Meeting Accessibility Standards: AODA
The new 2011 accessibility regulation requires GSS Security to ensure alignment of its accessibility policies with Accessibility for Ontarians with Disabilities Act (AODA) legislation in its multi-year accessibility plan.
GSS Security Statement of Commitment to Creating an Accessible Company gives guidance to the delivery of Company services to people with disabilities, in compliance with requirements of Provincial legislation. (Accessibility Standards for Customer Service, O. Reg. 429/07, Integrated Accessibility Standards, O.Reg.191/11, established under the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11.)
This Statement applies to all Company employees, volunteers, and third party contractors who deal with the public on behalf of the Company, and those who are involved in Company policy and program development.
Establishment of Accessibility Plans and Policies
GSS Security shall produce a multi-year Accessibility Plan. The plan will be posted on GSS Security website and made available in accessible formats upon request. The Accessibility Plan will be reviewed and updated at least once every five years.
The Company maintains policies on how it shall meet AODA requirement and will provide policies in an accessible format upon request.
Accessibility in Procurement
When procuring goods, services, the Company shall incorporate accessibility criteria and features, unless it is not feasible (practicable) to do so. If not practicable, the Company shall provide an explanation, upon request. Accessibility criteria, guidelines, and checklists have been developed as resources for Company employees.
General Training Requirements
Company employees, volunteers, all those who participate in developing GSS Security policies and those who provide goods, services or facilities on GSS Security’s behalf shall be required to undergo training on the requirements of the AODA accessibility standards and on the Ontario Human Rights Code as it relates to people with disabilities.
Accessible Customer Service Standards
Company employees, volunteers and third party contractors shall accommodate the use of service animals by people with disabilities who are accessing Company services, programs, and facilities unless the animal is otherwise excluded by law, such as food preparation areas as prohibited by Food Premises, R.R.O. 1990, Reg. 562 under the Health Protection and Promotion Act, R.S.O. 1990, c. H.7.
A guide dog is defined in Section One of the Blind Persons' Rights Act. To be considered a service animal under the Customer Service Standard, it must be readily apparent that the animal is being used because of a person's disability or the person with a disability must provide a letter from a physician or nurse confirming that it is required because of his or her disability.
Where a person with a disability accessing Company services, programs or facilities is accompanied by a support person, Company employees, volunteers, and third party contractors shall ensure that both persons are permitted to enter the premises together and shall ensure that the person with a disability can access the support person while on the premises.
A support person is a person who accompanies the person with a disability in order to help with communication, mobility, personal care or medical needs or with access to goods or services. The support person can be a paid support worker, volunteer, a friend or a family member.
When communicating with a person with a disability, Company employees, volunteers, and third party contractors shall do so in a manner that respects the person's disability.
Notice of service disruption
If there is a temporary disruption in the availability of services, programs, and facilities used by persons with disabilities (e.g., temporary loss of elevator service), the Company shall notify the public of the reason for the disruption, the date(s) of disruption, its anticipated duration and a description of alternative facilities or services, if any, that are available. Such notice may be provided by a variety of methods, depending on the circumstances, and may include postings in conspicuous places at the affected premises, other Company facilities, and the GSS Security website, as well as by other means that will ensure that the notice reaches those persons potentially affected by the temporary disruption.
Training - Contractors, Consultants and Service Providers
The Company shall ensure that Company employees and volunteers who deal with the public on behalf of the Company, and those who are involved in Company policy and program development receive training on accessible customer service.
Third party contractors who deliver goods and services on behalf of the Company are also required to ensure that they meet the legislative requirements of accessible customer service.
Training includes information on the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11 and the requirements of the Accessibility Standards for Customer Service, O. Reg. 429/07.
Managers and supervisors shall ensure that training records are maintained, including dates when training is provided and the number of employees who received training.
Customer Service training can take various forms as a part of an orientation; or a separate training program. The training can be provided through handouts at an orientation session, a mandatory online module, in a classroom setting, or through other formats.
The Company shall ensure that every area that interacts directly with the public develops and publishes a process for receiving and responding to feedback about how services and programs are delivered to people with disabilities.
Public feedback may be provided in person, by telephone, in writing or by electronic means. Feedback received by the Company of Toronto shall be responded to, documented and tracked.
The documents required by the Accessible Customer Service Standards (Guidelines for implementation and training requirements of Contractors, Consultants and Service Providers) shall be maintained on GSS Security website and provided to individuals, upon request, in the appropriate format.
The Company Operations Office is responsible for reviewing this Statement and accessibility requirements annually and recommending amendments to ensure on-going compliance with regulated accessibility standards and legislated obligations.
The Company Operation Office shall provide advice and direction on the implementation of this Statement.
Information and Communication Standards
The Company is to ensure that any process for receiving and responding to feedback is accessible to persons with disabilities by providing or arranging for the provision of accessible formats and communication supports. The public shall be notified about the availability of accessible formats and communication supports.
Accessible formats and communication supports
The Company will provide or arrange for the provision of accessible formats and communication supports for persons with disabilities, upon request. Accessible formats and communication supports shall be provided in a timely manner, taking into account, the person's accessibility needs to determine the suitability of an accessible format or communication support. The public shall be notified about the availability of accessible formats and communication supports.
Accessible formats may include but are not limited to, large print, recorded audio and electronic formats, Braille and other formats used by persons with disabilities.
Emergency procedures, plans or safety information
The Company shall provide public emergency procedures, plans, and public safety information to the public upon request, in an accessible format with appropriate communication supports in a timely manner.
Accessible websites and web content
Make internet websites and web content controlled directly by the Company or through a contractual relationship that allows for modification of the product, shall conform with World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 Level A initially and Level AA in accordance with the schedule set out in the AODA Integrated Accessibility Standards.
Web Content Accessibility Guidelines (WCAG) is an international standard for making websites and web content accessible through a series of technical checkpoints (Level A and Level AA) so that websites and content are increasingly accessible to a broader range of users with disabilities. Web accessibility involves understanding a broad spectrum of disabilities, including visual, auditory, physical, cognitive, speech, learning, language, and neurological disabilities.
GSS Security shall post information about the availability of accommodation for applicants with disabilities in its recruitment process. Job applicants who are selected for an assessment /interview shall be notified that accommodations are available for materials/processes used in selection, upon request. Successful applicants shall be notified about GSS Security policies for accommodating employees with disabilities.
The Company shall inform employees of policies used to support employees with disabilities, including policies on the provision of job accommodations that take into account an employee's accessibility needs due to a disability. The Company shall provide this information to new employees as soon as practicable after they begin their employment and provide updated information to employees whenever there is a change to existing policies on the provision of job accommodations.
Accessible formats and communication supports for employees
Upon the request of an employee with a disability, the Company shall consult with the employee to provide/arrange for the provision of accessible formats and communication supports for:
· information needed to perform the employee's job; and,
· for information that is generally available to employees in the workplace
The Company will consult with the employee making the request in determining the suitability of an accessible format or communication support.
Workplace Emergency Response Information
If an employee's disability is such that the individualized workplace emergency response information is necessary and the Company is aware of the need for accommodation, this information shall be provided to employees. In addition, this information shall be provided, with the person's consent, to the person designated to provide assistance. The information shall be reviewed when the employee moves to a different location, when the employee's overall accommodation needs or plans are reviewed and when the Company reviews its general emergency response plan.
Documented individual accommodation plans
A written process for the development and maintenance of documented individual accommodation plans shall be developed for employees with disabilities. If requested, the plans shall include individualized workplace emergency response information. Elements for the individual accommodation plans are set out in the AODA Integrated Accessibility Standards.
Return to work process
The Company shall have in place a documented return to work process for employees who are returning to work due to a disability and require disability-related accommodations. The return to work process shall outline the steps that the Company shall take to facilitate the return to work.
Performance Management and Career development and Redeployment
The Company shall take into account the accessibility needs of employees with disabilities as well as any individual accommodation plans when providing career development, performance management and when considering redeployment.
Emergency Preparedness and Response Policies
The Company shall make public emergency preparedness and response policies that provide for the safety of persons with disabilities; and upon request, provide them in an accessible format.
Legislative and administrative authorities
Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005.
Accessibility Standards for Customer Service, O. Reg. 429/07.
Integrated Accessibility Standards, O. Reg. 191/11.
Ontario Human Rights Code, R.S.O. 1990, c. H.19.
Compliance Resources: Accessibility Directorate of Ontario
Compliance Manual, October 2008
Guide to the Accessibility Standards for Customer Service, O. Reg. 429/07, January 2008
Training Resource, February 2009
Guide to the Integrated Accessibility Standards Regulation, July 2012