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Contents
Integrated Accessibility Standards Regulation Policy
Purpose
This policy is drafted in accordance with the Integrated Accessibility Standards Regulation (Ontario Regulation 191/11) and addresses how the Ontario Arts Council (OAC) achieves or will achieve accessibility by meeting the requirements of the Regulation. The requirements will be met within the timeframes set in the Regulation.
The requirements of the Regulation as they apply to the OAC include:
- the establishment, implementation, maintenance and documentation of a multi-year accessibility plan, which outlines the OAC’s strategy to prevent and remove barriers and meet its requirements under this Regulation;
- the incorporation of accessibility criteria and features when procuring or acquiring good, service or facilities;
- training;
- the specific requirements under the Information and Communication Standards, and the Employment Standards.
This policy is supported by procedures/departmental policies which outline the detailed processes and accommodations pursuant to this policy.
Definitions
- Accessible formats may include, but are not limited to, large print, recorded audio and electronic formats, braille and other formats usable by persons with disabilities;
- Accommodation means the special arrangements made or assistance provided so that individuals with disabilities can participate in the experiences available to individuals without disabilities. Accommodation will vary depending on the customer’s unique needs.
- Communication supports may include, but are not limited to, captioning, alternative and augmented communication supports, plain language, sign language and other supports that facilitate effective communications.
- Communications means the interaction between two or more persons or entities, or any combination of them, where information is provided, sent or received;
- Conversion ready means an electronic or digital format that facilitates conversion into an accessible format;
- ‘Disability’ is (as defined in the AODA):
- 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 a 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.
- Information includes data, facts and knowledge that exists in any format, including text, audio, digital or images, and that coveys meaning.
- Volunteer may include a person who voluntarily undertakes a task on behalf of the OAC.
Statement of Organizational Commitment
OAC celebrates the creativity, innovation and excellence of Ontario’s artists and art organizations in all their diversity. In fall 2011, the OAC Board of Directors passed the following Equity Vision for the organization:
“We are inspired by and value Ontario’s artists, who help shape our thriving and diverse society and express the richness of our stories, histories and cultures. Therefore, as a public agency, funder and employer, OAC will lead and be responsive and inclusive in supporting diverse artists, artistic practices, arts communities and our own organization.”
As part of our commitment to equity, and as an agency of the Ontario government, OAC is committed to meeting, and wherever possible exceeding, all legislative requirements.
We are committed to the principles outlined in the Accessibility for Ontarians with Disabilities Act, 2005 and to meeting the needs of people with visible and invisible disabilities and people who are Deaf, in a timely manner, through the implementation of the requirements of the Act.
Furthermore, we are deeply committed to access for all Ontarians and these are the OAC’s goals to achieve accessibility according to the Integrated Accessibility Regulations Standard.
Accessibility Goals
The OAC strives at all times to ensure that our policies, practices and procedures are consistent with the following accessibility goals:
- Our programs and services must be provided in a manner that respects the dignity and independence of Deaf persons and persons with disabilities;
- Deaf persons and persons with disabilities must be given the same opportunity provided to other members of the public to access our programs and services;
- Our organization will create and provide information and communications in ways that are accessible for Deaf people and people with disabilities;
- As an employer, the OAC will integrate accessibility into all our regular workplace processes and will provide for accessibility across all stages of the employment life cycle.
Mandatory Requirements
General
- Accessibility Plans
- OAC’s Multi-year Accessibility Plan (“the plan”) outlines the strategy to prevent and remove barriers, and to meet its requirements under the Regulation;
- The plan is posted on the website, and will be provided in alternate formats upon request;
- The plan will be reviewed and updated at least once every five years;
- The plan has been created in consultation with OAC staff and with public input;
- An annual status report on the progress of measures taken to implement the strategy will be posted on the website and in alternate formats upon request.
- Procuring or acquiring goods, services or facilities
- Accessibility criteria and features are incorporated in the procurement process and contract when procuring or acquiring goods, services or facilities, except where it is not practicable to do so;
- Where it is not practicable to incorporate accessibility criteria and features when procuring or acquiring goods, services or facilities, OAC will document and provide, upon request, an explanation.
