Ecclesiastical Insurance Office, PLC (“EIO” or the “Company”) is committed to providing equal treatment and opportunity to people with disabilities with respect to accessing services, accommodation and employment in a way that respects their dignity and independence. EIO strives to meet the needs of people with disabilities in a timely manner, and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”).
Purpose
The Integrated Accessibility Standards, Regulation 191/11 (“IASR”) under the AODA establishes standards to address barriers that persons with disabilities face in the areas of information and communications, employment and the design of public spaces. Accessibility Standards for Customer Service, Regulation 429/07 under the AODA establishes accessibility standards for providing goods and services to persons with disabilities. The requirements under these standards are not a replacement or substitution for the requirements of the Ontario Human Rights Code. The purpose of these policies is to put in practice our responsibilities under the AODA and to ensure that EIO complies with provincial accessibility standards.
Application
EIO has proactively chosen to recognize itself as a designated large private organization under the AODA that strives to meet the accessibility needs of its employees, its customers and the public it serves. As such, the practices and procedures in these Accessibility Policies apply to all EIO employees, volunteers and individuals that provide services or interact with people with disabilities on behalf of the Company.
Definitions
Assistive Devices
Auxiliary aids such as communication aids, cognition aids, personal mobility aids and medical aids (e.g. canes, crutches, wheelchairs or hearing aids).
Communication Tools
Tools that facilitate effective communications, including, captioning, alternative and augmentative communication tools, plain language and sign language.
Disability
As defined by the Ontario Human Rights Code means:
- 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; or
- An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act.
Employees
Every person who deals with members of the public or other third parties on behalf of EIO, whether the person does so as an employee, agent, volunteer or otherwise.
Persons with Disabilities
Individuals who have a disability as defined under the Ontario Human Rights Code (and above).
Service Animals
Animals individually trained to do work or perform tasks for the benefit of a person with a disability.
Support Persons
Any persons, whether a paid professional, volunteer, family member or friend, who accompany an individual with a disability in order to help with communications, personal care or medical needs, or with access to services.
Multi-Year Accessibility Plan
EIO will prepare and maintain a Multi-Year Accessibility Plan, which outlines the phased-in strategy to prevent and remove barriers and addresses the current and future requirements of the AODA. The Company will report annually on the progress and implementation of the Multi-Year Accessibility Plan, post the information on the Company website and provide the information in an accessible format upon request.
The Multi-Year Accessibility Plan will be reviewed and updated at least once every five (5) years.
Customer Service Standards
Reasonable efforts will be made by EIO, including its employees, volunteers and individuals providing services on their behalf to ensure that:
- Persons with disabilities are provided equal opportunity to obtain, use and benefit from EIO’s services;
- EIO’s services are provided in a manner that respects the dignity and independence of persons with disabilities;
- Services provided to persons with disabilities are integrated with the services provided to others unless an alternative measure is necessary to allow a person with a disability to benefit from the services;
- Communications with a person with a disability are conducted in a respectful manner that takes the person’s disability into account;
- Persons with disabilities may use assistive devices, service animals and support persons as is necessary to access EIO’s offices and services unless superseded by other legislation.
Assistive Devices
EIO is committed to serving people with disabilities who use assistive devices to obtain, use or benefit from our services. We will ensure that all staff, volunteers and others interacting with the public are trained and familiar with various assistive devices that may be used by customers with disabilities while accessing our services.
Telephone Services
EIO is committed to providing fully accessible telephone service to our customers. We will train employees to communicate with customers over the telephone in clear and plain language and to speak clearly and slowly.
All staff, volunteers and others dealing with the public will offer to communicate with customers by email if telephone communication is not suitable to their communication needs or is unavailable.
Orders and Billing
EIO is committed to providing accessible invoices to all of our customers. For this reason, invoices will be provided in the following formats upon request: hard copy or email.
All staff, volunteers and others interacting with the public will answer any questions that customers may have about the content of the invoice by hard copy or email.
Service Animals and Support Persons
EIO is committed to welcoming and providing services to people with disabilities who are accompanied by a service animal on parts of our premises that are open to the public and other third parties. EIO is also committed to providing services to people with disabilities located at client sites. All staff, volunteers and others dealing with the public will be properly trained on how to interact with people with disabilities who are accompanied by a service animal.
We are also committed to welcoming and providing services to people with disabilities who are accompanied by a support person on parts of our premises that are open to the public and other third parties. EIO is also committed to providing services to people with disabilities located at client sites. Any person with a disability who is accompanied by a support person will be allowed to enter the Company’s premises with his or her support person.
Notice of Temporary Service Disruption
EIO will provide customers with notice in the event of a planned or unexpected disruption in the facilities or services usually used by people with disabilities. This notice will include information about the reason for the disruption and its anticipated duration and a description of alternative facilities or services, if available.
