The Accessibility for Ontarians with Disabilities Act, 20015 (AODA) is a Provincial Act with the purpose of developing, implementing and enforcing accessibility standards in order to achieve accessibility for people with disabilities and others with accessibility needs. The AODA mandates five standards in the following areas:
- Customer Service
- Information and Communications
- Design of Public Spaces
As a company operating in Ontario, Edelman Canada is obligated to meet all relevant AODA requirements as articulated in the Customer Service Regulation and the Integrated Accessibility Standards Regulation as it pertains to the business of Edelman Canada. The following plan and policies describe how Edelman Canada is meeting those obligations as outlined in sections 3 and 4 of the Integrated Accessibility Standards Regulation and the Customer Service Regulation of the AODA.
I. Statement of Commitment
Edelman Canada is a leading independent global communications marketing firm. Pushing the boundaries of traditional PR, Edelman Canada uses the latest social media and digital tools to establish a new era of public engagement between organizations and their constituents. Edelman Canada is helping to re-define 21st century communications for local and national clients across the country. Whether in the area of branding, marketing, social media, community relations, websites or event promotion, Edelman Canada prides ourselves on surpassing the expectations of our customers.
We know that over 15% of the population has a disability and even more people have accessibility needs. Disabilities can be sensory, physical or cognitive, visible or invisible. No matter what the need, Edelman Canada is committed to serving our clients and treating our employees in a way that respects dignity and independence. We endeavor to communicate and provide our services in a manner that is inclusive to everyone and which takes peoples’ accessibility needs into account in all of our activities.
Edelman Canada is committed to creating an inclusive environment where barriers will not prevent anyone from interacting effectively with us. We are also committed to ensuring that all accessibility requirements are adhered to in a rigourous fashion. Any policy of Edelman Canada that does not respect and promote the dignity and independence of people with disabilities will be modified or removed.
II. General Definitions
Accessible Formats: include, but are not limited to, accessible electronic formats, Braille, text transcripts, large print, recorded audio, colour contrasts, and other formats accessible to persons with disabilities.
Assistive Device: a technical aid, communication device or other instrument that is used to maintain or improve the functional abilities of people with disabilities. Personal assistive devices are typically devices that people bring with them such as a wheelchair, walker or a personal oxygen tank that might assist in hearing, seeing, communicating, moving, breathing, remembering and/or reading.
Barrier: as defined by the Ontarians with Disabilities Act, 2001, anything that prevents a person with a disability from fully participating in all aspects of society because of his/her disability. This includes:
- Physical barriers,
- Architectural barriers,
- Informational or communications barriers,
- Attitudinal barriers,
- Policy, practice or procedure barriers.
Communication Supports: include but are not limited to sign language, plain language, closed captioning and other communication supports that facilitate effective communications.
Disability: a key feature of the AODA is its definition of “disability”. Under the AODA, the definition of “disability” is the same as the definition in the Ontario Human Rights Code :
Any degree of physical disability, infirmity, malformation or disfigurement including, but not limited to:
- Diabetes mellitus;
- A brain injury;
- