In 2005, the Ontario government passed the Accessibility for Ontarians with Disability Act (AODA) with the clear objective of providing full “accessibility” for Ontarians with disabilities by 2025. To achieve this goal, the government has developed accessibility standards that all private, non-for-profit and public sector employers must meet. Under this Act, the Ontario government has put in place accessibility standards in place in the following areas:
- Customer Service
- Information and communications
- Built environment
Accessibility standards for customer service came into full force for non-for-profit employers on January 1, 2012. The accessibility standard for customer service applies to all people or organizations in Ontario that provide goods or services, and have one or more employees. It is the government’s intent that by meeting these standards, our society as a whole will eventually eliminate the barriers to access facing those citizens with disabilities.
- 1 in every 7 Ontarians currently have a disability
- Less than 2% of Canadians with a disability require the use of a wheelchair
- The majority of disabilities are not readily apparent and may include invisible disabilities such as: anxiety, asthma, developmental disabilities and diabetes
- As the population ages it is expected that 1 in 5 Ontarians will have a disability
The AODA and governing regulations are enforced by the Ministry of Community and Social Services who can apply monetary penalties to individuals as well as companies for violations to the Act depending on the severity of the infringement.
*Any notation to Advocis or the Association within this document refers to Advocis & Affiliates.
Advocis and Affiliates are committed to excellence in serving all customers including people with disabilities. This policy is intended to meet the requirements of Integrated Accessibility Standards, Ontario Regulation 191/11 and applies to the provision of goods and services to the public or other third parties, not to the goods themselves.
Upon request Advocis will provide or arrange for the provision of accessible formats of this policy and related documents for persons with disabilities in a manner that takes into account the person’s accessibility needs.
Definition of Disability
The term disability as defined by the Accessibility for Ontarians with Disabilities Act, 2005, and the Ontario Human Rights Code, refers to:
- 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 coordination, 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 appliance or device;
- a condition of mental impairment or a developmental disability;
- a learning disability, or dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
- a mental disorder; or
- an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.
Examples of disabilities include but are not limited to:
- Hearing impaired
- Vision impaired
- Speech impaired
- Restricted mobility
- Mental health, intellectual disability, learning disability
- Prone to seizures
The definition also includes disabilities of different severity, visible as well as non-visible disabilities and disabilities of which the effects may come and go, e.g.:
- A person with arthritis has a disability that over time may increase in severity
- A person with a brain injury has a disability that is not visible
- A person with multiple sclerosis has a disability that causes them to experience periods when the condition does not have an effect on their daily routine and other periods when it does
Employers are required to make every reasonable effort to ensure that their policies, procedures and practices are consistent with the principles of dignity, independence, integration and equal opportunity. It is important for Advocis’ staff to remember that customers have different needs and learning what those needs are requires patience and a willingness to learn. The customer service standard is geared to eliminating stereotypes and discrimination of people with disabilities by setting the expectation for all providers of goods and services to consider the needs of their customers and to make any required changes.
When assisting a customer with a disability, all Advocis employees and volunteers should follow these four guiding principles:
The freedom of control or influence such as allowing a customer with a disability to make their own decisions, to complete the task at their own pace, in their own way, maintaining their independence.
Treating all customers with a disability as valuable and deserving of effective and full service just as any other customer. No customer with a disability should be treated as an after thought nor should they be expected to accept lesser quality service.
To provide services to people with disabilities in the same fashion as other customers. Integration means that policies, practices and procedures are designed to be accessible to everyone including people with disabilities.
A person with a disability has the same opportunity, benefits, options, chances and results as any other person. In the case of services it means that people with disabilities have the same opportunity to benefit from the way you provide goods or services as others. It should not be an inconvenience for a person with a disability to access goods or services, nor should they have to accept lesser quality service or more inconvenience.
This policy applies to the provision of goods and services at the premises operated by Advocis.
