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1. POLICY STATEMENT
1.1 Groupe Média TFO supports the full participation of persons with disabilities in its workplace and as providers of its services, as defined in the Canadian Charter of Rights and Freedoms, the Ontario Human Rights Code, and the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”).
1.2 Groupe Média TFO commits itself to ensuring equal access and participation for persons with disabilities, and to treating them in a manner that maintains their dignity and independence.
1.3 Groupe Média TFO believes in the full inclusion of persons with disabilities. The organization commits itself to addressing the needs of such persons by removing and preventing barriers to accessibility, by educating its members, employees and volunteers, and by meeting the requirements set forth in Ontario’s accessibility laws.
2.1 The purpose of this policy is to ensure that all persons with disabilities are treated courteously and feel welcomed, safe, and valued, whether their disability is visible or invisible to others.
2.2 The policy also aims to ensure that persons with disabilities are consulted about how their accommodation needs can be met.
3.1 This policy outlines the minimum requirements for creating an accessible workplace and governing the provision of Groupe Media TFO’s services in a manner that respects the dignity and independence of persons with disabilities.
3.2 This policy seeks to guarantee that persons with disabilities are treated with the same level and expediency of care offered to everyone else, and that they are provided equal access to Groupe Média TFO’s goods and services. This policy also endeavours to ensure they benefit from the same services, in the same place and in equitable ways.
3.3 This policy must be applied to all staff members, members of the Board of Directors, volunteers, and other individuals who deal with the public or other third parties on behalf of Groupe Média TFO.
4.1 Policies follow certain wording conventions that determine the degree to which they are mandatory or optional. There are precise requirements and obligations associated with the following terms:
- Shall/Must: This requirement is not optional.
- Should: The implementer must choose this action unless business functionality dictates otherwise. Exceptions must be approved by management.
- May: The implementer may choose to pursue one or more of the options presented, but a choice must be made, as dictated within the context of the item.
4.2 The words “include” and “including” are not used in an exclusive sense. Both words mean “including, but not limited to.”
4.3 Disability: The definition of a disability includes
- any degree of physical disability, infirmity, malformation or disfigurement;
- 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 by the Workplace Safety and Insurance Act, 1997.
- This definition includes disabilities ranging in severity, visible and non-visible disabilities, and disabilities with episodic symptoms.
4.4 Service animal: An animal is a service animal for a person with a disability in the following cases:
- It is readily apparent that the animal is used by the person for reasons relating to a disability.
- The person provides a letter from a doctor or nurse confirming that they require the animal for reasons relating to their disability.
4.5 Guide dog: a “guide dog” as defined in section 1 of the Blind Persons Rights’ Act.
4.6 Support person: a person who accompanies a person with a disability in order to help with communication, mobility, personal care or medical needs, or with access to goods or services.
5.1 Management is responsible for ensuring compliance with the requirements outlined in this policy.
5.2 In principle, there must be no deviation or exemption from the requirements outlined in this policy.
5.3 Management must report cases of non-compliance, deviation or exemption related to the requirements in this policy to the Board of Directors.
6.1 Groupe Média TFO employees must be made aware of the provisions of the Ontario Human Rights Code and the AODA (2005) that are applicable to the organization and to the services it provides.
6.2.1 Training plays an important part in the implementation of the AODA. It ensures employees are aware of the needs of persons with disabilities and explains how and why to address those needs.
6.2.2 All Groupe Média TFO’s employees, volunteers, representatives and decision-makers must receive training in relation to
- the AODA requirements and accessibility standards applicable to Groupe Média TFO;
- customer service;
- accessible information and communication, including websites;
- workplace emergency response information; and
- obligations under the Ontario Human Rights Code (pertaining to disabilities).
6.3 Assistive Devices:
6.3.1 Groupe Média TFO commits itself to serving persons with disabilities who use assistive devices to obtain, use or benefit from our goods and services.
6.3.2 Groupe Média TFO shall ensure that its employees are trained and familiar with various assistive devices that may be used by customers with disabilities in accessing our goods or services.
6.4 Service Animals:
6.4.1 Groupe Média TFO commits itself to welcoming persons with disabilities who are accompanied by a service animal on the parts of our premises that are open to the public, unless the animal is otherwise excluded by law from the premises.
