OHRC - Multi year disability accessibility plan

Section 1: Introduction

OHRC statement of commitment:

The Ontario Human Rights Commission (OHRC) supports the full inclusion of persons with disabilities as set out in the United Nations’ Convention on the Rights of Persons with Disabilities, the Canadian Charter of Rights and Freedoms, the Ontario Human Rights Code, the OHRC’s Policy and guidelines on disability and the duty to accommodate, the Ontarians with Disabilities Act (ODA) 2001 and the Accessibility for Ontarians with Disabilities Act (AODA) 2005. The OHRC is committed to complying with the accessibility standards set out in the AODA’s Integrated Accessibility Standards Regulation (IASR) and the Accessibility Standards for Customer Service Regulation.

Regulations under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) include accessibility standards in:

  • Customer service
  • Information and communications
  • Employment
  • Transportation
  • The Built Environment

The Integrated Accessibility Regulation (IASR) under the AODA was enacted in June 2011. Section 4(1) of the IASR requires the Government of Ontario and designated public sector organizations, including the OHRC, to create, maintain and make publicly available a multi-year accessibility plan. The accessibility plan must be created, reviewed and updated in consultation with persons with disabilities.[1] The multi-year accessibility plan must also be reviewed at least once every five years, and all organizations are required to prepare an annual status report on the progress that the organization has made to implement their accessibility plan and comply with the IASR. The status reports must be made available to the public.[2]

The Ontario Public Service’s (OPS) Multi-Year Accessibility Plan describes the organization’s commitment to accessibility, and the steps the government is taking to prevent and remove barriers for persons with disabilities in employment, services, and in making policy. For more information about the OPS’ commitment to accessibility for persons with disabilities, refer to the Ontario Public Service Multi-Year Accessibility Plan. The OPS’ plan outlines the government’s strategies to prevent, identify and remove barriers for persons with disabilities. Each ministry prepares an annual accessibility plan, as required under the Ontarians with Disabilities Act, 2001 (ODA). The Ministry of the Attorney General’s Accessibility Plan sets out what the ministry plans to do to prevent and remove barriers for persons with disabilities, and what steps it is taking to comply with the requirements set out in the AODA and its regulations.

The OHRC has its own commitments to accessibility. We are guided by our Policy and guidelines on disability and the duty to accommodate. We also provide eLearning information on accessibility, such as our eLearning module on the duty to accommodate.

This document outlines the steps the OHRC has taken and plans to take during the next five years (2014-2019) to:

  1. prevent and remove barriers for persons with disabilities
  2. meet the standards set out in the Accessibility for Ontarians with Disabilities Act, 2005 and its regulations.

Section 2: Current accessibility policies, practices, facility and service features

General

The OHRC works to advance the understanding of the duty to accommodate and accessibility using our mandate under the Ontario Human Rights Code. For example, the OHRC recently released Minds that Matter: Report on the consultation on human rights, mental health and addictions, and is developing a policy on mental heath and addictions for release in 2014. An eLearning module on human rights and the duty to accommodate is available on the OHRC’s website, and the organization routinely provides training to the public on these topics.

Systems and practices are already in place to help the OHRC comply with the requirements under the AODA, the Accessibility Standards for Customer Service, Ontario Regulation 429/07, the Integrated Accessibility Standards, Ontario Regulation 191/11 and the Human Rights Code

Customer Service

  • Communications supports including ASL interpretation and captioning are provided at OHRC-hosted public events; other forms of accommodation are available upon request
  • All OHRC-hosted public events take place at accessible locations. The Special Events Coordinator visits each proposed event space to make sure that it is fully accessible
  • Standard language on all invitations invites people to contact the OHRC about additional Ontario Human Rights Code-related accommodation requests before event dates
  • As required under Section 7 of the AODA Accessibility Standards for Customer Service Regulation, a web-based feedback process is available to help the OHRC better understand how well customer expectations are being met. People can also provide feedback via telephone, TTY, mail or fax.

Information and Communications

  • The OHRC has developed and launched a website that is designed to comply with the World Wide Web Consortium (W3C) Web Content Accessibility Guidelines (WCAG) 2.0, Level AA  (www.ohrc.on.ca)
  • Staff are provided with specialized training on emerging technologies, designing accessible e-learning modules, and other topics to improve the accessibility of the OHRC’s online resources
  • Staff routinely take steps to make sure that the organization’s website and communications products are as accessible as possible, including:
    • The tools and products that are used to develop the website and other online materials have built in accessibility features
    • Web developers and any other external vendors are selected, in part, based on their experience designing accessible websites.
    • Any online materials, such as e-learning modules, are tested regularly during their development and are tested on an ongoing basis by staff and by external contacts who have disabilities
  • The OHRC provides local and toll free TTY numbers for communication with people who are deaf, deafened or hard of hearing
  • The OHRC uses a range of communication methods such as email and social media platforms to communicate with stakeholders and communities
  • All public documents including correspondence and publications are available in accessible digital formats, including accessible PDFs for all new publications. Captioning and transcripts are provided for all video content
  • All staff are expected to use plain language to write publications, documents, training materials and correspondence. Assistance with plain language editing is available for all OHRC policies and publications.