This policy applies to employees, volunteers, agents and/or contractors who deal with the public or other third parties that act on behalf of Advocis, including when the provision of goods and services occurs off the premises of Advocis such as in: delivery services, call centers, vendors, drivers, catering and third party marketing agencies.
The section of this policy that addresses the use of guide dogs, service animals and service dogs only applies to the provision of goods and services that take place at premises and operated by Advocis.
This policy shall also apply to all persons who participate in the development of Advocis’ policies, practices and procedures governing the provision of goods and services to members of the public or third parties.
Barriers are defined as something that keeps a person with a disability from fully participating in all aspects of society. It is important that employees recognize these barriers.
Barriers can be visible or invisible and include the following:
- Architectural or structural
- Information and communication
Attitude is a barrier that refers to the way people think and behave. In most instances, attitude is often the most difficult barrier to overcome however; it is definitely within our power to do so with the assistance of education and training. For example, not understanding how a hearing loss affects a person’s ability to communicate can lead to stereotypes and misconceptions about the person’s mental health.
Architectural and Structural
These types of barriers result from the design and layout of a building or facility. Stairs, doorways, shelves, the width of hallways or the space around furniture can all be considered architectural barriers. For example, stairs and narrow corridors can make it difficult for someone in a wheelchair to navigate throughout a facility.
Information and Communication
Information and communication are shared between people in many different forms such as verbal, written or through pictures or symbols. It helps to first consider how the disability affects the way the person expresses, receives and processes information then you can adjust or modify the way you interact and communicate with them. For example, the use of technical jargon may be confusing, or make it difficult or impossible to convey or receive a message.
Technology has advanced tremendously and in some cases, can actually be an aid/assistive devise however in other cases technology can become a barrier if not set up with accessibility in mind. For example, an ATM allows us to use technology to access our banking however if they are not set up with accessibility in mind, they can be impossible for those with disabilities to use.
Systemic barriers result from the way we are accustomed to doing business and are often unintentional but occur when a policy or procedure is set up without first considering the needs of all potential customers. For example, a store that plays loud music to attract customers makes it extremely difficult for a person using a hearing aid to hear what the staff is saying.
Customer Service Standards
In accordance with the Integrated Accessibility Standards, Ontario Regulation 191/11, this policy addresses the following Customer Service Standards:
- The Provision of Goods and Services to Persons with Disabilities
- The Use of Assistive Devices
- The Use of Guide Dogs, Service Animals and Service Dogs
- The Use of Support Persons
- Notice of Service Disruptions
- Customer Feedback
- Notice of Policy Availability
The Provision of Goods and Services to Persons with Disabilities
Advocis will make every reasonable effort to ensure that its policies, practices and procedures are consistent with the principles of dignity, independence, integration and equal opportunity (as defined under Guiding Principles above). It is the expectation that all Association staff and volunteers will adhere to these principles by:
- ensuring that all customers receive the same value and quality of service
- allowing customers with disabilities to do things in their own ways, at their own pace when accessing goods and services as long as this does not present a safety risk
- using alternative methods when possible to ensure that customers with disabilities have access to the same services, in the same place and in a similar manner
- taking into account individual needs when providing goods and services
- communicating in a manner that takes into account the customer’s disability
The Use of Assistive Devices
An assistive device is a technical aid, communication device or other instrument that is used to maintain or improve the functional abilities of people with disabilities. Personal assistive devices are typically devices that customers bring with them to assist in hearing, seeing, communicating, moving, breathing, remembering and/or reading. Some examples of assistive devices include, wheelchairs, scooter, screen readers, sign language interpreter, oxygen tank, monocular, hearing aid, cane/crutches, TTY (teletypewriter), artificial limb, white cane and speech generating device.
Only in cases where the assistive device presents a safety concern or where accessibility limitations might be an issue will other reasonable measures be used to ensure the access of goods and services. For example, open flames and oxygen tanks cannot be near one another. Therefore, the accommodation of a customer with an oxygen tank may involve ensuring the customer is in a location that would be considered safe for both the customer and business.
