Accessibility Policy
Intent
This
policy is intended to outline practices and procedures in place at OUTEDGE
Media Canada LP (OUTEDGE Media) to meet the requirements established by provincial
accessibility legislations. This policy
establishes OUTEDGE Media’s accessibility standards for customer service,
information and communication and employment.
Scope
a)
This
policy applies to the provision of accessibility for persons with disabilities
at premises owned and operated by OUTEDGE Media.
b)
This
policy applies to employees, volunteers or other third parties that act on
behalf of OUTEDGE Media, including when the provision of accessibility for
persons with disabilities occurs off the premises of OUTEDGE Media.
c)
The
section of this policy that addresses the use of service animals only applies
to the provision of accessibility for persons with disabilities that take place
at premises owned and operated by OUTEDGE Media.
d)
This
policy shall also apply to all persons who participate in the development of
the OUTEDGE Media’s policies, practices and procedures governing the provision
of accessibility for persons with disabilities to members of the public or
third parties.
Definitions
Accessible
Formats
– means, but is not limited to, any form of large print, recorded audio and
electronic formats, braille and other formats usable
by persons with disabilities.
Accommodation
–
means providing continuum of assistive responses to a request from a disabled person
to improve access to services or employment.
This continuum includes such simple responses as providing additional
time to review material, to moving furniture to manage wheelchair access, to
permitting entry of a service animal or to providing specialized or modifying
equipment for employment purposes.
Assistive
Device – means a technical aid, communication device
or other instrument that is used to maintain or improve the functional
abilities of persons with disabilities. Personal assistive
devices are typically devices that persons with disabilities use such as a
wheelchair, walker or a personal oxygen tank to
facilitate hearing, seeing, communicating, moving, breathing, remembering
and/or reading.
Customer –
means the subset of the public or third parties to whom OUTEDGE Media provides
services in the ordinary course of our business.
Communication
Support
– means, but is not limited to, captioning, alternative and augmentative
communication support, plain language, sign language and other support that
facilitate effective communications.
Disability –as defined by provincial accessibility legislations and
Human Rights Codes, 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
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 provincial workers compensation boards.
Service
Animal
– means any animal used by a person with a disability for reasons related to
the disability, where it is readily apparent that the animal is used by the
person for reasons relating to his or her disability; or if the person provides
a letter from a physician or nurse confirming that the person requires the
animal for reasons relating to the disability.
Support
Person
– means a person who accompanies a person with a disability in
order to assist him or her with communication, mobility, personal care,
medical needs.
Web
Content Accessibility Guidelines – means the World Wide Web Consortium
Recommendation, dated December 2008, entitled Web Content Accessibility Guidelines (WCAG) 2.0.
Web
Page –
means a non-embedded resource obtained from a single Uniform Resource
Identifier (URI) using Hypertext Transfer Protocol (HTTP) and any other
resources that are used in the rendering or intended to be rendered together
with it by a user agent.
Policy
Statement
OUTEDGE
Media is committed to accessibility for persons with disabilities based upon
the core principles of dignity, independence, inclusion, integration, responsiveness and equality of opportunity. We are committed to meeting the needs of
persons with disabilities in a timely manner, and will
do so by preventing and removing barriers to accessibility and meeting the
accessibility requirements under provincial accessibility legislations. OUTEDGE Media respects and supports applicable
provincial Human Rights Codes.
General
Principles
1.0 Accessible
Customer Service
1.1 Provision of Goods and Services
OUTEDGE Media will
ensure that all persons with disabilities receive the same value and quality,
allowing persons with disabilities to do things in their own ways, at their own
pace when accessing goods and services as long as this
does not present a safety risk.
OUTEDGE Media will use
alternative methods when possible to ensure that persons
with disabilities have access to the same services, in the same place and in a
similar manner.
OUTEDGE Media will take into
account individual needs when providing goods and services.
1.2 Communication
OUTEDGE Media will communicate with persons
with disabilities in ways that take into account their
disability and enable them to communicate effectively for purposes of using,
receiving and requesting OUTEDGE Media goods and services.
OUTEDGE Media will train its employees on how
to interact and communicate with persons with various types of disabilities.
1.3 Use of Assistive Devices
Persons with disabilities may use their own
assistive devices as required when accessing goods or services, or premises of OUTEDGE
Media.
In cases where the assistive device presents a
safety concern or where accessibility might be an issue, other reasonable
measures will be used to ensure the access of goods and services, or premises. For example, open flames and oxygen tanks
cannot be near one another. Therefore,
the accommodation of a person with an oxygen tank may involve ensuring the person
is in a location that would be considered safe for both the person and business.
It is the responsibility of the person with a
disability to ensure that his/her assistive device is operated
in a safe and controlled manner at all times.