- Training
- OAC ensures that training is provided on the requirements of accessibility standards referred to within the Regulation and on the Ontario Human Rights Code as it pertains to persons with disabilities for,
- All employees and volunteers;
- All persons who participate in developing OAC’s policies; and
- All other persons who provide goods, services or facilities to the public on behalf of the OAC.
- The training provided is appropriate to the duties of employees, volunteers and other persons.
- Training is provided as practicable to employees, volunteers and other persons.
- Where there are changes to the Integrated Accessibility Standards Regulation Policy, training will be provided with regard to those changes.
- OAC will maintain a record of the dates of when training is provided and the number of individuals to whom it was provided.
Information and Communication Standards
- Feedback
- OAC’s public feedback process is accessible to persons with disabilities and does provide, or arrange for the provision of, accessible formats and communication supports upon request.
- The public is notified regarding the availability of accessible formats and communication supports.
- Accessible Formats and Communication Supports
- OAC will, upon request, provide or arrange for the provision of accessible formats and communication supports for persons with disabilities,
- in a timely manner that takes into account the person’s accessibility needs due to disability, and;
- at a cost that is no more than the regular cost charged to other persons.
- OAC will consult with the person making the request in determining the suitability of alternative formats or communication supports.
- OAC notifies the public about the availability of accessible formats and communication supports.
- Accessible websites and web content
- OAC’s new internet, intranet websites and web content on those sites conforms to the WCAG 2.0, in accordance with the Regulation.
- All new internet websites and web content on those sites will comply to the WCAG 2.0 Level A by January 1, 2014;
- As of January 1, 2021 all internet, intranet and web content will conform with the WCAG 2.0 Level AA, other than: success criteria 1.2.4 Captions (Live) and success criteria 1.2.5 Audio Descriptions (Pre-recorded);
- Websites and web content, including web-based applications, that OAC controls directly or through a contractual relationship that allows for modification of the product, are included in this timeline, where practicable;
- In determining practicability, consideration will be given to the availability of commercial software, or tools or both, and whether planned or initiated implementation timelines (before January 20) will be significantly impacted
Employment Standards
- Recruitment
- OAC notifies its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment processes;
- During a recruitment process, applicants who are individually selected to participate in an assessment or selection process, are notified that accommodations are available upon request in relation to the materials or processes used;
- If a selected applicant requests an accommodation, OAC consults with the applicant, having regard for the applicant’s accessibility needs, on the provision of a suitable accommodation;
- When making an offer of employment, OAC will notify the successful applicant of its policies for accommodating employees with disabilities.
- Informing employees of supports
- OAC informs its employees of its policies used to support its employees with disabilities, including, but not limited to, policies on job accommodation that take into account the employee’s accessibility needs due to a disability.
- New employees will be informed as soon as practicable after they begin their employment.
- Where there are changes to existing policies on the provision of job accommodation, all employees will be provided updated information.
- Accessible formats and communication supports for employees
- Where an employee requests it, the OAC will consult with the employee to provide or arrange for the provision of accessible formats and communication supports for:
- Information that is needed in order for the employee to perform the employee’s job; and
- Information that is generally available to employees in the workplace.
- OAC will consult with the employee making the request in determining the suitability of an accessible format or communication support.
- Workplace emergency response information
- OAC provides individual workplace emergency response information to employees who have a disability;
- Where the disability is such that individual information is necessary, and
- Where OAC is aware of the need for accommodation due to the employee’s disability.
- If an employee with individualized workplace emergency response information requires assistance and provides consent, OAC will provide the individualized information to the person designated by OAC to provide assistance to the employee.
- Individualized information is provided as soon as practicable after OAC becomes aware of the need for accommodation due to an employee’s disability.
- OAC will review the individualized workplace emergency response information
- When the employee moves to a different location;
- When the employee’s overall accommodation needs or plan are reviewed;
- When the OAC reviews its general emergency response policies.
