Purpose
OCAS Application Services Inc. (“OCAS”) meets the requirements of Ontario Regulation 191/11, “Integrated Accessibility Standards” (Regulation) under the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) and has developed this Policy further to the requirements of the AODA.
Commitment
OCAS is committed to preventing and removing barriers faced by people with disabilities and to treating all people in a manner that allows them to maintain their dignity and independence. We believe in integration and equality of access. We are committed to meeting the needs of persons with disabilities in a timely manner.
Scope
This policy applies to all employees of OCAS in Ontario, whether engaged on a full-time, part-time, temporary, and casual basis, and every person who deals with members of the public or other third parties on behalf of OCAS.
OCAS is governed by this policy as well as the Accessibility Standards for Customer Service Policy, in compliance with the AODA.
Definitions
Disability means:
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 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.
Establishment of Accessibility Plan
OCAS has developed and will follow and maintain a multi-year accessibility plan outlining its strategy for preventing and removing barriers from its workplace in accordance with AODA. OCAS will post its multi-year accessibility plan on its website in accordance with AODA and provide the plan in an accessible format upon request. OCAS will review and update its multi-year accessibility plan once every five years. If requested, the plan shall be provided in an accessible format or with communication supports. The plan will be posted on the OCAS website. Accessibility Compliance Reports shall also be prepared and filed by OCAS as required under the AODA.
Training Requirements
OCAS will ensure that every person who deals with members of the public or other third parties on behalf of OCAS, whether the person does so as an employee, volunteer or otherwise. Every person who participates in developing OCAS policies, practices, and procedures governing the provision of services to members of the public or other third parties will receive training as required as soon as practicable and on an ongoing basis in connection with changes to the policies required by the Regulation. Employees will receive training during their period of orientation as new employees, and as appropriate to those employees’ duties.
OCAS will track and maintain a record of the training it provides.
Training will include instruction on the requirements of the accessibility standards required by the Regulation and on the Human Rights Code as it pertains to persons with disabilities.
Information & Communication Standards
Accessible Formats and Communication Supports
OCAS will provide or arrange for the provision of accessible formats and communication supports for persons with disabilities, taking into account the person’s disability and accessibility needs when customizing individual requests. Such accessible formats and communication supports will be arranged in a timely manner, and in consultation with the person making the request to determine suitability of an accessible format or communication support, and at no additional cost to the individual.
OCAS will notify the public about the availability of accessible formats and communication supports.
Accessible Website and Web Content
OCAS will ensure, where practicable and where OCAS controls the websites and web content directly or through a contractual relationship, that its web content conforms to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 at Level AA.
Feedback Process
OCAS will ensure that its feedback processes are accessible to persons with disabilities by providing, or arranging for the provision of, accessible formats and communication supports, upon request. OCAS will notify the public about the availability of accessible format and communications supports with respect to the feedback process.
Employment Standards
OCAS is proud to have a diverse workforce, with a safe, inclusive, and accessible work environment. OCAS policies, guidelines, and practices are intended to foster diversity, inclusiveness, and accessibility.
Accommodations are available to job applicants in the recruitment process. OCAS will make every reasonable effort to accommodate job applicants who have disabilities. Applicants who are selected to participate further in the hiring process will be informed that accommodations are available during the hiring and recruitment process. If a selected job applicant requests accommodation relating to their participation in the hiring process, OCAS will consult with the job applicant and will take reasonable measures to provide or arrange for the provision of suitable accommodation(s) that accounts for the job applicant’s disability-related needs.
When making offers of employment and/or employment contracts, OCAS will notify all successful applicants of our policies and support for accommodating employees with disabilities.
OCAS will inform all its employees of policies used to support employees with disabilities, including but not limited to policies relating to job accommodations.
An employee with a disability may, at any time, request that information the employee needs to perform their job, or information that is generally available to other employees, be provided to the employee in an accessible format or with appropriate communication supports. OCAS is committed to providing, or arranging to provide, accessible formats and communication supports for its employees.
OCAS will consult with every employee with a disability who requests accessible formats or communication supports in the workplace to determine the most suitable solution to the barrier the employee faces.