Employment

  • The OHRC is a scent-sensitive workplace. A Scent sensitivity policy exists to accommodate staff who report various sensitivities to chemicals or scents.
  • The OHRC follows the OPS’ Employee Accommodation and Return to Work Guidelines and Operating Policy for developing and documenting individual accommodation plans, return-to work plans and workplace emergency response information for employees with disabilities. 
  • The Orientation Manual for new OHRC employees includes information about employees’ rights and responsibilities under the Ontario Human Rights Code, the AODA and OPS Policies that foster an inclusive workplace. These include the Scent Sensitive Policy, the internal Human Rights Policy, and the OHRC’s Policy on providing goods and services to people with disabilities

Accessibility Training

The OHRC has an internal guide on plain language writing and staff have been trained on plain language writing.

Section 3: Strategies and actions planned to 2019

The OHRC is planning take the following steps help meet the goal of being an organization that is fully accessible to persons with disabilities. These activities will help the OHRC comply with the Ontario Human Rights Code, the AODA, the IASR and the AODA Accessibility Standards for Customer Service in the following areas:

  • Customer Service
  • Information and Communications
  • Procurement
  • Accessibility Training
  • Employment.

General

The OHRC is committed to advancing the human rights of persons with disabilities using our mandate under the Code, through activities such as public education, policy development, public inquiries and litigation. The OHRC makes the following commitments on promoting the human rights of persons with disabilities.

  • The OHRC will take steps to ensure that its workspaces and common areas are accessible for persons with disabilities. The OHRC will perform an inclusive design review of its offices to make sure that they are accessible for visitors and employees with disabilities. The Ministry of the Attorney General’s facilities branch will be involved in this review, where necessary.
    Timeline: 2015-2019

Customer Service

The OHRC is committed to providing customer service in a way that best respects the dignity and independence of persons with disabilities. The OHRC will continue to adhere to its policies and procedures on Providing goods and services to people with disabilities and the Accessibility Standards for Customer Service Regulation.

  • The OHRC will amend staff email signatures to include information about the OHRC’s policy on providing goods and services to people with disabilities.
    Timeline: 2014
  • The OHRC will include feedback opportunities at the end of education and training sessions to understand how well Code-related accommodation needs of participants are being met and will consider opportunities for improvement.
    Timeline: ongoing

Information and Communications

  • The OHRC is committed to making sure its information and communications systems and products are accessible for persons with disabilities.
  • The OHRC will amend the telephone script to improve accessibility by, for example, reducing the number of options in the script, making it easier to connect to staff directly, and by removing superfluous pre-recorded information.
    Timeline: underway
  • The OHRC will develop an internal document template with clear guidelines on accessibility standards and formatting for OHRC publications and correspondence. The document will be based on the accessibility components in the OPS’ Correspondence Style Guide (2012)[3]. Staff will receive training on accessibility standards for correspondence, and will be expected to adhere to the organization’s guidelines on accessible correspondence. 
    Timeline: 2014
  • The OHRC will conduct reviews to identify and address any barriers in the ways that the organization makes information available to the public. The OHRC will continue to review website accessibility with external organizations and persons with disabilities to maintain the highest possible level of accessibility for users with disabilities and to keep up with emerging trends and technologies.
    Timeline: 2014 and ongoing

Procurement

The OHRC is committed to integrating accessibility considerations into procurement processes and will continue to comply with the OPS’ Guidelines: Meeting Accessibility Obligations in Procurement and the Management Board of Cabinet Procurement Directive, April 2011 as well as the Accessibility for Ontarians with Disabilities Act, 2005 and its regulations regarding accessibility in procurement. 

  • The OHRC will identify accessibility requirements in project terms of reference, requests for proposals and contracts with third-party service providers. 
    Timeline: ongoing
  • Where necessary, staff with disabilities may be consulted about any accessibility considerations at the outset of the procurement so that they are included in the contract.
    Timeline: ongoing

Employment

Sections 22-32 of the IASR require that employers take steps to ensure that employees are offered appropriate accommodation throughout their careers in a way that best respects their dignity and supports their full inclusion and advancement. The OHRC is committed to accessible employment practices and policies to attract and retain employees with disabilities. The OHRC is also committed to providing accommodation to employees with disabilities in a way that allows them to take part fully and meaningfully in the OHRC’s work, in a way that best respects their dignity. The OHRC also believes that inclusive design and integration are preferable to individual accommodations, where possible.