- Documented individual accommodation plans
- The OAC process for the development of Individual Accommodation Plans for employees with disabilities is as follows:
- Employee identifies to their Manager and Human Resources as soon as reasonably possible that accommodation is required in order to return to work, with a description of the disability and what types of accommodation should be considered.
- Depending on the request a medical note may be required that would specify such things as what symptoms and/or conditions the accommodation would address and if applicable, the duration that the accommodation may be required.
- The Manager and Human Resources shall discuss the request and assess all options and possibilities with respect to the employee, their position and what OAC can do within reason to provide accommodation that would suitably address the symptoms and/or conditions.
- The Manager and Human Resources will communicate back to the employee on options available and consult on an implementation plan, and follow up plan if required.
- The decision on accommodation will then be documented in writing to the employee and placed in the employee’s personnel file.
- The Manager is to follow up with the employee according to a progress schedule, if required, and/or during the annual performance appraisal.
- Return to work
OAC has 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. The process is the same as the process for providing accommodations and the creation of an Individual Accommodation Plan, as follows:
- Employee identifies to their Manager and Human Resources as soon as reasonably possible that accommodation is required in order to return to work, with a description of the disability and what types of accommodation should be considered.
- Depending on the request a medical note may be required that would specify such things as what symptoms and/or conditions the accommodation would address and if applicable, the duration that the accommodation may be required.
- The Manager and Human Resources shall discuss the request and assess all options and possibilities with respect to the employee, their position and what OAC can do within reason to provide accommodation that would suitably address the symptoms and/or conditions.
- The Manager and Human Resources will communicate back to the employee on options available and consult on an implementation plan, and follow up plan if required.
- The decision on accommodation will then be documented in writing to the employee and placed in the employee’s personnel file.
- The Manager is to follow up with the employee according to a progress schedule, if required, and/or during the annual performance appraisal.
- Performance Management
Where the OAC uses performance management in respect of its employees, the accessibility needs of employees with disabilities, and individual accommodation plans are taken into account.
- Career Development and Advancement
Where the OAC uses career development and advancement in respect of its employees, the accessibility needs of employees with disabilities, and individual accommodation plans are taken into account.
- Redeployment
Where the OAC uses redeployment in respect of its employees, the accessibility needs of employees with disabilities, and individual accommodation plans are taken into account.
Accessibility Standards for Service to the Public Policy
The following policy, practices and procedures have been established by the Ontario Arts Council to govern the provision of its services in accordance with the Accessibility for Ontarians with Disabilities Act, 2005 and Regulation 429/07 “Accessibility Standards for Customer Service”.
Our mission
The mission of the Ontario Arts Council is to foster the creation and production of art for the benefit of all Ontarians.
Our commitment
In fulfilling our mission, the Ontario Arts Council strives at all times to ensure that our policies, practices and procedures are consistent with the principles outlined in the Accessibility Standards for Customer Service, specifically:
- Our programs and services must be provided in a manner that respects the dignity and independence of persons with disabilities
- Persons with disabilities must be given the same opportunity provided to other members of the public to access our programs and services
- Persons with disabilities are encouraged to contact us to identify and discuss whether the provision of our programs and services could be provided in ways that would better take into account their disability. Please see section nine of this policy for more details on the feedback process.
Communication
We will communicate with persons with disabilities in ways that take into account their disability.
We will communicate with members of the public in person, in writing, by electronic mail, telephone, and through relay services.
We will train staff who communicate with the public on how to interact and communicate with persons with various types of disabilities.
Assistive devices
We are committed to serving persons with disabilities who use assistive devices to access our programs and services.
Our staff will be trained on any assistive devices available on our premises.
Use of service animals
We recognize that some individuals with disabilities may require the use of service animals in order to access our premises and services. We welcome people with disabilities and their service animals to parts of our premises that are open to the public and third parties.
