To ensure that Immigrant Women Services Ottawa (IWSO) promotes and serves with excellence all clients, including persons with disabilities;
To outline the practices and procedures in place to help identify and remove barriers that impede a person’s ability to access services and resources provided by IWSO; and
To ensure that the IWSO meets the requirements of the Accessibility Standards for Customer Service, Ontario Regulation 429/07 under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and the Immigrant Women Services Ottawa Accessible Client Service Plan.
This policy applies to the provision of goods and services by all individuals and staff who deal with the public or other third parties on behalf of IWSO, in any capacity, including and without limitation, to employees, supervisors, managers, volunteers, contractors, consultants, clients and board members. The policy applies to all activities that occur while on IWSO premises or while at other location(s) where individuals may be located as a result of his/her work with IWSO, or while s/he is engaging in IWSO business, activities or social events. This policy also applies to all persons who participate in the development of IWSO policies, practices and procedures governing the provision of services and goods to clients, public and third parties.
This policy is intended to benefit the full range of persons with disabilities, as defined in the Ontario Human Rights Code and the AODA.
3. Policy Statement:
IWSO is committed to providing services and programs that will assist immigrant women in their journey to attain their full potential. IWSO is committed to excellence in serving all clients, including persons with disabilities.
IWSO is committed to treating all persons in a way that allows them to maintain their dignity and independence. We believe in integration and equal opportunity. We are committed to meeting the needs of persons with disabilities in a timely manner, and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the AODA.
IWSO is also committed to maintaining an inclusive workplace environment and reasonable and practical accommodation for its staff, including persons with disabilities.
4.1 Responsibilities of Staff, including Employees, Volunteers and Management
Employees, volunteers and other staff are expected to:
- Promote and serve with excellence all clients, including persons with disabilities;
- Ensure that accessible client service is provided to all clients in accordance to this policy and related procedures;
- Participate in IWSO education and training programs on accessibility and disabilities;
- Provide clients with publicly available emergency information in an accessible way upon request;
- Provide emergency services as per their duties and responsibilities. IWSO employees will provide employees with disabilities with individualized emergency response information when necessary;
- Understand and comply with this Policy, IWSO Accessible Client Service Plan and all related procedures, including the Ontario accessibility legislation.
Management is expected to perform all those responsibilities of staff, and to:
- Ensure education and training of employees, volunteers and all other staff, with respect to this policy, Ontario’s accessibility laws and on the Human Rights Code as it relates to persons with disabilities. Training will be provided in a way that best suits the duties of employees, volunteers and other staff members;
- Keep records of accessibility training provided, including the dates on which training took place and the individuals to whom it was provided;
- Ensure that this policy is communicated to staff and is carried out consistently;
- Implement the IWSO Accessible Client Service Plan throughout program planning and delivery;
- Review reports, complaints and apparent issues with program delivery and IWSO policy that give rise to a potential problem or conflict with respect to this policy, Ontario’s accessibility laws, the Human Rights Code and the IWSO Accessible Client Service Plan;
- Take all reasonable measures to address and resolve any problem which may interfere or prevent IWSO from providing services and resources to persons with disabilities.
4.2 Providing Goods and Services to Persons with Disabilities
Immigrant Women Services Ottawa is committed to excellence in serving all clients including persons with disabilities. We will promote accessibility and inclusion in all aspects of program and client service delivery.
IWSO will communicate with a person with a disability in a manner that takes into account his or her disability.
4.4 Assistive Devices and Measures
IWSO shall enable persons with disabilities to access our goods and utilize our services by offering all reasonable assistive devices and measures to the best ability of the organization and its staff. We will ensure that all staff are trained and familiar with various assistive devices that may be commonly used by clients with disabilities while accessing our goods and services.
IWSO will encourage persons with disabilities to use their own personal assistive devices to improve access to IWSO services and resources.
Where the premises, program delivery structure or other systemic issues prevent a client access to our goods and services, we will endeavor to immediately accommodate to the best of our ability. Furthermore, we will review the source of the problem with the object of remedying current and foreseeable future issues through our review processes.
4.5 Service Animals
IWSO welcomes persons with disabilities and their service animals. IWSO shall allow persons with disabilities to bring their guide dog or service animal with them to areas of the premises that are open to the public.
4.6 Support Persons
A person with a disability who is accompanied by a support person will be allowed to have that person accompany them on our premises. IWSO will ensure that a person with a disability has access to his or her support person while on our premises.
In situations where confidential information of a client with a disability is to be discussed, IWSO employees, volunteers and other staff must require permission from the client (verbal or written) allowing their support person to be present. Managers may also require a client and a support person to indicate in writing (or otherwise) their understanding of the confidentiality considerations where confidential matters are being discussed.
Fees will not be charged for support persons or for admission to IWSO’s premises and programs. IWSO will notify clients of our policy with respect to support persons through a notice posted on
our premises and our website.
4.7 Notice of Temporary Disruption
In the event of a planned or unexpected disruption to services or facilities for clients with disabilities, IWSO will notify clients promptly via a clearly posted notice. The notice will include information about the reason for the disruption, its anticipated length of time, and a description of alternative facilities or services, if available.
The notice will be placed on our website and at the entrance to the IWSO office.
IWSO shall provide training to employees, volunteers and others who deal with the public or other third parties on their behalf. Training shall also be provided to persons involved in the development of policies, plans, practices and procedures related to the provision of our goods and services.
Individuals in the following positions will be trained:
- All front-line staff;
- All managers;
- All Directors and Members of the Policy and Programs Committee
This training will be provided to staff within one (1) month of being hired or otherwise acquiring one of the above positions.