  • The OHRC will continue to adhere to the Ontario Public Service’s policies and procedures on employment accommodation for both current and prospective employees with disabilities, as well as the standards outlined in the IASR.
    Timeline: ongoing
  • The OHRC is committed to ensuring that the recruitment process for new staff is accessible. For example, the OHRC will review and monitor whether hiring managers always tell prospective employees that accommodations are available throughout the interview process. The OHRC will also explore ways to advise candidates about the type of testing that they will be expected to do during the interview process so that job applicants can request an appropriate accommodation for their disability for each job competition.[4]
    Timeline: Starting in 2014 and ongoing.
  • The OHRC will create an accessible quiet room for staff and visitors. This will  improve accessibility for persons with disabilities who may require, for example, the room to take medication or rest, and it will also improve accessibility for staff and visitors based on creed. It will also improve accessibility for women who are breastfeeding.
    Timeline: 2014
  • In accordance with Sections 12 and 26 of the IASR, the OHRC will review the software and systems it uses to manage and store information to identify and address any barriers for employees with disabilities. These reviews will be done in consultation with employees with disabilities, and may result in changes to OHRC business rules or recommendations to explore new software.
    Timeline: 2015-2019

Accessibility Training

The OHRC will continue to provide training on disability and the duty to accommodate to all staff. As part of its mandate, the OHRC will also continue to offer training on disability and the duty to accommodate to the public.

  • The OHRC will provide ongoing training to all staff and commissioners on human rights for persons with disabilities. The OHRC will develop a training plan to ensure that all staff and Commissioners receive ongoing training on accessibility and the duty to accommodate for disability and other grounds of the Human Rights Code. For example, the OHRC will also train all staff on the OHRC’s new Policy on mental health and addictions. 

Timeline: ongoing

Feedback Process:

The OHRC encourages feedback about the its accessibility, including customer service, website, employment practices, procurement, etc. Feedback can be submitted using an online request form, which is available at: www.ohrc.on.ca/en/contact/ohrc-feedback.  Feedback may also be made in writing, by telephone, TTY or email[5] to:

Ontario Human Rights Commission
Executive Director’s Office
180 Dundas Street West, Suite 900
Toronto, ON M7A 2R9 

Tel: 416-314-4562
Toll Free: 1-800-387-9080
Fax: 416-325-2004
TTY Local: 416-326-0603
TTY Toll Free: 1-800-308-5561
Email: info@ohrc.on.ca

The Executive Director or a delegate will review the customer feedback, investigate the situation, try to resolve it and provide a response within 14 business days of receiving the information.

Conclusion

The OHRC will report annually about our progress on these commitments to identify and remove barriers for persons with disabilities, and the steps we have taken to comply with the requirements of the IASR. The OHRC will also report publicly on any barriers for persons with disabilities that are raised through the feedback process, and will identify the steps it is taking to address them, where possible.


[1] Section 4 (2) of the IASR requires that: “The Government of Ontario, Legislative Assembly and designated public sector organizations shall establish, review and update their accessibility plans in consultation with persons with disabilities and if they have established an accessibility advisory committee, they shall consult with the committee.” O. Reg. 191/11, s. 4 (2).

[2]IASR Section 4 (3): “The Government of Ontario, Legislative Assembly and designated public sector organizations shall,

(a) prepare an annual status report on the progress of measures taken to implement the strategy referenced in clause (1) (a), including steps taken to comply with this Regulation; and

(b) post the status report on their website, if any, and provide the report in an accessible format upon request.” O. Reg. 191/11, s. 4 (3); O. Reg. 413/12, s. 3 (1).

[4] Section 23 of the IASR requires that hiring managers inform job applicants that accommodations are available upon request in relation to the testing and interviewing materials or process. If a job applicant requests accommodation, the hiring manager must consult with the applicant and provide or arrange for a suitable accommodation. However, job applicants may not know what format the testing will take (for example, that reading a large amount of materials will be required) during the interview process, and therefore may not know if they need accommodation, or what type of accommodation is appropriate.

[5] Section 11 of the IASR requires that organizations with processes for receiving and responding to feedback make sure those processes are accessible for persons with disabilities by providing accessible formats and communication supports on request.  

 

Code Grounds: 
Organizational responsibility: