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OHRC multi-year AODA accessibility plan 2020–21 – 2025–26

Code Grounds
disability
Organizational responsibility
accessibility
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Introduction

This document outlines the Ontario Human Rights Commission’s (OHRC) multi-year AODA accessibility plan (accessibility plan) for 2020–21 – 2025–26 to:

  1. Prevent and remove barriers for persons with disabilities
  2. Meet the requirements set out in the Accessibility for Ontarians with Disabilities Act, 2005 and its regulations.

Statement of commitment

The 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 (Code), the OHRC’s Policy on ableism and discrimination based on disability, and the Accessibility for Ontarians with Disabilities Act, 2005 (AODA). The Code has primacy over the AODA. The OHRC is committed to complying with the accessibility standards set out in the AODA’s Integrated Accessibility Standards Regulation (IASR) and the duty to accommodate disability related needs under the Code.

AODA requirements

Ontario Regulation 191/11: Integrated Accessibility Standards (IASR) under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) include accessibility standards for:

  • Policies, training, plans and reports
  • Procurement
  • Customer service
  • Information and communications
  • Employment
  • Transportation
  • The built environment.

Section 4 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. The accessibility plan must also be reviewed at least once every five years, and all organizations are required to report annually on the progress they have made to implement the accessibility plan and comply with the IASR. The status reports must be made available to the public.

The Ontario Public Service’s 2017–21 OPS Multi-Year Accessibility Plan describes the OPS’ 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. The OPS accessibility plan outlines the government’s strategies to prevent, identify and remove barriers for persons with disabilities. The Ministry of the Attorney General’s Accessibility for People with Disabilities 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 considered these requirements and plans in the development of its accessibility plan.

Guiding principles and policies

In accordance with section 3 of the IASR, and our mandate under section 29 of the Code, we have established and are also guided by our policies and other functions that promote, protect and advance understanding of human rights for people with disabilities.

For example, the OHRC has published various policies and reports including its Policy on ableism and discrimination based on disability, Minds that Matter: Report on the consultation on human rights, mental health and addictions, and its Policy on preventing discrimination based on mental health disabilities and addictions. The OHRC has also published eLearning modules on Ableism and discrimination based on disability, Human rights and the duty to accommodate and Working Together: The Code and the AODA.

Application

The OHRC accessibility plan applies to:

 

Strategies and actions for 2020–21 – 2025–26

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 to meet the goal of being an organization that is fully accessible to persons with disabilities. The OHRC’s activities will help us comply with the Code, the AODA and the IASR in the following areas:

  • Customer service
  • Information and communications
  • Employment
  • Accessibility training
  • Procurement.

Customer service

In accordance with Part IV.2 of the IASR, the OHRC is committed to ensuring that all individuals have access to and can effectively use its services, goods and facilities. The OHRC has the following in place to meet its obligations and commitments:

  • Customer service policy on Providing goods and services to people with disabilities, as required by the IASR
  • Communications supports such as sign language interpretation and captioning for OHRC-hosted public events as required; other forms of accommodation are available upon request
  • All OHRC-hosted public events take place at accessible locations or on accessible video conferencing platforms. The OHRC takes steps to confirm that each physical and virtual event space is fully accessible before finalizing an event
  • Standard language on all invitations invites people to contact the OHRC about additional Code-related accommodation requests before event dates
  • As required under Section 11 of the IASR, 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
  • 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 customer service policy on Providing goods and services to people with disabilities and the IASR by:
    • Ensuring that stakeholders, clients and employees are aware of their roles and responsibilities under this accessible customer service procedure
    • Promptly addressing accommodation and accessibility issues identified in a dignified and respectful way, to facilitate effective access to, and participation in, OHRC services
    • Responding to identified accommodation and accessibility needs on an individual basis.

