Integrated Accessibility Standards Regulation Policy

1.0 Purpose

This Policy is drafted in accordance with the Integrated Accessibility Standards Regulation (IASR) (Ontario Regulation 191/11) and addresses how the Ontario Trillium Foundation (OTF) achieves or will achieve accessibility by meeting the requirements of the Regulation. The requirements will be met within the timeframes set in the Regulation.

The requirements of the Regulation include:

• The establishment, implementation, maintenance and documentation of a multi-year accessibility plan, which outlines the OTF strategy to prevent and remove barriers and meet its requirements under this Regulation
• The incorporation of accessibility criteria and features when procuring or acquiring goods, services or facilities
• The incorporation of accessibility features when designing, procuring or acquiring self-service kiosks (not applicable to OTF)
• Training
• The specific requirements under the Accessible Information and Communications Standards and the Accessible Employment Standards

This Policy is supported by applicable procedures which outline the detailed processes and accommodations pursuant to this policy.

2.0 Policy

2.1 Statement of Organizational Accessibility Commitment

The Foundation is committed to the principles outlined in the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and to meeting the needs of people with disabilities, in a timely manner, through the implementation of the requirements of the Regulations under the AODA.

The core principles of the AODA - independence, dignity, integration, equality of opportunity for people with disabilities - are aligned with inclusion, one of the six strategic enablers, or building blocks, that help us achieve our mission. We support initiatives that remove barriers and promote or increase equitable access to social and economic participation in community life.

OTF is committed to promoting a healthy work environment where employees can participate fully in all aspects of their job. We offer a barrier-free workplace that is accessible to all employees, stakeholders and people with disabilities.

The Foundation has a comprehensive Accessibility Policy and a range of accessibility services and supports for people with disabilities. OTF also has a Five-year Accessibility Plan which outlines our strategy to provide accessible customer service, accessible information and communications, accessible employment, and barrier-free access to our offices and meetings.

2.2 Mandatory Requirements under the IASR

General Requirements

Accessibility Plans

• The Five-year OTF Accessibility Plan (“the Plan”) outlines the strategy to prevent and remove barriers between 2023 and 2028, and to meet the Foundation’s requirements under the Regulation
• The Plan is posted on the website, otf.ca, and will be provided in alternate formats upon request
• The Plan will be reviewed and updated annually (as required) and a new plan created at least every five years or whenever the current Plan expires
• The Plan has been created in consultation with OTF staff and with public input
• An annual status report on the progress of measures taken to implement the Plan will be posted on the website and in alternate formats upon request

Procuring or Acquiring Goods, Services or Facilities

• Accessibility criteria are considered and features are incorporated when procuring or acquiring goods, services or facilities, except where it is not practicable to do so
• Where it is not practicable to incorporate accessibility criteria and features when procuring or acquiring goods, services or facilities, OTF will provide, upon request, an explanation as to the rationale behind this decision

Training

• OTF ensures that training is provided on the requirements of accessibility standards referred to within the Integrated Accessibility Standards Regulation (Ontario Regulation 191/11) and on the Human Rights Code as it pertains to persons with disabilities for:
  • All employees and volunteers
  • All persons who participate in developing Foundation’s policies; and
  • All other persons who provide goods, services or facilities on behalf of OTF (e.g. suppliers and consultants)
• The training provided is appropriate to the duties of employees, volunteers and other persons
• Training is provided as practicable to employees, volunteers and other persons
• Where there are changes to the Integrated Accessibility Standards Regulation Policy, training will be provided regarding to those changes
• OTF will maintain a record of the dates of when training is provided and the number of individuals to whom it was provided

2.3 Accessible Information and Communications Standards

Feedback

• The OTF feedback process is accessible to persons with disabilities and does provide or arrange for the provision of accessible formats and communication supports upon request
• The public is notified regarding the availability of accessible formats and communication supports

Accessible Formats and Communication Supports

• OTF will, upon request, provide or arrange for the provision of accessible formats and communication supports for persons with disabilities
  • In a timely manner that respects the person’s accessibility needs due to disability; and
  • At a cost that is no more than the regular cost charged to other persons
• OTF will consult with the person making the request to determine the suitability of an accessible format or communication support
• OTF notifies the public about the availability of accessible formats and communication supports