6.4.2 Staff members and other individuals who deal with the public shall be properly trained on how to interact with persons with disabilities who are accompanied by a service animal.
6.4.3 Should Groupe Média TFO determine that laws prohibit the entry of a service animal or require the presence of a support person, an appropriate alternative shall be provided.
6.5 Support Persons:
6.5.1 Groupe Média TFO commits itself to welcoming persons with disabilities who are accompanied by a support person.
6.5.2 In no way shall a person with a disability who is accompanied by a support person be prevented from having access to them on premises that are open to the public.
6.6 Information on Accessible Emergency Plans or Procedures:
6.6.1 Groupe Média TFO commits itself to providing publicly available emergency plans and procedures to its customers in an accessible format upon request.
6.6.2 Groupe Média TFO shall also provide individualized information on emergency plans or procedures to its employees with disabilities.
6.7.1 Groupe Média TFO’s goal is to meet customer service expectations when serving customers with disabilities.
6.7.2 Groupe Média TFO encourages and appreciates comments about the way it provides services and meets expectations.
6.7 Feedback on the way Groupe Média TFO provides goods and services to persons with disabilities can be given by email, by mail, by phone, in person, via the accessibility feedback form available online or in paper format (upon request), or via any other method that best suits the person’s communication needs.
6.7.4 Our feedback process calls for all comments to be submitted to Groupe Média TFO’s management team to be recorded, processed and replied to within 30 days.
6.8 Information and communication:
6.8.1 Groupe Média TFO and its employees must communicate with persons with disabilities in a manner that take their disabilities into account. Groupe Média TFO shall train its staff members on how to interact and communicate with persons with various disabilities.
6.8.2 Telephone Services: Groupe Média TFO shall provide telephone services to its customers using Bell Canada’s relay service, as required. Groupe Média TFO shall train its staff members to communicate with people over the phone using clear, simple language.
6.8.3 Written documents: Groupe Média TFO shall provide documents pertaining to its customer service policies and procedures to its customers, staff members and other persons with disabilities upon request. Groupe Média TFO may provide its accessibility standards policies and procedures in an alternate media format mutually agreed upon between Groupe Média TFO and the person with a disability. Groupe Média TFO will answer any questions customers may have regarding the content of these policies and procedures by phone, by email or in person.
6.8.4 Accessible formats and communication supports: Should anyone request information regarding Groupe Média TFO or its services, including public safety information, said information must be provided using accessible media or communication supports.
6.8.5 Accessible websites and web content: Groupe Média TFO’s websites must meet the requirements outlined in the internationally accepted WCAG 2.0 standards.
6.8.6 Temporary disruptions: Groupe Média TFO shall provide public notice in the event of a temporary disruption (whether planned or unplanned) of the facilities or services habitually used by persons with disabilities. The notice shall specify the reason for the disruption, its anticipated duration, and any available alternative facilities or services. The notice shall be posted in Groupe Média TFO’s reception areas. Depending on the nature of the disruption, the organization may provide a recorded telephone message and post a notice on its website.
6.9.1 When procuring goods and services, Groupe Média TFO must ensure that proper consideration is given to accessibility criteria and features.
6.10.1 Notice to selected applicants and recruits: Employees, future recruits and the public must be made aware of the availability of accommodation during recruitment and hiring processes.
6.10.2 Informing employees of support measures: Employees must be made aware of the kinds of support available to persons with disabilities.
6.10.3 Individual accommodation plans: A process for developing individual accommodation plans for employees must be implemented. Individual accommodation plans shall be developed in consultation with the person with disabilities.
6.10.4 Workplace emergency response: If necessary, individualized emergency information, which aims to provide assistance to an employee with disabilities in the event of an emergency, must be developed and delivered in a format that is accessible to the person in question.
6.10.5 Performance management: All performance management, professional development and redeployment processes must take into account the accessibility needs of all employees.
6.10.6 Return to work process: Upon returning to work following a sick leave, an employee with disabilities must be given the opportunity to demonstrate a capacity to perform essential job tasks once accommodation is provided.
6.10.7 Work environment: Management commits itself to building, fostering and maintaining a work environment that is respectful of employees with disabilities and their rights.