In consultation with people with disabilities, the OHRC will review and make any necessary changes to improve the accessibility of its:

  • Customer service policy and practices in accordance with the standards under the IASR, including:
    • Routinely asking individuals if they require any disability-related accommodations or assistance
    • Reviewing potential barriers that visitors with disabilities may experience when arriving at the OHRC’s offices, including the accessibility of the current elevator lobby phone, staff phone list and lack of “glass door” reception for visitors with vision and/or hearing loss or other types of disabilities
    • Clarifying that the customer service policy applies to individuals who use mobility devices
    • Reviewing potential barriers that individuals who use mobility devices may experience within the OHRC’s offices, including along internal paths of travel to and within meeting rooms
    • Informing visitors that the OHRC has a quiet room available for persons with disabilities who may require private space to take medication or rest.
  • Mechanism/procedure for the OHRC to receive AODA compliance-related feedback or inquiries, including complaints, in accordance with section 11 of the IASR:
    • Including clarifying the process to provide feedback via website, phone and TTY.

Information and communications

In accordance with Part II of the IASR, the OHRC is committed to making sure its information and communications systems and products are accessible to persons with disabilities.

  • The OHRC takes into account individual disabilities when communicating with people. The OHRC will continue to review its digital and other communication methods in an effort to improve accessibility to its services.
  • The OHRC’s website is designed to comply with the World Wide Web Consortium (W3C) Web Content Accessibility Guidelines (WCAG) 2.0, Level AA.
  • The OHRC has in place internal emergency procedures and plans, including personalized evacuation plans, with the Persons in Need of Assistance list continuously updated and confidentially shared with the property manager.
  • Staff will continue to receive appropriate specialized training on emerging procedures and plans, video conferencing platforms, designing accessible eLearning modules, and other topics to improve the accessibility of the OHRC’s online resources.
  • Staff routinely take steps to make the website and communication products 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 eLearning modules, are tested regularly during their development and are tested on an ongoing basis by staff and by external persons with disabilities
    • Captioning and transcripts are provided for all video content
    • The OHRC provides local and toll free TTY numbers for communicating with people who are Deaf, deafened or hard of hearing
    • The OHRC uses a range of communication methods such as mail, email, telephone, video conferencing including Internet-based communications platforms, and social media platforms to communicate with stakeholders and members of the public
    • All public documents, including correspondence and publications, are available in accessible digital formats, such as HTML or accessible PDFs, and MS Word document format is available upon request
    • 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.

In consultation with people with disabilities, the OHRC will review and make any necessary changes to improve the accessibility of its:

  • Website, as it works towards revamping the website design, including but not limited to the accessibility of posted documents inPDF format, and potentially MS Word format, as well as online eLearning modules/videos, including whether any elements of these online products may be causing barriers (e.g. watermarks on documents or music playing in the background of eLearning modules/video)
  • Social and other media accounts, including Facebook, Instagram, YouTube and especially Twitter
  • Other OHRC digital information and communications, including email, electronic document formats and distribution, and its audio/video teleconferencing software and practices, including making sure video conferencing participants who require them have access to and know how to use accessibility features such as captioning
  • Other information technology the OHRC uses including computer software (e.g. correspondence software, VPN access) and hardware (e.g. employee personal computers, telephones, audio-video conferencing equipment)
  • Plain language writing at Grade 10 and lower levels for people with reading-related disabilities
  • Emergency procedures, plans and public safety information including making sure staff know what to do when visitors with disabilities are on-site during an emergency
  • TTY phone line, including reviewing current use and best practices, or alternatives, for contacting the OHRC office that meet the preferred mode of communication for individuals who are Deaf, deafened or hard of hearing.

Employment

In accordance with Part III of the IASR, the OHRC is committed to ensuring that the recruitment process for new staff is accessible.

  • 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 best respects their dignity and allows them to carry out their essential job duties and take part fully and meaningfully in the OHRC’s work. The OHRC also believes that inclusive design and integration are preferable to individual accommodations, where possible.
  • The OHRC informs candidates and employees about their right to accommodation and will advise candidates about the type of testing that they will be expected to do during the interview process, so that candidates can request an appropriate accommodation for a disability if need be.
  • 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.
  • New OHRC employees receive information and training on employees’ rights and responsibilities under the Code, the AODA and OPS policies that foster an inclusive workplace. These include the OHRC’s customer service policy on Providing goods and services to people with disabilities and commitment to promote a scent-sensitive office space.
  • The OHRC will continue to adhere to OPS policies and procedures on employment accommodation for both current and prospective employees with disabilities, as well as the standards outlined in the IASR.
  • The OHRC has an accessible quiet room for staff and visitors, which improves accessibility for persons with disabilities who may require private space to take medication or rest, for example. It improves accessibility for staff and visitors based on creed. It also improves accessibility for women who are breastfeeding.