Accessible Websites and Web content

• OTF’s public websites and web content conform with the WCAG 2.0, in accordance with the Integrated Accessibility Standards Regulation:
  • As of January 1, 2021, all Internet, intranet and web content will conform with the WCAG 2.0 Level AA, other than 1.2.4 Captions (Live) and 1.2.5 Audio Descriptions (pre-recorded)
  • Websites and web content, including web-based applications, that OTF controls directly or through a contractual relationship that allows for modification of the product, are included in this timeline, where practicable
• In determining practicability, consideration will be given to the availability of commercial software, or tools or both, and whether planned or initiated implementation timelines will be significantly impacted

2.4 Accessible Employment Standards

Recruitment

• OTF notifies its employees and the public about the availability of accommodations for applicants with disabilities in its recruitment processes
• During a recruitment process, applicants who are individually selected to participate in an assessment or selection process, are notified that accommodations are available upon request in relation to the materials or processes used
• If a selected applicant requests an accommodation, OTF consults with the applicant, having regard for the applicant’s accessibility needs, on the provision of a suitable accommodation
• When making an offer of employment, OTF will notify the successful applicant of its policies for accommodating employees with disabilities

Informing Employees of Supports

• The Foundation informs its employees of its policies used to support employees with disabilities, including, but not limited to, policies on job accommodations that take into account the employee’s accessibility needs due to a disability
  • New employees will be informed as soon as practicable after they begin their employment
  • Where there are changes to existing policies on the provision of job accommodations, all employees will be provided with updated information

 Accessible Formats and Communication Supports for Employees

• Where an employee makes a request, the Foundation will consult with them to provide or arrange for the provision of accessible formats and communication supports for:
  • Information that is needed in order for the employee to perform their job; And
  • Information that is generally available to employees in the workplace
• OTF will consult with the employee making the request to determine the suitability of an accessible format or communication support

Workplace Emergency Response Information

• The Foundation provides individual workplace emergency response information to employees who have a disability:
  • Where the disability is such that individual information is necessary; and
  • Where the Foundation is aware of the need for accommodation due to the employee’s disability
• An employee who has requested accommodation will be provided with the necessary supports.
• If an employee with individualized workplace emergency response information requires assistance and provides consent, OTF will provide the individualized information to the person designated by the Foundation to provide assistance to the employee
• Individualized information is provided as soon as practicable after the Foundation becomes aware of the need for accommodation due to an employee’s disability
• The Foundation will review the individualized workplace emergency response information:
  • When the employee moves to a different location
  • When the employee’s overall accommodation needs or plan are reviewed
  • When OTF reviews its general emergency response policies

Documented Individual Accommodation Plans

• The Foundation will develop a written process for the development of individual accommodation plans for employees with disabilities

Return to Work

• OTF has a documented return to work process for employees who have been absent from work due to a disability and require disability-related accommodations in order to return to work. The steps of this process are:
  • The Case Manager and/or Rehabilitation Consultant at the benefit insurer will work with the employee and the employee’s doctor to have the employee return to work when medically ready to do so;
  • Prior to the employee’s return date, the Case Manager will contact OTF and suggest a schedule for the accommodation plan for the employee’s return to work (modified hours, modified duties, etc.);
  • A meeting will take place with the employee, their OTF Manager and Rehabilitation Consultant to discuss the schedule and accommodation details;
  • The employee returns to work as per the schedule if hours are modified;
  • The OTF Manager will arrange training or refresh training if the employee has been on leave for an extended period;
  • HR and the benefit insurer will follow up with the employee and the OTF Manager regularly to ensure a successful return to work.

Performance Management

• The accessibility needs of employees with disabilities, and individual accommodation plans are taken into account in the use of the Foundation’s performance management program.

Career Development and Advancement

• The accessibility needs of employees with disabilities, and individual accommodation plans are not an impediment when career development and advancement is considered.

3.0 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 arrangements made or assistance provided so that people with disabilities can participate in the experiences available to people without disabilities.  Accommodation will vary depending on the person’s unique needs.

Communication supports may include, but are not limited to, captioning, alternate and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications.

Communication means the interaction between two or more persons or entities, or any combination of them, where information is provided, sent or received.

Conversion-ready refers to an electronic or digital format that facilitates conversion into an accessible format.

Disability is:

• 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 service animal or on a wheelchair or other remedial appliance or device
• A condition of mental impairment or a developmental disability
• A learning disability or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language
• A mental disorder
• An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997

Information includes data, facts and knowledge that exist in any format, including text, audio, digital or images, and that convey meaning

Volunteer may include a person who voluntarily undertakes a task on behalf of the Foundation.