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ACCESSIBILITY FOR ONTARIANS WITH DISABILITIES ACT, 2005
INTEGRATED ACCESSIBILITY STANDARDS – Multi Year Plan

Part I – GENERAL REQUIREMENTS

Section Initiative Description Action Status Compliance Date
3 Establishment of Accessibility Policies 3.(1) Every obligated organization shall develop, implement and maintain policies governing how the organization achieves or will achieve accessibility through meeting its requirements under the accessibility standards referred to in this Regulation. Completed April 22, 2013 Complete January 1, 2014
4 Accessibility Plans 4. (1) Large organizations shall,

a) establish, implement, maintain and document a multi-year accessibility plan, which outlines the organization‘s strategy to prevent and remove barriers and meet its requirements under this Regulation;

b)post the accessibility plan on their website, if any, and provide the plan in an accessible format upon request; and

c)review and update the accessibility plan at least once every five years.
Completed April 22, 21013

Posted December 23, 2013
Complete January 1, 2014
6 Self-Serve Kiosks 6.(2) Large organizations and small organizations shall have regard to the accessibility for persons with disabilities when designing, procuring or acquiring self-service kiosks. N/A   January 1, 2014
7 Training 7.(1) Every obligated organization shall ensure that training is provided on the requirements of the accessibility standards referred to in this Regulation and on the Human Rights Code as it pertains to persons with disabilities to,

(a) all employees, and volunteers;
(b) all persons who participate in developing the organization‘s policies; and
(c) all other persons who provide goods, services or facilities on behalf of the organization.
Training provided via HR Downloads to all current employees & new starters

Incorporate AODA language/clause into RFP process with vendors/suppliers in Ontario
Complete January 1, 2015

PART II – Information and Communications Standards

Section Initiative Description Action Status Compliance Date
11 Feedback 11.(1) Every obligated organization that has processes for receiving and responding to feedback shall ensure that the processes are accessible to persons with disabilities by providing or arranging for accessible formats and communications supports, upon request. Conduct a review of all feedback processes that exist within the organization in all functional areas
i.e. Customer satisfaction survey, customer opinion, employee satisfaction survey, etc.

Determined what accessible formats and communications supports we are going to provide upon request
Complete January 1, 2015
12 Accessible Formats & Communication Supports 12.(1) Except as otherwise provided, every obligated organization shall upon request provide or arrange for the provision of accessible formats and communication supports for persons with disabilities,

a) in a timely manner that takes into account the person‘s accessibility needs due to disability; and
b) at a cost that is no more than the regular cost charged to other persons.
Determined what formats and supports will be provided to persons with disabilities upon requests

(a) Defined what is a timely matter for the organization

(b) Cost needs to be communicated to others to ensure no cost is charged beyond the regular charge
Complete January 1, 2016
12   12.(2) The obligated organization shall consult with the person making the request in determining the suitability of an accessible format or communication support. Developed a process for handling such requests Complete January 1, 2016
12   12.(3) Every obligated organization shall notify the public about the availability of accessible formats and communication supports. Accessible customer Service Policy posted to Accommodations page on Company website Complete January 1, 2016
13 Emergency Procedures, Plans or Public Safety Info 13.(1) In addition to its obligations under section 12, if an obligated organization prepares emergency procedures, plans or public safety information and makes the information available to the public, the obligated organization shall provide the information in an accessible format or with appropriate communication supports, as soon as practicable, upon request. N/A N/A January 1, 2012
14 Accessible Websites & Web Content 14.(2) Designated public sector organizations and large organizations shall make their internet websites and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG)2.0, initially at Level A and increasing to Level AA, and shall do so in accordance with the schedule set out in this section. Met with Online & New Media Manager and Webmaster on October 7, 2013 to make sure that any new sites or content are in compliance
Ongoing
January 1, 2014

New internet websites and web content on those sites must conform with WCAG 2.0 Level A.
      Made Senior Manager, Digital Strategy & VP, Publisher aware of compliance obligations July 30th 2019
Ongoing
January 1, 2021