All employees should be aware that any person with a disability may use their own assistive device as required when accessing goods or services provided by Advocis and Affiliates unless it poses a safety concern. The Association does not provide assistive devices for use by its customers.
The Use of Guide Dogs, Service Animals and Service Dogs
Customer with a disability who is accompanied by a guide dog, service animal or service dog must be allowed access to premises that are open to the public unless otherwise excluded by law. “No pet” policies do not apply to guide dogs, service animals and/or service dogs.
A guide dog is defined as a highly-trained working dog that has been trained at one of the facilities listed in Ontario Regulation 58 under the Blind Persons’ Rights Act, to provide mobility, safety and increased independence for people who are blind.
As reflected in Ontario Regulation 191/11, an animal is a service animal for a person with a disability if:
- it is readily apparent that the animal is used by the person for reasons relating to his or her disability; or
- the person provides documentation from one of the following regulated health professionals confirming that the person requires the animal for reasons relating to the disability:
(i) A member of the College of Audiologists and Speech-Language Pathologists of Ontario.
(ii) A member of the College of Chiropractors of Ontario.
(iii) A member of the College of Nurses of Ontario.
(iv) A member of the College of Occupational Therapists of Ontario.
(v) A member of the College of Optometrists of Ontario.
(vi) A member of the College of Physicians and Surgeons of Ontario.
(vii) A member of the College of Physiotherapists of Ontario.
(viii) A member of the College of Psychologists of Ontario.
(ix) A member of the College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario. O. Reg. 165/16, s. 16
As reflected in Health Protection and Promotion Act, Ontario Regulation 562 a dog other than a guide dog for the blind is a service dog if:
- it is readily apparent to an average person that the dog functions as a service dog for a person with a medical disability;
- or the person who requires the dog can provide on request a letter from a physician or nurse confirming that the person requires a service dog.
If a guide dog, service animal or service dog is excluded by law (see applicable laws below) Advocis will offer alternative methods to enable the person with a disability to access goods and services, when possible (e.g., securing the animal in a safe location and offering the guidance of an employee).
Food Safety and Quality Act 2001, Ontario Regulation 31/05: Animals not intended for slaughter or to be euthanized are not allowed in any area or room of a meat plant. It also makes an exception for service dogs to allow them in those areas of a meat plant where food is served, sold or offered for sale to customers and in those areas that do not contain animals or animal parts and are not used for the receiving, processing, packaging, labelling, shipping, handling or storing of animals or parts of animals.
The Health Protection and Promotion Act, Ontario Regulation 562 Section 60, normally does not allow animals in places where food is manufactured, prepared, processed, handled, served, displayed, stored, sold or offered for sale. It does however allow guide dogs and service dogs to go into places where food is served, sold or offered for sale.
Dog Owners’ Liability Act, Ontario: If there is a conflict between a provision of this Act or of a regulation under this or any other Act relating to banned breeds (such as pit bulls) and a provision of a by-law passed by a municipality relating to these breeds, the provision that is more restrictive in relation to controls or bans on these breeds prevails.
Recognizing a Guide Dog, Service Dog and/or Service Animal
If it is not readily apparent that the animal is being used by the customer for reasons relating to his or her disability, Advocis may request verification from the customer.
Verification may include;
- a valid identification card signed by the Attorney General of Canada
- a certificate of training from a recognized guide dog or service animal training school
- a letter from a regulated health professional confirming that the person requires the animal for reasons related to the disability
Care and Control of the Animal
The customer that is accompanied by a guide dog, service dog and/or service animal is responsible for maintaining care and control of the animal at all times.
If a health and safety concern presents itself for example in the form of a severe allergy to the animal, Advocis will make all reasonable efforts to meet the needs of all individuals.
The Use of Support Persons
As reflected in Ontario Regulation 191/11, a support person means, in relation to a person with a disability, another person who accompanies him or her in order to help with communication, mobility, personal care, medical needs or access to goods and services.
