Accessibility Policy
Purpose
Scope
Definitions
Accessible Formats may include, but are not limited to, large print, recorded audio and electronic formats, braille, and other formats usable by persons with disabilities.
Accommodation means the special arrangement made or assistance provided so that persons with disabilities can participate in the experiences available to persons without disabilities. Accommodation will vary depending on the person’s unique needs.
Assistive Devices are supporting aids such as communication aids, cognition aids, personal mobility aids and medical aids (e.g., canes, crutches, wheelchairs or hearing aids).
Communication Supports are devices or tools to aid communication between two or more individuals and may include, but are not limited to, captioning, alternative and additional communication, plain language, sign language and other supports that help with effective communications.
Disability means (a) any degree of physical disability, ailment, malformation or disfigurement that is caused by bodily injury, birth defect or illness and may include but is not limited to 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 appliances 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. The definition includes disabilities of different severity, visible as well as non-visible disabilities, and disabilities the effects of which may come and go.
IASR means Integrated Accessibility Standards Regulation
Support Persons are any persons, whether a paid professional, volunteer, family member, or friend, who accompany a person with a disability in order to help with communications, personal care or medical needs, or with access to goods or services.
Service Animals are animals individually trained to do work or perform tasks for the benefit of a person with a disability.
Unconvertible means it is not technically feasible to convert the information or communication or that the technology to convert the information or communication is not readily available.
Web Content Accessibility Guidelines (WCAG) means the world wide web consortium recommendation dated December 2008 entitled “Web Content Accessibility Guidelines”.
Procedures
1. General Requirements
VHA shall use every effort to ensure that it and all its representatives meet the needs of people with disabilities in a respectful and timely manner. To do so, VHA shall:
- ensure equal access and participation for people with disabilities
- ensure that its information is communicated in an accessible manner
- ensure that it and its representatives follow the Customer Service Standard (see Section 2 below)
- ensure that it and its representatives follow the Integrated Accessibility Standard (see Section 3 below)
- ensure that its office premises are barrier free
- ensure its staff and potential staff are aware that accommodations can be made, upon request
- provide training and education with respect to accessibility and aspects of the Ontario Human Rights Code that relate to persons with disabilities
- remain committed to removing and preventing any barriers to accessibility by establishing and
- maintaining a multi-year accessibility plan
- establish and maintain processes for receiving and responding to feedback and ensure that those processes are provided in accessible formats, upon request
2. Customer Service Standard
VHA is committed to excellence in serving all clients, including people with disabilities, and will carry out functions and responsibilities as follows:
(a) Communication
VHA will communicate with people with disabilities in ways that take into account their disability and will work with the person to determine what method of communication is suitable for them.
VHA Staff who communicate with clients will be trained how to interact and communicate with people with various types of disabilities.
(b) Telephone Services
VHA is committed to providing fully accessible telephone service to clients. Employees who communicate with clients over the telephone will be trained to speak clearly and slowly and in plain language. Staff will offer to communicate with clients by e-mail or TTY relay services if telephone communication is not suitable to their communication needs or is not available.
(c) Assistive Devices
VHA is committed to providing fully accessible telephone service to clients. Employees who communicate with clients over the telephone will be trained to speak clearly and slowly and in plain language. Staff will offer to communicate with clients by e-mail or TTY relay services if telephone communication is not suitable to their communication needs or is not available.
(d) Billing
VHA is committed to providing accessible invoices to all clients. For this reason, invoices will be provided in alternative methods upon request and staff will answer any questions clients may have about the content of the invoice by telephone or e-mail.
(e) Use of Support Persons and Service Animals
VHA is committed to welcoming people with disabilities who are accompanied by a support person or a service animal into a VHA office building. At no time will a person with a disability who is accompanied by a support person or service animal be prevented from having access to his or her support person or service animal while on the premises.
If a client with a service animal is seeking to attend an area of the facility that is unable to be accessed by the service animal, we will discuss with the client why that exclusion may be necessary and determine other ways to ensure the same provision of goods or services.
(f) Notice of Temporary Disruption
VHA’s office buildings have the following features for people with disabilities:
- Elevator;
- Front entrance ramp;
- Powered door operator; and
- Wheelchair accessible bathrooms
In the event of a planned or unexpected disruption to those building’s features for people with disabilities, VHA will promptly post a notice. This notice will include:
- Reason for the disruption
- Anticipated length of time of the disruption
- Description of alternative facilities or services, if available
The notice will be posted on the front entrance doorway and at the front reception desk, if applicable.
(g) Training for Staff
VHA will ensure training is provided to every employee, contractor, vendor, policy developer and any other person who provides goods, services and/or facilities to clients on behalf of VHA.
The training will be provided within 3 months of such person obtaining a role that provides goods, services and/or facilities to VHA clients and if/when any significant changes are made to this Policy. VHA and/or its vendors, as applicable, will maintain accurate records of training delivered. Training will include:
- An overview of AODA, the requirements of the Customer Service Standard, the Integrated Accessibility Standard and any other applicable legislation
- VHA’s Accessibility Plan
- 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
- Overview of accessible features at VHA’s offices (for example, elevators, powered door at the front entrance and accessible washrooms)
- What to do if a person with a disability is having difficulty in accessing VHA’s goods, services or facilities
(h) Feedback Process
The goal of this policy is to meet expectations while serving those with disabilities. Comments on how well those expectations are being met are welcome and appreciated. Individuals who wish to provide feedback on the way VHA provides goods, services and/or facilities to people with disabilities can do so in a variety of ways:
- by e-mail: accessibility@vha.ca
- by fax: 416-482-8785
- by phone: 1-888-314-6622
- in person: 30 Soudan Avenue, Toronto Ontario M4S 1V6, 6th floor
If none of these are suitable methods to provide feedback or receive responses, individuals may request another method, at which time, VHA will consult with the individual to determine other methods taking into account the suitability of an accessible format or communication support.
All feedback will be directed to the appropriate department to investigate and a written response will be provided within 15 business days. Complaints will be addressed according to VHA’s regular complaint management process.
3. Integrated Accessibility Standards
(a) Procuring, Obtaining or Acquiring Goods, Services or Facilities
VHA will review accessibility criteria and features, where appropriate, when procuring, obtaining or acquiring goods, services or facilities as part of its commitment to accessibility.
(b) Information and Communications
VHA will create, provide and deliver information and communications in ways that are accessible to people with disabilities.
(i) Accessible Formats and Communication Supports
Upon request, VHA shall provide or arrange for accessible formats and communication supports to be made available, in a timely manner, for persons with disabilities. VHA shall consult with the person making the request to determine the suitability of an accessible format or communication support to be used. VHA shall do so at a cost that is no more than the regular cost charged to other persons.
If VHA determines that it is not technically feasible to convert the information or communications to the requested format or the technology to convert the information or communications is not readily available, VHA will provide the person making the request with an explanation as to why the information or communications are unconvertible along with a summary of the unconvertible information or communications.
(ii) Emergency Information
VHA’s emergency procedures, plans and public safety information shall provide the information in an accessible format or, upon request, with appropriate communication supports, as soon as practicable.
(iii) Website Accessibility
VHA shall make their internet website and web content conform with the WCAG 2.0, initially at Level A and increasing to Level AA, by January 1, 2021.
(c) Employment Standard
The Employment Standard under AODA builds upon the requirements of the Human Rights Code (Ontario) in relation to how VHA will provide accessibility throughout the employment cycle. It applies in respect to employees and does not apply to volunteers and other non-paid individuals, however, VHA will make equal effort to accommodate volunteers and other non-paid individuals.
(i) Recruitment and Hiring
VHA shall notify employees and the public about the availability of accommodations for applicants with disabilities during the recruitment process when job applicants are individually selected to participate in an assessment or selection process. If a selected applicant requests accommodation, VHA shall consult with the applicant and provide or arrange for the provision of a suitable accommodation that takes into account the applicant’s disability. VHA shall also notify successful applicants of the policies for accommodating employees with disabilities.
(ii) Employee Notification
VHA shall inform its employees of the policies available to support 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. Notification will be provided to new employees as soon as feasible after they begin their employment and to all employees whenever there is a change to existing policies on the provision of job accommodations due to a disability.
(iii) Accessible Formats and Communication Supports for Employees
Upon request by a VHA employee with a disability, VHA will consult with the employee to provide or arrange for the provision of accessible formats and communication supports with respect to:
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- Information that is needed in order to perform the employee’s job
- Information that is generally available to employees in the workplace
- The employee’s manager or HR will consult with the employee making the request in determining the suitability of an accessible format or communication support.
(iv) Individual Accommodation Plan (IAP)
Upon request, VHA shall develop a documented IAP for employees with a disability. The IAP shall be developed with the employee’s participation and, if requested, participation of a representative from the workplace chosen by the employee. The IAP shall be developed using the following protocols:
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- Assessment on an individual basis
- Identification of accommodations to be provided
- Timelines for the provision of accommodations
- If deemed necessary, an evaluation by outside medical or other expert, at VHA’s expense, to assist with determining accommodation and how to achieve accommodation
- Identification of steps to be taken to protect the privacy of the employee’s personal information;
- Frequency with which the IAP will be reviewed and/or updated and the manner in which the review will be done;
- If accommodation is denied, the reasons for denial are to be provided to the employee as part of the IAP process;
- Identification of any other accommodation that is to be provided.
- The format for the IAP must take into account the employee’s disability needs and any communication supports required and be produced in an accessible format.
(v) Return to Work
VHA has 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 for each returning employee and include an IAP, where appropriate.
(vi) Performance Management
VHA will take into account the accommodation needs and/or IAPs of its employees when:
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- Using performance management processes;
- Providing career development and advancement information;
- Using reassignment and redeployment procedures.
(vii) Workplace Emergency Response Information
Upon request, and as soon as feasible after becoming aware of the request, VHA will provide individualized workplace emergency response information to employees who have a disability if the disability is such that the individualized information is necessary. If the employee who receives an individualized workplace emergency response information requires assistance, and with that employee’s consent, VHA shall provide the workplace emergency information to a person designated by VHA to provide assistance to the employee in the event of a workplace emergency.
VHA shall review the individualized workplace emergency response information when the employee moves to a different location within the organization, when overall accommodations needs or plans are reviewed and when the employer reviews its general emergency response policies.
(d) Public Spaces
VHA shall incorporate accessibility into its public spaces that are newly constructed or redeveloped on and after January 1, 2017. VHA follows the requirements for the Design of Public Spaces (Accessibility Standards for the Built Environment Maintenance) for exterior paths of travel, accessible parking, and service-related elements.
Questions
Additional Resources
Related VHA Policies
B.10 VHA Vision Mission and Core Beliefs
B.60 Client Rights and Responsibilities
B.20 Code of Ethical Conduct
B.30 Valuing Diversity
D.12 Accessibility for Clients with Special Needs and Preferences
I.20 Early and Safe Return to Work
I.55 Positive Work Environment – No Discrimination or Harassment
Resources
AODA
Ontario Human Rights Code
Ontario Building Code Act, 1992