All internet websites and web content must conform with WCAG 2.0 Level AA, other than,
  • success criteria 1.2.4 Captions (Live)
  • success criteria 1.2.5 Audio Descriptions (Pre-recorded).
15 Educational & Training Resources & Materials 15(1) Every obligated organization that is an educational or training institution shall do the following, if notification of need is given:
  1. Provide educational or training resources or materials in an accessible format that takes into account the accessibility needs due to a disability of the person with a disability to whom the material is to be provided by,
    1. procuring through purchase or obtaining by other means an accessible or conversion ready electronic format of educational or training resources or materials, where available, or
    2. arranging for the provision of a comparable resource in an accessible or conversion ready electronic format, if educational or training resources or materials cannot be procured, obtained by other means or converted into an accessible format.
  2. Provide student records and information on program requirements, availability and descriptions in an accessible format to persons with disabilities.
Does not apply to OUP N/A January 1, 2013
16 Training to Educators 16(1) In addition to the requirements under section 7, obligated organizations that are school boards or educational or training institutions shall provide educators with accessibility awareness training related to accessible program or course delivery and instruction.
Does not apply to OUP N/A January 1, 2013
    (2) Obligated organizations that are school boards or educational or training institutions shall keep a record of the training provided under this section, including the dates on which the training is provided and the number of individuals to whom it is provided.
Does not apply to OUP N/A January 1, 2013
17 Producers of Educational or Training Material 17(1) Every obligated organization that is a producer of educational or training textbooks for educational or training institutions shall upon request, make accessible or conversion ready versions of the textbooks available to the institutions. Handled by Permissions Department Complete January 1, 2015 For accessible or conversion ready versions of textbooks
    (2) Every obligated organization that is a producer of print-based educational or training supplementary learning resources for educational or training institutions shall upon request, make accessible or conversion ready versions of the printed materials available to the institutions. Handled by Permissions Department Complete January 1, 2020 For accessible or conversion ready versions of printed materials that are educational or training supplementary learning resources.
18 Libraries of educational & training institutions 18(1) Subject to subsection (2) and where available, the libraries of educational and training institutions that are obligated organizations shall provide, procure or acquire by other means an accessible or conversion ready format of print, digital or multimedia resources or materials for a person with a disability, upon request.

(2) Special collections, archival materials, rare books and donations are exempt from the requirements of subsection (1).
Does not apply to OUP N/A January 1, 2015
For print-based resources or materials

January 1, 2020 For digital or multimedia resources or materials

PART III – Employment Standard

Section Initiative Description Action Status Compliance Date
22 Recruitment – General 22. Every employer shall notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment processes. Include statement in job ads that we are committed to providing accommodation for applicants with disabilities Complete January 1, 2016
23 Recruitment, Assessment or Selection Process

23.(1) During a recruitment process, an employer shall notify job applicants, when they are individually selected to participate in an assessment or selection process, that accommodations are available upon request in relation to the materials or processes to be used.
(2) If a selected applicant requests an accommodation, the employer shall consult with the applicant and provide or arrange for the provision of a suitable accommodation in a manner that takes into account the applicant‘s accessibility needs due to disability.

Message included in interview invites sent via email
Complete January 1, 2016
24 Notice to Successful Applicants 24. Every employer shall, when making offers of employment, notify the successful applicant of its policies for accommodating employees with disabilities. Added notification to the employment agreement email Complete January 1, 2016
25 Informing Employees of Supports 25.(1) Every employer shall inform its employees of its policies used to support its employees 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 disability.
Policy statement communicated during New Employee Orientation Complete January 1, 2016
25   25.(2) Employers shall provide the information required under this section to new employees as soon as practicable after they begin their employment. Orientation Complete January 1, 2016
25  

25.(3)Employers shall provide updated information to its employees whenever there is a change to existing policies on the provision of job accommodations that take into account an employee‘s accessibility needs due to disability.