If a customer with a disability is accompanied by a support person, Advocis will ensure that both persons are allowed to enter the premises together and that the customer is not prevented from having access to the support person.
In extenuating circumstances there may be times where seating and availability prevent the customer and support person from sitting beside each other. In these situations Advocis will make every reasonable attempt to resolve the issue.
In situations where confidential information may need to be discussed, consent must be obtained from the customer to ensure that the support person can be privy to such conversation where confidential information is discussed.
Notice of Disruptions in Service
Service disruptions may occur due to reasons that may or may not be within the control or knowledge of Advocis. In the event of any temporary disruptions to facilities or services that customer’s with disabilities rely on to access or use Advocis’ goods or services, all reasonable efforts will be made to provide advance notice. In some circumstances such as in the situation of unplanned temporary disruptions, advance notice may not be possible.
Notifications Will Include
In the event that a notification needs to be posted the following information will be included unless it is not readily available or known:
- goods or services that are disrupted or unavailable
- reason for the disruption anticipated duration
- a description of alternative services or options
A Service Disruption Notice form is attached for use in this event.
When disruptions occur Advocis will provide notice by one or all of the following options:
- posting notices in conspicuous places including at the point of disruption, at the main reception entrance, the nearest accessible entrance to the service disruption and/or on Advocis website
- contacting customers with appointments (by the applicable staff person or department)
- verbally notifying customers when they are making a reservation or appointment
- by any other method that may be reasonable under the circumstances
Customer Feedback Process
Feedback is one way the Association can determine how well we are doing in providing quality service to customers with disabilities and where there is an opportunity for improvement.
Advocis therefore offers the following methods of communication to provide positive or negative feedback on the service provided to customers with disabilities. Customers can contact Angeline Simbandumwe, Manager, Human Resources as follows;
- By Phone at – 416 342-9851
- By Fax at – 416 444-8031
- By Mail at – 10 Lower Spadina Ave, Suite 600, Toronto, ON, M5V 2Z2
- By E-mail at – email@example.com
Any Advocis customer that provides feedback will receive acknowledgement of their feedback, along with any resulting actions based on their concern or complaint submitted. Advocis will arrange for the provision of any response provided in an accessible format or with communication support, taking into account disability related accessibility needs, if requested.
The customer service standard requires employers to train staff and volunteers on providing customer service to people with disabilities. This training must be given to all staff, as well as third parties who act on behalf of a company. Training must also be given to anyone who develops polices, procedures and practices. Those who must be provided with training include employees, volunteers, agents and contractors or others who could reasonably be expected to:
- Interact with the public on behalf of Advocis
- Participate in developing Advocis policies, practices and procedures on providing goods or services to members of the public or third parties
This includes: salespersons, drivers, vendors, event operators, call centers as well as third party marketing agents.
As reflected in Ontario Regulation 191/11, regardless of the format, training will cover the following:
- A review of the purpose of the Accessibility for Ontarians with Disabilities Act, 2005
- A review of the requirements of the Accessibility Standards for Customer Service, Ontario Regulation 191/11
- Instructions on how to interact and communicate with people with various types of disabilities
- Instructions on how to use equipment or devices that are available at our premises or that we provide that may help people with disabilities
- Instructions on what to do if a person with a disability is having difficulty accessing your services
- Advocis policies, procedures and practices pertaining to providing accessible customer service to customers with disabilities
- Instructions on how to interact with people with disabilities who;
- use assistive devices
- require the assistance of a guide dog, service dog or other service animal
- require the use of a support person (including the handling of admission fees)
Training must be provided to all current employees and volunteers, including full-time, temporary, contract or student workers upon the commencement of their duties. Revised training will be provided in the event of changes to legislation, procedures and/or practices.
Record of Training
The customer service standard requires every organization keep a record of the training provided under this section including the dates on which training is provided and the number of individuals to whom it is provided.