When we cannot easily identify that an animal is a service animal, our staff may ask for documentation from a regulated health professional that confirms the person needs the service animal for reasons relating to their disability.
If service animals are prohibited by another law, we will do the following to ensure the person can access our services or premises:
- explain why the animal is excluded
- discuss with the person alternate methods of providing information or services
Use of support persons
We recognize that some individuals with disabilities rely on support persons for assistance while accessing our premises, programs and services. We welcome people with disabilities and their support person to parts of our premises that are open to the public and third parties. They will not be prevented from having access to each other while on the premises.
In certain cases, we might require a person with a disability to be accompanied by a support person for the health or safety reasons of:
- the person with a disability
- others on the premises
Before making a decision, we will:
- consult with the person with a disability to understand their needs
- consider health or safety reasons based on available evidence
- determine if there is no other reasonable way to protect the health or safety of the person or others on the premises
Support persons accompanying or assisting individuals with disabilities may be required to abide by our conflict of interest and confidentiality policies.
When support persons (e.g., sign language interpreters, real-time captioners, attendants) are required for Ontario Arts Council sponsored meetings, consultations, events or information sessions, the Ontario Arts Council will arrange for and cover the costs for the necessary support persons to be present.
If a person requests ahead of time to have their own support person present, the Ontario Arts Council may enter into an agreement with the person to pay support persons directly for their time and reasonable travel expenses on request, in accordance with government travel and hospitality guidelines.
Notice of temporary disruption
The Ontario Arts Council will provide the public with notice in the event of a planned or unexpected disruption to the facilities or services usually accessed by persons 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 of the disruption will normally be posted at all public entrances to our premises. Depending on the nature of the disruption, notice will also be provided on outgoing telephone messages and on our web-site.
Training for staff
The Ontario Arts Council will provide training to its staff who deal with the public, and all those who are involved in the development and approvals of public service policies, practices and procedures, about the provision of services to persons with disabilities.
Staff will be trained on an ongoing basis when changes are made to these policies, practices and procedures. New staff will be trained as part of their orientation upon employment.
Training will include the following:
- A review of this policy and any other practices and procedures relating to the Accessibility Standards for Customer Service
- The purposes of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of Accessibility Standards for Customer Service
- How to interact and communicate with people with various types of disabilities, including those who use assistive devices, service animals or support persons
- How to use any equipment or devices available on our premises, or otherwise, that may assist with the provision of programs or services to persons with disabilities
- What to do if a person with a disability is having difficulty in accessing Ontario Arts Council’s programs and services
The Ontario Arts Council will keep a record of the training it provides.
Feedback process
The ultimate goal of this policy is to meet program and service expectations while serving persons with disabilities. Comments on our programs and services regarding how well those expectations are being met are welcome and appreciated.
The Ontario Arts Council will let the public know that methods are available for giving feedback. If a method is not suitable, individuals may request another method. Privacy will be respected and all feedback will be reviewed for possible action that can be taken to improve access to our programs and services.
Feedback received will be directed to the Ontario Arts Council’s Director of Human Resources and will be addressed in accordance with our normal complaints administration procedures and timelines. Where possible, complaints will be addressed immediately. However, some complaints may require more time to address, and must be reviewed for action, possibly at a higher level.
Feedback responses will endeavour to be in a format that is accessible to the complainant.
Modifications to this or other policies
We are committed to ensuring that our public service policies, practices and procedures respect and promote the dignity and independence of all persons with disabilities. Therefore, no changes will be made to this policy before considering the impact on persons with disabilities.
Any policy of the Ontario Arts Council affecting service to the public that does not respect and promote the dignity and independence, integration and equal opportunity of persons with disabilities will be modified or removed.
Questions about this policy
This policy exists to achieve service excellence to persons with disabilities. If anyone has a question about the policy, or if the purpose of this policy is not understood, please contact:
Nina Small, Director of Human Resources
121 Bloor St East, 7th Floor
Toronto, ON M4W 3M5
Telephone: 1-800-387-0058 or 416-969-7426
nsmall@arts.on.ca