Training will include:
An overview of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard;
Immigrant Women Services Ottawa Accessible Client Service Plan;
How to interact and communicate with persons with various types of disabilities;
How to interact with persons with disabilities who use an assistive device(s) or require the assistance of a service animal(s) or support person(s);
How to use the equipment and devices available on-site or otherwise that may help with providing goods or services to persons with disabilities; and
What to do if a person with a disability is having difficulty in accessing Immigrant Women Services Ottawa’s goods and services.
Staff will also be trained when changes are made to the IWSO Accessible Client Service Plan.
4.9 Feedback process
Clients who wish to provide feedback on the way IWSO provides goods and services to persons with disabilities may provide feedback via e-mail, verbally or through the IWSO’s suggestion box.
All feedback shall be directed to the Program Manager. IWSO will provide a response to feedback within 5 working days.
Complaints will be addressed according to our regular complaint management procedures and duties and responsibilities with respect to the protection of confidential information. It is the responsibility of every staff member to be attentive to the concerns of IWSO staff, clients and visitors and to resolve concerns related to accessibility.
4.10 Notice of availability
IWSO will notify the public that this Policy and IWSO Accessible Customer Service Plan are available upon request by posting a notice on our website or posting a notice at the entrance of the IWSO office.
4.11 Review and Resolution Process
IWSO Managers who identify a problem that impedes access of IWSO services or goods and resources of a person with a disability OR who are in receipt of a complaint, report and feedback shall immediately have an investigation conducted into the matter.
IWSO Managers must take immediate action to resolve the underlying problem. All reports and incidents of a failure to comply with this Policy, IWSO Accessible Customer Service Plan and all related procedures, including the Ontario accessibility legislation, shall be investigated, resolved and all actions taken by IWSO documented in an IWSO Accessibility Resolution Report.
4.12 Workplace Accommodation and Accessibility
IWSO is committed to providing a barrier-free workplace and promoting respect for all people. To fulfill this commitment, IWSO provides accommodations for workers in instances where a worker’s work environment has a discriminatory effect on the worker’s ability to fully participate in work- related activities. IWSO will make every reasonable effort short of undue hardship to create a workplace environment that is as free from barriers as possible.
4.12.1 Requests for Accommodation
Workers are not subject to reprisal for good faith requests for accommodation.
It is the worker’s responsibility to make a request in writing for workplace accommodation to their supervisor or manager. All written accommodation requests will be acknowledged within 5 working days and responded to within 30 working days. IWSO will ensure confidentiality of the information related to a request for accommodation to the extent possible and as required by law.
4.12.2 Accommodation Plan
Upon receipt of a request for accommodation, a manager shall draft an accommodation plan that may include:
- A description of the relevant limitations and needs of the individual requesting accommodation, including assessments and information from any experts consulted;
- Any arrangements made for assessments by experts;
- Identification of the most suitable accommodation;
- The steps to be taken to meet the suitable accommodation with a timeline;
- The reasons accommodation cannot be made, if any.
A copy of the accommodation plan shall be provided to the individual requesting accommodation upon completion. A copy of the reasons for the IWSO’s denial of a request for accommodation will be provided to the requester.
If by being refused accommodation an individual feels that they have been discriminated against, the Anti-racism and Anti-Oppression Policy should be consulted.
4.13 Monitoring, Review and Modifications to this or other policies
IWSO will review this Policy and the effectiveness of the IWSO Accessible Customer Service Plan at least every year.
Any policy of IWSO that does not respect and promote the dignity and independence of persons with disabilities will be modified or removed.
Assistive Device – is a technical aid, communication device or other instrument that is used to maintain or improve the functional abilities of persons with disabilities. Personal assistive devices are typically devices that customers bring with them such as a wheelchair, walker or a personal oxygen tank that might assist in hearing, seeing, communicating, moving, breathing, remembering and/or reading.
Accommodation refers to the removal of barriers preventing an otherwise qualified individual from performing the essential duties of his/her job. Accommodations may include acquiring or modifying equipment, making facilities readily accessible, modifying work schedules and reassignment, or such other modifications which are deemed appropriate.
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 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;
- An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.
Discrimination means “the treatment or consideration influenced by class or category rather than individual merit and that can be used to privilege (special treatment in favour of) as well as disadvantage (special treatment against) a particular group or individual.” Discrimination and harassment on the basis of gender, sexual orientation, race, ancestry, place of origin, ethnic origin, citizenship, colour, creed, age, marital status, family status or disability is a violation of the Ontario Human Rights Code (OHRC).
Guide Dog – is 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 persons who are blind.
Staff – For the purposes of this policy, s t a f f includes all employees (permanent full time, part time and casual) and others such as volunteers, contractors, outsourced services providers and affiliates.
Service Animal – as reflected in Ontario Regulation 429/07, 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
if the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disability.
Service Dog – 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;
- 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.
Support Person – as reflected in Ontario Regulation 429/07, 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.
Undue hardship – refers to the limit at which the organization accommodates a request without incurring a risk to the health and safety of the requestor or others, serious disruption to others or to service delivery or excessive expense.
Workplace – refers to any location where the work of the organization is performed.
5.2 Immigrant Women Services Ottawa Accessible Customer Service Plan (Attached)
5.3 Anti-racism and Anti-Oppression Policy
5.5 Related Legislation
- Accessibility for Ontarians with Disabilities Act, 2005
- (AODA) Accessibility Standards for Customer Service, Ontario Regulation
- 429/07 Ontario Human Rights Code, 1990
- Blind Persons’ Rights Act, Ontario Regulation 58, 1990
- Health Protection and Promotion Act, Ontario Regulation
- 562 Workplace Safety and Insurance Act, 1997
I have read, understood and agree to abide by the terms of this Accessibility and Persons with Disability Policy.
Name (Print Name)
Date of Signature
Approved January, 2015