Notice of Policy Availability
It is a requirement under the AODA customer service standard that employers notify customers that the documents required by this regulation be made available upon request and when applicable that it is in a format that takes into account the customer’s disability. If a customer requires a copy of this document in a different format than what is provided herein, please contact Angeline Simbandumwe. This document must be sufficiently detailed to address the issues required and to verify that we are in compliance with the requirements of the standard. The notice may be given by posting this information in a conspicuous place owned and operated by the employer or any such other method as is reasonable in the circumstances.
A copy of Advocis’ AODA Policy will be available upon request by any Advocis customer and is also available at the reception desk and on Advocis’ website.
Advocis is focused on eliminating discrimination and providing equal opportunities for all persons with a disability.
Implementing polices and procedures that provide accessible goods and services to our customers will increase customer satisfaction and essentially provide an accessible workplace for all Advocis customers.
A safe and healthy workplace, free from barriers simply makes good business sense.
Be Smart, Be Aware, Be Informed, Be Safe.
Advocis Disruption of Service Notification
Please put the following notification on Advocis Letterhead prior to posting.
Dear Valued Customers,
The (insert goods or services that are unavailable) will be out of service as (insert reason for disruption) from (insert appropriate date) until (if known, insert appropriate date).
The following alternative services and options are available:
- (list options)
We regret any inconvenience this may cause. If you have questions or concerns, please contact (Name, Title, E-mail, telephone).
Thank you for your understanding and patience, we appreciate your business.
Manager, Human Resources
The following TIPS on how to interact and communicate with people with various types of disabilities has been provided by the Ontario Ministry of Community and Social Services.
Being able to interact and communicate with people with disabilities is a big part of providing accessible customer service. Sometimes the best approach is to ask a person with a disability how you can best communicate with them.
There are many types and degrees of disability. Openly communicating and responding to your customers’ needs is the key to excellent customer service for all. Here are a few tips for interacting with people who have various disabilities.
People with Physical Disabilities
Only some people with physical disabilities use a wheelchair. Someone with a spinal cord injury may use crutches while someone with severe arthritis or a heart condition may have difficulty walking longer distances.
- When you know someone has vision loss, don’t assume the individual can’t see you. Many people who have low vision still have some sight
- Identify yourself when you approach and speak directly to the customer
- Ask if they would like you to read any printed material out loud to them (e.g., a menu or schedule of fees) When providing directions or instructions, be precise and descriptive
- Offer your elbow to guide them if needed
People Who Have Hearing Loss
People who have hearing loss may be deaf, deafened or hard of hearing. They may also be oral deaf – unable to hear, but prefer to talk instead of using sign language. These terms are used to describe different levels of hearing and/or the way a person’s hearing was diminished or lost.
- Once a customer has identified themselves as having hearing loss, make sure you are in a well-lit area where they can see your face and read your lips
- As needed, attract the customer’s attention before speaking. Try a gentle touch on the shoulder or wave of your hand
- If your customer uses a hearing aid, reduce background noise or move to a quieter area
- If necessary, ask if another method of communicating would be easier (e.g., using a pen and paper)
People Who Are Deafblind
A person who is deafblind may have some degree of both hearing and vision loss. Many people who are deafblind will usually be accompanied by an intervenor, a professional support person who helps with communication.
- A customer who is deafblind is likely to explain to you how to communicate with them, perhaps with an assistance card or a note
- Speak directly to your customer, not to the intervenor
People with Speech or Language Impairments
Cerebral palsy, hearing loss or other conditions may make it difficult for a person to pronounce words or may cause slurring. Some people who have severe difficulties may use a communication board or other assistive devices.
- Don’t assume that a person with speech impairment also has another disability
- Whenever possible, ask questions that can be answered with “yes” or a “no”
- Be patient. Don’t interrupt or finish your customer’s sentences
People Who Have Learning Disabilities
The term “learning disabilities” refers to a variety of disorders. One example is dyslexia, which affects how a person takes in or retains information. This disability may become apparent when a person has difficulty reading material or understanding the information you are providing.