In consultation with people with disabilities, the OHRC will review and make any necessary changes to improve the accessibility of its employment policies and practices (e.g. employee recruitment, accommodation procedures and plans) in accordance with Part II of the IASR as well as Ontario Public Service policies including making sure time limits for recruitment tests are designed inclusively and do not generally adversely affect candidates with disabilities, and accommodations are available to meet the disability-related need for more time.

Accessibility training

In accordance with sections 3 and 80.49 of the IASR, the OHRC is committed to making sure that all staff and commissioners remain informed about their rights and responsibilities under the Code, the AODA and the IASR by providing ongoing training.

  • All OHRC staff and commissioners receive ongoing training on disability-related policies and procedures, including AODA mandatory training on the requirements of the accessibility standards under the IASR, and on the Code as it pertains to persons with disabilities. All current staff have completed the OHRC’s eLearning module Working Together: The Code and the AODA.
  • The OHRC has an internal guide on plain-language writing and staff have been trained on plain-language writing. In addition to providing ongoing training to staff, as part of its mandate, the OHRC will continue to offer training on disability and the duty to accommodate to the public.
  • In accordance with the OPS requirements, the OHRC will track staff and commissioner training on accessibility and the duty to accommodate for disability and other grounds of the Code.

In consultation with people with disabilities, the OHRC will review and make any necessary changes to improve its staff and Commissioner training on IASR requirements, including making sure:

  • New staff receive information and training on the OHRC and OPS inclusive workplace policies
  • Current staff receive refresher training on the AODA, including the accessible customer service requirements
  • Relevant staff receive regular training on evolving best practice standards for accessible website design and online resources
  • All staff receive refresher training on plain-language writing at Grade 10 and lower levels.

Procurement

In accordance with section 5 of the IASR, the OHRC is committed to incorporating accessibility design, criteria and features when procuring or acquiring goods, services or facilities.

  • The OHRC will continue to comply with the procurement standard in the IASR and the accessibility obligations in the Ontario Public Service Procurement Directive Issued by Management Board of Cabinet in December 2014.
  • The OHRC will identify accessibility requirements in project terms of reference, requests for proposals and contracts with third-party service providers.
  • Where necessary, staff with disabilities will be consulted about any accessibility considerations at the outset of the procurement, so that they are included in the contract.

In consultation with people with disabilities, the OHRC will review and make any necessary changes to improve the accessibility of its procurement practices.

 

OHRC achievements from its 2014–19 multi-year AODA accessibility plan

The OHRC implemented the following initiatives as part of its 2014–19 Multi-year AODA accessibility plan:

  • Reviewed its customer service policy on Providing goods and services to people with disabilities
  • Designated an accessible quiet room for staff and visitors
  • Amended staff email signatures to include information about alternative forms of accommodation on request
  • Installed an accessible public telephone in the OHRC 9th floor elevator lobby
  • Developed and launched a Policy on ableism and discrimination based on disability
  • Reconfigured lighting in its boardrooms to improve accessibility
  • Updated the OHRC’s internal guide on plain language writing and provided training to all staff
  • Prepared accessibility guidelines and a checklist for the Association of Statutory Human Rights Agencies (CASHRA) to ensure commission documents, communications, meetings and events, including conferences and training sessions, are accessible for people with disabilities and other human rights-related needs
  • Developed public eLearning modules on duty to accommodate disability including Working together: the AODA and the Code
  • Trained staff and commissioners on human rights, accessibility and the duty to accommodate employees and clients with disabilities, including training on the AODA and the Code
  • Routinely sought feedback at the end of education and training sessions to understand how well Code-related accommodation needs of participants were met.

 

Feedback process

In accordance with section 11 of the IASR, the OHRC encourages feedback about its accessibility, including customer service, its website, employment practices, procurement, etc. Feedback can be submitted using an online request form, available at: www.ohrc.on.ca/en/contact/ohrc-feedback. Feedback can also be made in writing, by telephone, TTY or email 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 publicly through our annual report about our progress on implementing this accessibility plan, our commitments to identify and remove barriers for persons with disabilities, and the steps we have taken to comply with the requirements of the IASR.