6.11 Accessibility plans:
6.11.1 Groupe Média TFO commits itself to developing a multi-year accessibility plan that outlines the steps it will take to comply with Ontario’s accessibility laws in order to identify, prevent and remove barriers to accessibility.
6.11.2 Groupe Média TFO’s management team shall provide annual progress reports to the Board of Directors.
6.11.3 The accessibility plan shall be publicly available on Groupe Média TFO’s website.
6.12 Built environments and public spaces:
6.12.1 Service counters: Groupe Média TFO shall ensure that all newly constructed service counters and all replacements for existing counters accommodate mobility aids and comply with the Integrated Accessibility Standards Regulation and the Ontario Building Code.
6.12.2 Waiting areas: Groupe Média TFO shall ensure that the waiting or reception area is accessible to individuals using mobility aids and that it complies with the Integrated Accessibility Standards Regulation and the Ontario Building Code.
6.12.3 Parking: Groupe Média TFO shall ensure that parking areas are accessible to persons with disabilities and comply with the Integrated Accessibility Standards Regulation and the Ontario Building Code.
6.12.4 Constructing, fitting out and redeveloping offices: Groupe Média TFO commits itself to complying with the accessibility requirements set out under the Ontario Building Code for the construction, renovation, fitting out and redevelopment of its offices.
6.12.5 Maintenance: Groupe Média TFO shall establish preventative and emergency maintenance procedures for the accessible elements of its built environment and public spaces.
6.12.6 Disruptions: Groupe Média TFO shall establish procedures for dealing with temporary disruptions caused by problems with the accessible elements required by law.
7.1 The Human Resources Services Branch is accountable for this policy.
7.2 The Human Resources Services Branch is responsible for documenting the implementation of this policy in compliance with the Act and with applicable regulations.
7.3 The Human Resources Services Branch is responsible for implementing, interpreting, and enforcing this policy.
7.4 Employees are responsible for knowing and following the requirements set out in this policy for offering inclusive, accessible services and for interacting with their colleagues. Any concerns should be raised at an appropriate time and in an appropriate fashion, according to protocol.
7.5 All employees are expected to keep up with changes to this policy, should they occur.
7.6 The Board of Directors must review this policy at least every twelve (12) months to ensure its viability. Following this review, it shall oversee any necessary amendments to this policy.
8. PUBLICATION AND NOTIFICATION
8.1 A copy of the current policy and related documents shall be available in electronic form at the following web address: www.tfo.org.
8.2 Employees must be informed of any significant change or modification to this policy.
8.3 Employees should periodically visit Groupe Média TFO’s website to learn about any changes to the current policy and to related guidelines and procedures.
9.1 Each provision of this policy and any relevant agreement pursuant to it shall be interpreted in such manner as to be effective and valid under applicable laws of Ontario and Canada, including, but not limited to
- Accessibility for Ontarians with Disabilities Act, 2005 (AODA);
- Ontario Regulation 429/07: Accessibility Standards for Customer Service;
- Ontario Regulation 191/11: Integrated Accessibility Standards;
- Ontario Regulation 332/12: Building Code; and
- Ontario Human Rights Code.
9.2 Failure on behalf of Groupe Média TFO at any time to enforce the provisions in this policy, or failure at any time to require the performance of any provision of this policy by any other party, shall in no way constitute a present or future waiver of such provisions, nor shall it in any way affect Groupe Média TFO’s ability to enforce any such provisions at a later time. The express waiver by Groupe Média TFO of any provision, condition or requirement in this policy, as well as related agreements, shall not constitute a waiver of any future obligation to comply with such provisions, conditions or requirements.
10. QUESTIONS ABOUT THIS POLICY
This policy was developed to help remove barriers and increase accessibility for persons with disabilities. Anyone with a question about this policy or requiring clarification about the purpose of a given policy may contact the Human Resources Services Branch for an explanation.
11. POLICY HISTORY
Effective date: September 11, 2015 Board resolution: 2015.CA.69.5
This policy replaces and supersedes the following policy:
- Services à la clientèle – fourniture de biens et de services aux personnes handicapées (in French only), which came into effect on January 1, 2010.