- Be patient – people with some learning disabilities may take a little longer to process information, to understand and to respond
- Try to provide information in a way that takes into account the customer’s disability. E.g., some people with learning disabilities find written words difficult to understand, while others may have problems with numbers and math
People Who Have Intellectual Developmental Disabilities
Developmental or intellectual disabilities, such as Down Syndrome, can limit a person’s ability to learn, communicate, do everyday physical activities and live independently. You may not know that someone has this disability unless you are told.
- Don’t make assumptions about what a person can do
- Use plain language
- Provide one piece of information at a time
People Who Have Mental Health Disabilities
Mental health issues can affect a person’s ability to think clearly, concentrate or remember things. Mental health disability is a broad term for many disorders that can range in severity. E.g., some customers may experience anxiety due to hallucinations, mood swings, phobias or panic disorder.
- If you sense or know that a customer has a mental health disability be sure to treat them with the same respect and consideration you have for everyone else
- Be confident, calm and reassuring
- If a customer appears to be in crisis, ask them to tell you the best way to help
People Who Use Assistive Devices
An assistive device is a tool, technology or other mechanism that enables a person with a disability to do everyday tasks and activities, such as moving, communicating or lifting. Personal assistive devices can include things like wheelchairs, hearing aids, white canes or speech amplification devices.
- Don’t touch or handle any assistive device without permission
- Don’t move assistive devices or equipment, such as canes and walkers, out of your customer’s reach
- Let your customers know about accessible features in the immediate environment that are appropriate to their needs (e.g. public phones with TTY service, accessible washrooms, etc.)
People Who Use a Service Animal
People with vision loss may use a guide dog, but there are other types of service animals as well. Hearing alert animals help people who are deaf, deafened, oral deaf, or hard of hearing. Other service animals are trained to alert an individual to an oncoming seizure.
Under the standard, service animals must be allowed on the parts of your premises that are open to the public. In some instances, service animals will not be permitted in certain areas by law (E.g., a restaurant kitchen).
- Remember that a service animal is not a pet. Avoid touching or addressing them
- If you’re not sure if the animal is a pet or a service animal ask your customer
People Who Are Accompanied By a Support Person
Some people with disabilities may be accompanied by a support person, such as an intervenor. A support person can be a personal support worker, a volunteer, a family member or a friend. A support person might help your customer with a variety of things from communicating, to helping with mobility, personal care or medical needs.
Welcome support people to your workplace or business. They are permitted in any part of your premises that is open to the public. If your organization is one that charges admission, such as a movie theatre or bowling alley, provide notice, in advance, about what admission fee will be charged for a support person.
- If you’re not sure which person is the customer, take your lead from the person using or requesting your goods or services, or simply ask
- Speak directly to your customer, not to their support person
People With Disabilities Who Need Help Accessing Your Goods or Services
If you notice that your customer is having difficulty accessing your goods or services, a good starting point is to simply ask “How can I help you?”
Your customers are your best source for information about their needs. A solution can be simple and they will likely appreciate your attention and consideration.
You can get more information related to accessibility for Ontarians at ontario.ca/AccessON.
Questions or Comments
Any policy of Advocis that does not respect and promote the dignity and independence of people with disabilities will be modified or removed.
It is important that staff fully understand Advocis’ Accessible Customer Service Policy. If you have any questions or comments about this policy or its related procedures please contact,
Angeline Simbandumwe – firstname.lastname@example.org or extension 9851.
This policy and its related procedures will be reviewed as required in the event of legislative changes
Advocis and Affiliates’ Accessible Customer Service Policy Acknowledgement and Agreement
All employees of Advocis and Affiliates, including full-time, contract, temporary and student workers, are required to have a signed copy of this Accessible Customer Service Policy Acknowledgement and Agreement form on file with Human Resources.
By signing this form, I acknowledge that I have received, read, understand, and agree to comply with Advocis and Affiliates’ Accessible Customer Service Policy.
I further understand that if I should violate this policy, I may face corrective action up to and including termination from employment, legal action and/or criminal liability.
Updates made to this agreement will also apply.