Legal Information
Accessibility for Ontarians with Disabilities: Multi-Year Accessibility Plan
1. Introduction
This policy has been prepared in accordance with the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) and its associated regulations, including the Accessibility Standards for Customer Service and the Integrated Accessibility Standards.
It is intended to govern Zafin’s provision of goods and services to people with disabilities and sets out how Zafin will comply with the requirements of the AODA and its regulations.
Zafin is committed to meeting the accessibility needs of people with disabilities in a timely manner. Zafin will use reasonable efforts to ensure that the provision of goods and services is consistent with the following guiding principles:
- Respecting the dignity and independence of people with disabilities
- Ensuring that the provision of goods and services to people with disabilities is integrated with the provision of goods and services to others unless an alternative measure is necessary
- Ensuring that people with disabilities are given an equal opportunity to obtain, use and benefit from the goods and services provided by Zafin
This policy will be maintained on Zafin’s website and provided, upon request, in a format that takes a person’s accessibility needs due to disability into account.
2. Scope
This policy applies to all employees and to any individual or organization that provides facilities, goods or services to Zafin and the public or third parties on behalf of Zafin.
3. Establishment of Multi-Year Accessibility Plan
To achieve its accessibility goals, Zafin has established the below Multi-Year Accessibility Plan, which describes the specific short-term and long-term actions that Zafin endeavors to take to meet its obligations under the AODA and its regulations within the required timelines. The Multi-Year Accessibility Plan will be updated at least once every five years.
Zafin’s Multi-Year Accessibility Plan will cover a five-year period (2020-2025), to align with our strategic plan.
3.1 Training
All employees and people who participate in the development of Zafin’s policies, practices and procedures and all persons, including third parties, involved in the provision of goods and services to members of the public or people with disabilities on Zafin’s behalf will receive training regarding the requirements of the AODA and its regulations, and regarding the Ontario Human Rights Code as it relates to people with disabilities.
Training will include:
- How to interact and communicate with persons with various types of disability
- How to interact with persons with disabilities who use an assistive device or require the assistance of a guide dog, other service animal or support person
- How to use equipment or devices available on Zafin’s premises or otherwise provided by Zafin that may help with the provision of goods or services to a person with disability
- What to do if a person with a disability is having difficulty accessing Zafin’s goods or services
The training provided will be appropriate to the duties of the employee, person or third party. Training will take place at the start of employment or as soon as is practicable and Zafin will keep a record of the training taken.
4. Accessibility Compliance Reports
Zafin will file an Accessibility Compliance Report with the Ministry of Economic Development, Trade and Employment. The Accessibility Compliance Report is an online report that confirms that Zafin is meeting the accessibility requirements set out in the AODA and its regulations. Zafin will file an Accessibility Compliance report on December 31, 2020 and every three years thereafter.
5. Accessibility Standards for Customer Service
5.1 Assistive Devices
Zafin will accommodate the use of assistive devices in order to ensure that people with disabilities are able to obtain, use or benefit from Zafin’s facilities, goods and services. Assistive devices include, but are not limited to, wheelchairs, canes, walkers, scooters, screen readers, listening devices and Braille display boards.
5.2 Service Animals
Guide dogs and other service animals will be permitted to enter Zafin’s premises and to remain with the person with the disability unless the guide dog or other service animal is otherwise excluded by law. If the guide dog or other service animal is otherwise excluded by law, Zafin will ensure that other measures are available to allow the person with the disability to use, obtain or benefit from Zafin’s facilities, goods and services.
5.3 Support Person
Zafin will accommodate a person with a disability’s need for the assistance of a support person. If a person with a disability is accompanied by a support person, Zafin will ensure that both persons are permitted to enter Zafin’s premises. The person with the disability will not be prevented from having access to the support person while on Zafin’s premises.
If Zafin charges an admission fee in connection with a support person’s presence, Zafin will ensure that advance notice of the amount that is payable in respect of the attendance of the support person is provided.
Zafin may require that a person with a disability be accompanied by a support person if necessary, to protect the health and safety of the person with the disability.
5.4 Notice of Temporary Disruption in Service
Zafin will provide notice of temporary disruptions in the facilities or services that people with disabilities use to obtain or benefit from Zafin’s goods or services. Facilities or services may include escalators, elevators, accessible washrooms, accessible parking spots, amplification systems or note-taking devices.
Notice of temporary disruptions in service will include the reason for the disruption, the anticipated duration of the disruption and a description of available alternative facilities, if any. Notice of temporary disruptions may be provided by a variety of methods, depending on the circumstances, and may include posting notices in places where people are likely to see them.
5.5 Feedback
6. Integrated Accessibility Standards: Information and Communications Standards
6.1 Accessible Formats and Communication Support
Zafin will communicate with people with disabilities in a manner that takes into account a person’s disability. Taking a person’s disability into account may require Zafin to consider how a disability affects the way in which a person expresses, receives or processes communications, and to respond accordingly.
