IPC Integrated Accessibility Standards Policy

Purpose

The Information and Privacy Commissioner of Ontario (IPC) is committed to creating an accessible organization by removing barriers for people with disabilities.  The purpose of this policy is to:

  • Ensure that employees, applicants for employment, and those who use our services are able to do so with independence, dignity, integration, and equality of opportunity; and
  • Meet our obligations under the Integrated Accessibility Standards made under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA).

The Integrated Accessibility Standards have been developed to break down barriers and increase accessibility for persons with disabilities.


Definitions

Accessible formats may include, but are not limited to, large print, recorded audio and electronic formats, Braille, and other formats used by persons with disabilities.

Communication supports may include but are not limited to, captioning, plain language, sign language and other supports that facilitate effective communications.

Accessibility Plan

The IPC will develop, maintain and document an Accessibility Plan outlining the IPC’s strategy to prevent and remove barriers from its facilities and services, to improve opportunities for persons with disabilities, and to meet its requirements under AODA and the Integrated Accessibility Standard.  The Accessibility Plan will be reviewed and updated every five years and will be posted on the IPC’s website.  Upon request, the IPC will provide a copy of the Accessibility Plan in an accessible format or with communication supports. The Accessibility Plan will be developed, reviewed and updated in consultation with persons with disabilities.

The IPC will prepare annual status reports on the progress of measures taken to implement the IPC’s strategy outlined in its Accessibility Plan.

Procurement

The IPC will incorporate accessibility design, criteria and features when it procures or acquires goods, services or facilities, except where it is not practicable to do so. Where the IPC determines that it is not practicable to incorporate accessibility design, criteria and features, the IPC will, upon request, provide an explanation for the determination.

Training

The IPC will ensure that training is provided to all employees of the IPC on the requirements of the Integrated Accessibility Standards and the Human Rights Code as it pertains to persons with disabilities.

The training will be appropriate to the duties of the person and will be provided as soon as practicable after the person starts their employment or contractual relationship with the IPC. Updated training will be provided when changes are made to this policy.

The IPC will keep records of the training it provides.

Information and Communication Standards

Feedback

The IPC will ensure that its processes for receiving and responding to feedback are accessible to persons with disabilities by providing or arranging for the provision of its feedback processes in accessible formats and with communication supports, upon request.

Accessible Formats and Communication Supports

Upon request, the IPC will provide accessible formats and communication supports for persons with disabilities in a timely manner that takes into account the person’s accessibility needs due to disability.

The IPC will consult with the person making the request in determining the suitability of an accessible format or communication support. The IPC will notify the public about the availability of accessible formats and communication supports.

Websites and Web Content

The IPC will ensure that its Internet and Intranet websites conform to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, at Level AA in accordance with the Integrated Accessibility Standards.

Employment Standards

Recruitment

The IPC will notify employees and the public about the availability of accommodations for applicants with disabilities in its recruitment process.

When an individual is selected to participate in an assessment or selection process, the IPC will notify them that accommodations in relation to the materials or processes to be used are available upon request. If a selected applicant requests an accommodation, the IPC will consult with the applicant and provide a suitable accommodation in a manner that takes into account the applicant’s accessibility needs due to disability.

When making offers of employment, the IPC will notify the successful applicant of its policies for accommodating employees with disabilities.

Employee Supports

The IPC will inform its employees of its policies used to support employees with disabilities, including policies on the provision of job accommodations that take into account an employee’s accessibility needs due to disability. This information will be provided to new employees as soon as practicable after commencing employment and whenever there is a change to the existing policies.

Upon the request of an employee with a disability, the IPC will consult with the employee to provide accessible formats and communication supports for information that the employee needs to perform his/her job, and information that is generally available to other employees.

Workplace Emergency Response Information

The IPC shall provide individualized workplace emergency response information to employees who have a disability if the disability is such that the individualized information is necessary and the employer is aware of the need for accommodation.

If the employee who receives an individual workplace emergency response information requires assistance, the IPC shall, with the employee’s consent, provide the workplace emergency information to the person designated by the IPC to assist the employee.

The IPC will provide the workplace emergency response information as soon as practicable after becoming aware of the need for accommodation due to the employee’s disability and will review the individualized workplace emergency response information when the employee moves to a different location in the organization, when overall accommodations needs or plans are reviewed, and when the IPC reviews its general emergency response policies.

Documented Individual Accommodation Plans

The IPC will develop and have in place a written process for developing a documented individual accommodation plan for employees with a disability.  The process will include the following elements:

  • The manner in which an employee requesting accommodation can participate in the development of the individual accommodation plan.
  • The means by which the employee is assessed on an individual basis.
  • The manner in which the employer can request an evaluation by an outside medical or other expert, at the employer’s expense, to assist the employer in determining if accommodation can be achieved and, if so, how accommodation can be achieved.
  • The steps taken to protect the privacy of the employee’s personal information.
  • The frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done.
  • If an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee.
  • The means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs due to disability.

Return-to-Work Processes

The IPC will have in place a return-to-work process for employees who have been absent from work due to a disability and require disability-related accommodation in order to return to work.  Such processes shall be documented and must outline the steps that the IPC will take to facilitate the return to work and include an individual accommodation plan.

Performance Management, Career Development and Advancement and Redeployment

The IPC will take into account the accommodation needs and/or individual accommodation plans of employees when:

  • using performance management processes;
  • providing career development and advancement information; and
  • using redeployment procedures.