Individualized Workplace Emergency Response Plans for Employees
OCAS will provide individualized workplace emergency response information to employees who have a disability, including a temporary injury or medical condition, if the disability is such that it could impact the employee’s ability to safely respond in the event of a workplace emergency, and if OCAS is aware of the need for accommodation due to the employee’s disability.
All information provided by employees for the purpose of individualized workplace emergency response planning will remain confidential, except to the extent disclosure is necessary to assist the employee pursuant to their individualized workplace emergency response plan. Employees are not required to provide details regarding their medical condition or disability – only information about their disability-related needs and the type of help or assistance the employee may need in an emergency is required.
Individualized workplace emergency response plans will be reviewed whenever an employee moves to a different location in the organization, when the employee’s overall accommodation needs or plans are reviewed, and when OCAS reviews its general emergency response policies.
Accommodation Plans and Processes
OCAS will develop and implement an individual accommodation plan process, addressing the following elements:
The way 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 way OCAS can request an evaluation by an outside medical or other expert, at OCAS expense, to assist OCAS in determining if and how accommodation can be achieved;
The way the employee can request participation of a representative from the workplace 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 way it will be done;
If an individual accommodation request is denied, the manner in which the reasons for the denial will be provided to the employee; and
The means of providing the individual accommodation plan in a format that accounts for the employee’s accessibility needs due to disability.
OCAS is committed to working with any employee who identifies as having a disability to develop and implement an individual accommodation plan.
OCAS will take reasonable measures to protect the confidentiality of employees’ personal information in the course of the accommodation process, including any medical information received, and to ensure that all means of accommodation are based on the employee’s accessibility needs. OCAS will maintain the confidentiality of the employee’s personal information and will not disclose the employee’s personal information to any third party without the employee’s consent, except as required by law.
OCAS will work with the employee in the development of a plan that meets their individual needs, and to determine when the plan should be reviewed or updated. The plans will include individualized workplace emergency response information (where required), information about accessible formats and communication supports (if applicable) and will identify any other accommodation that is to be provided to the employee.
Return to Work Process
OCAS is committed to supporting employees who have been absent from work due to non-work-related disability and require accommodation to return to work.
Those employees who have been absent from work as a result of a workplace injury and who received benefits pursuant to the Workplace Safety and Insurance Act, 1997 (the “WSIA”) shall return to work in accordance with the WSIA’s return-to-work process.
OCAS will maintain a documented return to work process for its employees who have been absent from work due to a non-workplace injury, and who require disability-related accommodations in order to return to work, and OCAS will follow the return-to-work process established. The return-to-work process outlines the steps OCAS will take to facilitate the return to work and will include documented individual accommodation plans as part of the process.
Performance Management, Career Development and Advancement and Redeployment
OCAS will consider the accessibility needs of employees with disabilities, as well as individual accommodation plans, when conducting performance management, providing career development and advancement opportunities to employees, or when redeploying employees.
Administration
This policy has been developed to break down barriers and increase accessibility for persons with disabilities in the areas of information and communications and employment. If anyone has a question or concerns about this policy or its related procedures or would like to obtain this document in an alternate format, please contact the Human Resources Department – HR@ocas.ca.
This policy and its related procedures will be reviewed on an annual basis as necessary to ensure compliance with the AODA and updated when required. OCAS is committed to developing policies that respect and promote the dignity and independence of persons with disabilities. OCAS policies and procedures are developed and updated to promote full access to our services and respect for all.
Referenced Documents
Accessibility for Ontarians with Disabilities Act, 2005
https://www.ontario.ca/laws/statute/05a11Integrated Accessibility Standards, Ontario Regulation 191 / 11
https://www.ontario.ca/laws/regulation/r11191Ministry of Community and Social Services, Making Ontario Accessible (Access ON)
https://www.ontario.ca/page/accessibility-lawsOntario Human Rights Code
https://www.ontario.ca/laws/statute/90h19WWW Consortium Web Content Accessibility Guidelines 2.0
https://www.w3.org/WAI/standards-guidelines/wcag/