Except as otherwise provided by the AODA and its regulations, Zafin will, upon request and in consultation with the person making the request, provide or make arrangements to provide accessible formats and communication supports for people with disabilities. Accessible formats include alternatives to standard print, such as braille or large font, and communication supports include methods to assist communication that are other than spoken word.
Accessible formats and communication supports will be provided in a timely manner, will take into account the person’s accessibility needs due to disability and will be provided at a cost that is not more than the regular cost charged to other persons.
The above does not apply to products and product labels, unconvertible information or communications and information that Zafin does not control directly or indirectly through a contractual relationship. If Zafin determines that information or communications are unconvertible, Zafin will provide the person requesting the information or communication with an explanation as to why the information or communication is unconvertible and a summary of the unconvertible information or communication.
6.2 Accessible Website and Web Content
Zafin will ensure that its internet websites and web content conform to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG). By January 1, 2021, all of Zafin’s internet websites and web content conform to Level AA.
7. Integrated Accessibility Standards: Employment Standards
7.1 Recruitment
Zafin will notify job applicants of the availability of accommodations for applicants with disabilities during the recruitment process.
Zafin will also notify job applicants who are selected to participate in an assessment process of the availability of accommodations for applicants with disabilities during the assessment process. Accommodations are available upon the job applicant’s request and are available in relation to the materials or processes to be used throughout the assessment process. If a job applicant requests an accommodation, Zafin will consult with the person making the request to provide for or arrange for the provision of accommodation that takes the person’s accessibility needs due to disability into account.
Successful job applicants will be notified of Zafin’s policies for accommodating employees with disabilities at the time an offer of employment is made or as soon as is practicable thereafter.
7.2 Employee Supports
Zafin will inform new and existing employees of its policies for accommodating employees with disabilities, including policies on the provision of employment-related accommodations that take into account an employee’s accessibility needs due to disability. When there are changes to Zafin policies for accommodating employees with disabilities, Zafin will ensure updated policies noting the changes are available and accessible to all employees and others, as applicable.
7.3 Accessible Formats and Communication Supports for Employees
Upon the request of an employee with a disability, Zafin will provide the employee with, or arrange for the provision of, information that is necessary in order for the employee to perform a job and information that is generally available in the workplace. Zafin may consult with the employee to determine the suitability of an accessible format or communication support.
7.4 Individualized Workplace Emergency Response Information
Zafin will provide individualized workplace emergency response information to employees who have disabilities if the disability is such that the individualized information is necessary and Zafin is aware of the need for accommodation due to the person’s disability.
Zafin will provide individualized workplace emergency response information as soon as is practicable after becoming aware of an employee’s need for accommodation. Zafin will update the employee’s individualized workplace emergency response information when the employee moves to a different location, when the employee’s overall accommodation requires it, or when Zafin reviews its general emergency response policies.
If an employee with a disability requires assistance during a workplace emergency, Zafin is only able to provide the employee’s individualized workplace emergency response information to another employee designated to provide assistance upon the consent of the employee with the disability.
7.5 Documented Individual Accommodation Plan
Zafin will develop a written process for the creation of documented individual accommodation plans for employees with disabilities. Documented individual accommodation plans will identify and describe the accommodations that are required, and will contain the following elements:
- How employees with disabilities can be involved in the development process of their documented individual accommodation plan
- How employees with disabilities are assessed on an individual basis
- How Zafin can seek outside medical or other expert evaluation so that it can provide effective support
- What steps are taken to protect the privacy of the employee’s personal information
- How frequently documented individual accommodation plans will be reviewed and updated and how this will be done
- If an accommodation is denied, that the reason for the denial will be provided to the employee
- If required, how the documented individual accommodation plan will be provided to the employee in a manner that takes the employee’s accessibility needs due to disability into account (for example, whether accessible formats and communication supports are required)
- If applicable, information regarding the employee’s individualized workplace emergency response information
Please see Zafin’s ‘Accommodation Guide & Plan’ for further information.
7.6 Return to Work Process
Zafin will have in place a documented return to work process for employees who have been absent from work due to disability and require disability-related accommodations in order to return to work. The return-to-work process will outline the steps that Zafin will take to facilitate the return to work of employees with disabilities. The return-to-work process will make use of the employee’s documented individual accommodation plan, if applicable. Please see Zafin’s ‘Return to Work Guide & Plan’ for further information.
7.7 Performance Management, Career Development and Redeployment
Zafin will take into account the accessibility needs of employees with disabilities and the documented individual accommodation plans of employees with disabilities, if applicable, when carrying out performance management processes and when assessing career development and redeployment opportunities.
8. Questions Regarding the Policy
Any questions regarding this policy should be directed to the Human Resources Department.