Changes to existing policies will be communicated via the company intranet Ongoing January 1, 2016
26 Accessible Formats & Communication Supports for Employees 26.1 In addition to its obligations under section 12, where an employee with a disability so requests it, every employer shall consult with the employee to provide or arrange for the provision of accessible formats and communication supports for,

(a) information that is needed in order to perform the employee‘s job; and
(b)  information that is generally available to employees in the workplace.
To be determined as necessary Ongoing January 1, 2016
26   26.2. The employer shall consult with the employee making the request in determining the suitability of an accessible format or communication support. To be determined as necessary Ongoing January 1, 2016
27

Workplace Emergency Response Information

27.(1) Every employer shall provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary and the employer is aware of the need for accommodation due to the employee‘s disability.


Communication sent to employees on December 4, 2012

Ongoing January 1, 2012
27   (2) If an employee who receives individualized workplace emergency response information requires assistance and with the employee‘s consent, the employer shall provide the workplace emergency response information to the person designated by the employer to provide assistance to the employee. Communication sent to employees on December 4, 2012 Ongoing January 1, 2012
27   (3) Employers shall provide the information required under this section as soon as practicable after the employer becomes aware of the need for accommodation due to the employee‘s disability. Communication sent to employees on December 4, 2012 Ongoing January 1, 2012
27   (4) Every employer shall review the individualized workplace emergency response information,

(a) when the employee moves to a different location in the organization;
(b) when the employee‘s overall accommodations needs or plans are reviewed; and
(c) when the employer reviews its general emergency response policies.
Communication sent to employees on December 4, 2012 Ongoing January 1, 2012
28 Documented Individual Accommodation Plans 28.(1) Employers, other than employers that are small organizations, shall develop and have in place a written process for the development of documented individual accommodation plans for employees with disabilities. Developed accommodation plan and accommodation process. Complete January 1, 2016
28   28 (2) The process for the development of documented individual accommodation plans shall include the following elements:

  1. The manner in which an employee requesting accommodation can participate in the development of the individual accommodation plan.
  2. The means by which the employee is assessed on an individual basis.
  3. The manner in which the employer can request an evaluation by an outside medical or other expert, at the employer‘s expense, to determine if and how accommodation can be achieved.
  4. The manner in which the employee can request the participation of a representative from their bargaining agent, where the employee is represented by a bargaining agent, or other representative from the workplace, where the employee is not represented by a bargaining agent, in the development of the accommodation plan.
  5. The steps taken to protect the privacy of the employee‘s personal.
  6. The frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done.
  7. If an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee.
  8. The means of providing the individual accommodation plan in a format that takes into account the employee‘s accessibility needs due to disability.
Ensured that developed plans are in compliance with these requirements Complete January 1, 2016
29 Return to Work Process 29.(1) Every employer, other than an employer that is a small organization,

  1. shall develop and have in place a return to work process for its employees who have been absent from work due to a disability and require disability-related accommodations in order to return to work; and
  2. shall document the process.
    Jaunary 1, 2016
29   29. (2) The return to work process shall,

  1. outline the steps the employer will take to facilitate the return to work of employees who were absent because their disability required them to be away from work; and
  2. use individual documented accommodation plans, as described in section 28, as part of the process.
Reviewed current RTW process and standards to ensure compliance Complete January 1, 2016
29   29. (3) The return to work process referenced in this section does not replace or override any other return to work process created by or under any other statute. Reference Safety Group Program standards Complete January 1, 2016
30 Performance Management 30.(1) An employer that uses performance management in respect of its employees shall take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when using its performance management process in respect of employees with disabilities. Reviewed performance appraisal process and take into account this requirement when developing any new programs Ongoing January 1, 2016
31 Career Development & Advancement 31.(1) An employer that provides career development and advancement to its employees shall take into account the accessibility needs of its employees with disabilities as well as any individual accommodation plans, when providing career development and advancement to its employees with disabilities. To be determined as necessary Ongoing January 1, 2016
32 Redeployment 32.(1) An employer that uses redeployment shall take into account the accessibility needs of its employees with disabilities, as well as individual accommodation plans, when redeploying employees with disabilities. To be determined as necessary Ongoing January 1, 2016