supports for:
- Information that is needed in order to perform the employee’s job; and
- Information that is generally available to employees in the workplace.
Freeman will consult with the employee making the request in determining the suitability of an accessible format or communication support.
Individual Accommodation Plan (IAP)
Freeman will develop and have in place a written process for developing a documented individual accommodation plan for employees with a disability. The process will include the following elements:
- The manner in which an employee requesting accommodation can participate in the development of the individual accommodation plan.
- The means by which the employee is assessed on an individual basis.
- The manner in which the employer can request an evaluation by an outside medical or other expert, at the employer’s expense, to assist the employer in determining if accommodation can be achieved and, if so, how accommodation can be achieved.
- 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.
- The steps taken to protect the privacy of the employee’s personal information.
- The frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done.
- If an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee.
- The means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs due to disability.
Return to Work
Freeman will have in place a return to work process for employees who have been absent from work due to a disability and require disability-related accommodation in order to return to work. Such processes shall be documented and must outline the steps that Freeman will take to facilitate the return to work and include an individual accommodation plan.
Performance Management, Career Development and Advancement and Redeployment
Freeman will take into account the accommodation needs and/or individual accommodation plans of employees when:
- Using performance management processes;
- Providing career development and advancement information;
- Redeploying employees in lieu of a layoff.
Workplace Emergency Response Information
Freeman shall provide individualized workplace emergency response information to employees who have a disability in accordance with the following elements:
- 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;
- If the employee who receives an individual workplace emergency response information requires assistance and with the employee’s consent, Freeman shall provide the workplace emergency information to the person designated by Freeman to provide assistance to the employee;
- As soon as practicable after becoming aware of the need for accommodation due to the employee’s disability;
- Review the individualized workplace emergency response information when the employee moves to a different location in the organization, when overall accommodations needs or plans are reviewed and when Freeman reviews its general emergency response policies.
Multi-Year Accessibility Plan – Integrated Accessibility Standards
| Activity | Department | Compliance Date in Integrated Accessibility Standards Regulation |
|---|---|---|
| Policies & Procedures | ||
| Create Policies with Statement of Organizational Commitment in written form | — | January 1, 2014 |
| Make available to the Public | — | January 1, 2014 |
| Accessibility Plan – Multi Year | ||
| Develop Accessibility Plan | — | January 1, 2014 |
| Accessibility Plan – Post to Freeman website | — | January 1, 2014 |
| Prepare and Annual Status Report in accordance with section 4 of the AODA | — | December 31, each year |
| Review every 5 years | — | Next review December 2019 |
| Provide in alternative format | — | — |
| Training | ||
| All employees & volunteers, policy developers, those providing goods or services on behalf of organization regarding Integrated Accessibility Standards Regulation and Human Rights Code. | — | January 1, 2015 |
| Develop training content | — | — |
| Create training schedule | — | — |
| Retain record of attendance at training on each date | — | — |
| Information & communications | ||
| If Freeman prepares emergency procedures, plans or public safety information and makes the information available to the public, Freeman will provide the information in an accessible format or with appropriate communication supports, as soon as practicable, upon request. | — | January 1, 2012 |
| Assess training resources and materials available in an accessible format and process for purchasing, obtaining or arranging alternative formats for customers, clients and suppliers. | — | January 1, 2013 |
| Freeman will ensure that its processes for receiving and responding to feedback are accessible to persons with disabilities by providing or arranging for the provision of accessible formats and with communication supports upon request. A review of feedback processes and accessibility will be completed. Freeman will notify the public about the availability of accessible formats and communication supports. | — | January 1, 2015 |
| Provide accessible formats and communication supports upon request to the public in a timely manner at a cost that is no more than the regular cost charged to other persons. | — | January 1, 2016 |
| Freeman websites and content will comply with WCAT 2.0 Level A. | — | January 1, 2014 |
| All Freeman internet websites and web content will comply with WCAG 2.0 Level AA | — | January 1, 2021 |
| Employment | ||
| Workplace Emergency Response for staff. | — | January 1, 2012 |
| Recruitment – notify employees and public regarding availability of accommodation. | — | January 1, 2016 |
| Notify applicant of availability of accommodation upon request for assessments or selection process. | — | January 1, 2016 |
| Inform employees of policies regarding job accommodations. | — | January 1, 2016 |
| Providing accessible formats and communication supports to perform job | — | January 1, 2016 |
| Documented Individual Accessibility Plan. | — | January 1, 2016 |
| Create a return to work process. | — | January 1, 2016 |
| Performance management takes into account an employee’s accessibility needs. | — | January 1, 2016 |
| Career development and advancement process takes into account accessibility needs. | — | January 1, 2016 |
| Redeployment process, if any exist at Freeman, takes into account accessibility needs. | — | January 1, 2016 |
TOR01: 5720149: v2
