Access for Ontarians with Disabilities Policy

This policy is one section of your staffing agency’s OHSP, containing the Access for Ontarians with Disabilities Policy. The Table of Contents contains hyperlinks that will direct you to fillable versions of any related documents or forms.

1. Policy

The purpose of this policy is to outline the responsibilities of the organization to provide goods, services, and opportunities to people with disabilities in accordance with the requirements set out by the Accessibility for Ontarians with Disabilities Act (AODA), 2005.

2. Objective

The organization endeavors, at all times, to provide its services and opportunities in a manner that respects the dignity and independence of people with disabilities. We are committed to giving people with disabilities the same opportunity to benefit from the same services and opportunities, in the same place and in a similar way as others.

3. Responsibilities

People 2.0 Workforce services Canada ULC. (People2.0)

Establish the AODA Policy and review it annually to ensure compliance with applicable legislation. Some changes to legislation may require more timely reviews in order to maintain compliance.
Retain all records required under law, audit these records to ensure compliance with established policy, and take corrective action on any deficient practices or deviations from policy.
Submit any compliance reports, documents, or records as required under the legislation.
Provide to all employees, any legislatively required documents and training.

Your Staffing Agency is responsible to:

Establish the AODA Policy and review it annually to ensure compliance with applicable legislation. Some changes to legislation may require more timely reviews in order to maintain compliance.
Retain all records required under law, audit these records to ensure compliance with established policy, and take corrective action on any deficient practices or deviations from policy.
Submit any compliance reports, documents, or records as required under the legislation.
Provide to all employees, any legislatively required documents and training.

Your Staffing Agency is responsible to:

Ensure all employees are trained on AODA requirements and have the necessary supports to deliver AODA-compliant services, including the proper use of assistive devices.
Understand and support employee entitlements as it pertains to accommodating disabilities.
Ensure all facilities meet AODA accessibility requirements and are maintained in good order.
Maintain all records of training, complaints, corrective activities, and service issues and submit them to People2.0 upon request for compliance reporting and auditing purposes.
Certify annual AODA reports as true and accurate and submit them to the government. Create and maintain a forum for client and employee feedback related to AODA concerns, and actioning items as appropriate.
Ensure that employees do not experience reprisal for identifying areas of concern related to AODA obligations for themselves, clients, or other employees.

Your Staffing Agency Supervisor:

Understand and support employee rights and preferences as it pertains to AODA and work with employees who require supports to assist their work activities.
Ensure that all applicants seeking employment with the organization are able to obtain information and participate in the recruitment process equitably and with needs taken into account.
Provide copies of accessibility policies to all employees and advise them of any updates to the policy.
Work with employees to develop and maintain accommodations plans as required.
Ensure that all clients seeking interaction with the organization are able to obtain information and conduct business in a manner that supports their needs, including but not limited to obtaining documents in alternative formats, the use of service animals, and assistive devices.
Ensure that the work premises are accessible with regular maintenance.
Maintain records of AODA-related training, client feedback, and building maintenance related to assistive devices and equipment, submitting them as required to the Agency and People2.0.

Workers are responsible to:

Participate in training related to AODA requirements and the use of any assistive devices in the workplace.
- Utilize active offers when dealing with clients, to proactively identify opportunities to provide services in alternative formats. Notify your supervisor of any AODA-related items that are not compliant with requirements.
Identify any accessibility needs related to own employment and participate in the accommodation plan process.

4. Definitions

Accessibility — The term accessibility means giving people of all abilities opportunities to participate fully in everyday life. It is used to describe how widely a service, product, device, or environment is available to as many people as possible. Accessibility can be seen as the ability to access and benefit from a system, service, product, or environment.

Barrier — Barriers are obstacles that limit access and prevent people with disabilities from fully participating in society. Most barriers are not intentional. Barriers usually arise because the needs of people with disabilities are not considered from the beginning.

Disability — Ontario’s accessibility law adopts the definition of disability that is in the Ontario Human Rights Code. It defines disability broadly:

“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 a 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.”

Workplace Accommodation – When an employer makes adjustments to the workplace for a person or group of people with unique requirements as a result of a characteristic protected under human rights law.

5. Process

The organization is required to create and maintain an Accessibility Plan that outlines the specifics of activities and commitments related to improving accessibility and report progress on the plan on an annual basis that can be shared with employees and clients.

Some of the commitments outlined in the plan are:

General Communications

All individuals interacting with the organization (employees, clients, third-party service providers, suppliers, and members of the general public) will be communicated in ways that take their disability support preferences into account. In order to provide this service:

Employees are required to complete AODA training to ensure an understanding of service delivery requirements and expectations, including an active offer of service supports and the proper use of assistive devices.
Websites will be developed and maintained using WCAG 2.0 Level AA.
Any written material will be provided in an alternative format upon request. This may include but is not limited to: memos, letters, invoices, service agreements, contracts, policies, and training material.

5.1 Support Person

Any individual with a disability is welcome to be accompanied by a support person. At no time will a person with a disability who is accompanied by a support person be prevented from having access to his or her support person while on the premises.

5.2 Use of Service Animals

Individuals who are accompanied by a service animal are welcome in all areas unless otherwise restricted by law. Employees are to ensure that all contact with services animals is compliant with the expectations of interacting with services animals including but not limited to asking permission of the owner prior to any interaction with the animal and following the directions of the owner in relation to any contact, verbal or physical.

5.3 Employment

Employment practices will be accessible to meet the needs of employees and job applicants with disabilities. Job advertisements will indicate that the organization will meet the needs of people with disability, including receiving job postings and descriptions in alternative formats and accommodations as it relates to the interview process. Candidates will also be asked upon hire if they require any workplace accommodation in order to support them in their new role and the appropriate resources will be provided.

5.4 Facilities

All work premises must comply with accessibility requirements under applicable legislation. Enhancements to the facilities for employees with additional workplace accommodation requirements will be actioned in accordance with the health and safety Policy on workplace accommodation.

5.5 Notice of temporary service disruption

The organization will provide notice in the event of a planned or unexpected disruption in the facilities or services provided and or the assistive devices provided for use by people with disabilities. This notice will include information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if available. The notice will be provided in a variety of formats such as on websites, signage, email, or notification on the phone system.

6. Recordkeeping

The organization is obligated to complete and retain the following:

Organizational Accessibility Plan
Annual compliance report and proof of submission to the government
Records for all employees related to AODA
Record of client or employee feedback related to accessibility activities or services
Workplace Accommodation plans for employees and record of activities

7. Related Documents:

Compliance Reporting Form (Ministry for Seniors and Accessibility), available at – https://www.ontario.ca/page/completing-your-accessibility-compliance-report#section-2
ON-IND-FRM Organizational Accessibility Plan
ON-IND-FRM Workplace Accommodation Template