OUTEDGE Media will ensure that its employees
are familiar with the use of assistive devices available on OUTEDGE Media’s
premises, as appropriate to their duties, and inform persons with disabilities
of the assistive devices that are available.
1.4 Use of Service Animals
A person with a
disability that is accompanied by a service animal will be allowed access to
premises that are open to the public unless otherwise excluded by law. “No pet”
policies do not apply to service animals.
Exclusion
Guidelines:
If a service animal is
excluded by law (see applicable laws below), OUTEDGE Media will offer
alternative methods to enable the person with a disability to access goods and
services, or premises when possible (for example, securing the animal in a safe
location and offering the guidance of an employee).
If there is a conflict between a provision of a provincial
animal liability act or of a regulation relating to banned breeds (such as
pitbulls) and a provision of a by-law passed by a municipality relating to
these breeds, the provision that is more restrictive in relation to controls or
bans on these breeds prevails.
Recognizing a Service
Animal:
If it is not readily apparent that the animal
is being used by the person with a disability for reasons relating to his or
her disability, OUTEDGE Media may request verification from the person with a
disability.
Verification may
include:
· a letter from a
physician or nurse confirming that the person requires the animal for reasons
related to the disability;
· a valid identification
card signed by the Attorney General of Canada; or,
· a certificate of
training from a recognized service animal training school.
Care and Control of the
Animal:
The person with disabilities that is
accompanied by a service animal is responsible for maintaining
care and control of the animal at all times.
Allergies:
If a health and safety
concern presents itself for example in the form of a
severe allergy to the animal, OUTEDGE Media will make all reasonable efforts to
meet the needs of all individuals.
1.5 Use of Support Persons
If a person with a
disability is accompanied by a support person, OUTEDGE Media will ensure that
both persons are allowed to enter its premises together and that the person
with disabilities is not prevented from having access to the support person.
OUTEDGE Media may
require a person with a disability to be accompanied by a support person when
on its premises in the event that a support person is
necessary to protect the health and safety of the person with a disability or
the health and safety of others on its premises.
In situations where
confidential information might be discussed, consent will be obtained from the person
with a disability, prior to any conversation where confidential information
might be discussed.
Admission Fees:
If payment is required
by a support person for admission to a sponsored event, OUTEDGE Media will
ensure that notice is given in advance by posting notice of admission fees for
support persons where OUTEDGE Media fees are posted.
1.6 Notice of Temporary
Service Disruptions
Service disruptions may occur due to reasons
that may or may not be within the control or knowledge of OUTEDGE Media. In the event of any temporary disruptions to
services that persons with disabilities rely on to access or use OUTEDGE Media's
goods or services, or premises, reasonable efforts will be made to provide
advance notice. In some circumstances such as in the situation of unplanned
temporary disruptions, advance notice may not be possible.
In the event that a notification needs
to be posted the following information will be included unless it is not
readily available or known:
· goods or services, or
premises, that are disrupted or unavailable
· reason for the
disruption
· anticipated duration
· a description of
alternative services or options
Notice will be made in conspicuous places
including at the point of disruption, at the main entrance and the nearest
accessible entrance to the service disruption, and/or on the OUTEDGE Media website,
by contacting persons with disabilities using a method that is reasonable under
the circumstances.
2.0 Information and Communication
2.1 Multi-Year
Accessibility Plan and Annual Progress Reports
As of January 1, 2014, OUTEDGE
Media will make public a Multi-Year Accessibility Plan to improve the
accessibility of its good, services and premises and meet the compliance
requirements of provincial accessibility legislations.
2.2 Website Accessibility
Where possible, OUTEDGE Media will publish new
web content on its internet website(s) after January 1, 2014, which conforms to
Web Content Accessibility Guidelines W3C WCAG 2.0 Level A. OUTEDGE Media continues to work towards increasing
the accessibility of its web content, website(s) and
web-based applications.
2.3 Alternate Formats Available Upon Request
All organizational information will be made
available to persons with disabilities in an accessible format or via
accessible communication support upon request.
OUTEDGE Media will consult with the person making the request to
determine the suitability of an accessible format or communication support
provided. Timeframes for this
information will be dependent upon the format requested, but
will be provided as soon as practicable.
OUTEDGE Media will notify the public about the
availability of accessible formats and communication supports through its
website(s).
2.4 Accessible
Emergency Information
OUTEDGE Media will provide emergency response
information and assistance to persons with disabilities in an accessible format
or with appropriate communication supports, as soon as practicable, upon
request.
3.0 Employment
3.1 Accommodation of
Persons with Disabilities
OUTEDGE
Media will review the needs of applicants, new and existing employees
with disabilities who request employment
related accommodations. Persons with
disabilities requiring employment related accommodation will be
consulted when
determining
suitable accommodation, including the provision of accessible formats or
communication
supports.
3.2 Individualized
Workplace Emergency Response Information
Individualized
workplace emergency procedures, plans and safety information are
available
to employees with disabilities in an accessible format or via accessible
communication
support upon request. Timeframes for
this information will be dependent
upon the format requested, but
will be provided as soon as practicable.
3.3 Individualized
Emergency Response Plans for Employees
All
OUTEDGE Media employees with disabilities that may require assistance in an
emergency
situation are encouraged to identify their
accessibility needs to their immediate
supervisor
or Human Resources so that individualized emergency accommodation plans
can
be created.
This information will be maintained
confidentially, unless assistance is required by the employee, in which case OUTEDGE
Media will provide the workplace emergency response information to the person
designated by OUTEDGE Media to provide assistance to
the employee.
4.0 Training
Training will be provided to all employees,
volunteers or other third parties that act on behalf
of OUTEDGE Media; and,
those who are involved in the development and approval of
policies;
practices and procedures for the delivery of these services as required by
provincial
accessibility legislations.
Training Provisions:
Training will include the following information:
· A review of the purpose
of provincial accessibility legislations;
· A review of the
requirements of the accessibility standards for customer service, information
and communication and employment, in accordance with provincial accessibility legislations;
· Instructions on how to
interact and communicate with persons with various types of disabilities;
· Instructions on how to
interact with persons with disabilities who:
o
use
assistive devices;
o
require
the assistance of a service animal; or
o
require
the use of a support person (including the handling of admission fees)
o
require
alternate formats of communication;
· Instructions on how to
use equipment or devices that are available at our premises or that we provide
that may help persons with disabilities;
· A review of different
types of alternate formats and accessible communication supports;
· Instructions on what to
do if a person with a disability is having difficulty accessing your services;
· A review of OUTEDGE
Media's policies, procedures and practices pertaining to Accessibility.
Training Schedule:
Training will be provided to each person
according to his or her duties as soon as is
practicable. Training will be provided on an ongoing basis
in connection with changes to
OUTEDGE Media policies, procedures
and practices governing the provision of
services to persons with
disabilities. Revised training will be
provided in the event of
changes to legislation, policies, procedures
and/or practices.
Record of Training:
OUTEDGE Media will keep
a record of training that includes the dates training was provided, the number and
names of employees who attended the training.
5.0 Feedback
Process
OUTEDGE Media shall provide persons with
disabilities with the opportunity to provide feedback on the goods and services
they receive. Information about the feedback process will be readily available
to all persons with disabilities and notice of the process will be made
available at the front desk of our facilities and on our website. Feedback forms along with alternate methods
of providing feedback such as verbally (in person or by telephone) or written (hand written, delivered, website or email), will be
available upon request.
Submitting Feedback:
Persons with disabilities can submit feedback
to:
·
Louise Plant, Vice-President, Human
Resources
·
416-521-6518
·
377 Horner Avenue, Toronto, Ontario M8W 1Z6
·
Louise.Plant@outedge.ca
·
www.outedge.ca
Persons with disabilities who wish to provide
feedback by completing an onsite feedback form or verbally can do so to any OUTEDGE
Media employee.
Privacy will be respected throughout the
feedback process. All feedback will be
reviewed for possible improvement in OUTEDGE Media’s goods and services and
accessibility to its goods and services.
Feedback will be directed to the most appropriate person within OUTEDGE
Media for dealing with it and any complaints will be addressed as soon as
possible.
Persons with disabilities that provide formal
feedback will receive acknowledgement of their feedback, along with any
resulting actions based on concerns or complaints that were submitted.
6.0 Availability
of Documents
OUTEDGE Media shall
notify persons with disabilities that the documents related to Accessibility for
Persons with Disabilities are available upon request, in a format that takes into account the person's disability. Notification will be given by posting the
information in a conspicuous place owned and operated by OUTEDGE Media, the OUTEDGE
Media's website and/or any other reasonable method of communication.
7.0 Administration
If you have any questions or concerns about
this policy or its related procedures please contact:
·
Louise Plant, Vice-President, Human
Resources
·
416-521-6518
·
377 Horner Avenue, Toronto, Ontario M8W 1Z6
·
Louise.Plant@outedge.ca
·
www.outedge.ca
This policy came into effect January 1, 2014 and was last revised March 1, 2024. This policy and
its related procedures will be reviewed as required in the event of legislative
changes.
Referenced Documents:
- Accessibility for Ontarians with Disabilities Act, 2005
- Accessibility for Manitobans Act
- Accessibility Standards for Customer Service, Ontario Regulation 429/07
- Integrated Accessibility Standards for Information and Communication, Employment and Transportation, Ontario Regulation 191/11
- Dog Owners' Liability Act, Ontario
- The Animal Liability Act, Manitoba
- Ontario Human Rights Code, 1990
- Manitoba Human Rights Code