The written notice will be placed in conspicuous places, including the Company website and a verbal notice will be placed on the Company’s telephone answering services. This will ensure that the notice reaches those persons potentially affected by the temporary disruption.
Feedback System
EIO’s ultimate goal is to meet and surpass customer expectations while serving customers with disabilities. Your comments about our services and how well these expectations are being met are welcomed and appreciated.
Feedback regarding the way EIO provides services to people with disabilities can be made by email.
Upon receipt of any complaints, Human Resources will investigate the matter with the appropriate individuals and provide a response to the complainant in a timely fashion.
Information and Communications
Communication
EIO is committed to meeting the communication needs of people with disabilities. We will notify the public and our employees of the availability of accessible formats and communication supports when requested. Upon request we will consult with the person making the request in a timely manner, and provide accessible formats and communication tools that take into account the person’s disability. This includes publicly available information about our goods, services and facilities, emergency information and feedback processes.
EIO will provide an explanation where information or communication cannot be provided in an accessible format or with communication supports, for example, if it is not technically feasible.
Accessible Websites and Web Content
Internet websites and web content controlled directly by EIO or through a third party that allows for modification of the site will conform to the World Wide Web Consortium, Web Content Accessibility Guidelines (WCAG) 2.0, at Level A and AA in accordance with the schedule set out in the IASR.
Emergency Procedures, Plans and Information
EIO will provide, upon request, any existing public emergency procedures, plans and public safety information relating to its Company premises in an accessible format or with appropriate communication supports in a timely manner upon request.
Training
Customer Service Standard
EIO will provide training on the Customer Service Standard requirements under the AODA to all employees, volunteers and others who interact with the public or other third parties on the Company’s behalf, and all those who are involved in the development and approvals of customer service policies, practices and procedures.
Applicable staff will be trained on policies, practices and procedures that affect the way services are provided to people with disabilities. Staff will also be trained on an on-going basis when changes are made to these policies, practices and procedures.
Integrated Accessibility Standard
EIO is committed to training employees, volunteers, persons who interact with the public or other third parties on our behalf on Ontario’s accessibility laws and accessibility aspects of the Ontario Human Rights Code that apply to individuals with disabilities.
Training will be provided in a way that best suits the duties of employees, volunteers and other staff members, and will be on-going where there are any changes to these policies. Training will take place within a reasonable time and upon completion, records of training will be kept and will be available for inspection as may be required.
Employment Standards
Recruitment
EIO will post information about the availability of accommodation for job applicants with disabilities in the recruitment process. Job applicants who are selected for an interview and/or testing will be notified that accommodations for material to be used in the process are available upon request. When the applicant requests accommodation, EIO will consult with him/her to arrange for accommodation in a manner that takes into account the applicant’s disability.
Employee Accommodation
EIO will inform its employees of the policies used to support employees with disabilities, including accommodation policies that take into account accessibility needs. This information will be provided to new employees as soon as practicable after they begin their employment and updated information will be provided to all employees whenever there is a change to existing accommodation policies.
Accessible Formats and Communication Support for Employees
Upon request, EIO will consult with employees to provide or arrange for the provision of accessible formats and communication support for:
- Information that is needed in order to perform the employee’s job; and
- Information that is generally available to employees in the workplace.
EIO will consult with the employee making the request to determine the suitability of the accessible format or communication support.
Workplace Emergency Response Information
Individual workplace emergency response procedures will be provided to an employee with a disability where necessary. In addition, this information will be provided, with the employee’s consent, to the person designated to provide assistance. The information will be reviewed whenever the employee moves to a different location, the employee’s overall accommodation needs or plans are reviewed or EIO reviews its emergency response plan.
Documented Individual Accommodation Plans
A written process for the development and maintenance of documented individual accommodation plans will be developed for employees with disabilities. Upon request, these plans will include information regarding accessible formats and communication supports and individualized workplace emergency response information.
Documented Return to Work Process
EIO will have in place a documented return to work process for employees returning to work due to disability and requiring disability-related accommodations. The return to work process will outline the steps the Company will take to facilitate the return to work.
Performance Management, Career Development and Re-assignment
EIO will take into account the accessibility needs of its employees with disabilities when providing career development, performance management and when considering redeployment.
Design of Public Spaces
EIO, in conjunction with the third-party property management will strive to meet the Accessibility Standards for the Design of Public Spaces, to the extent that EIO has control over such new construction, redesign & redevelopment of public spaces.
Public spaces include:
- Outdoor paths of travel (e.g. sidewalks, ramps, stairs)
- Accessible parking
- Service-related elements (e.g. service counters, waiting areas)
Policy Updates
Our policies are maintained and updated regularly to reflect legislative changes and changes in our practices. As such any EIO policies that do not respect and promote the dignity and independence of people with disabilities will be modified or removed. As we are committed to developing accessibility policies that respect and promote the dignity and independence of people with disabilities, no changes will be made to these Policies before considering the impact on people with disabilities.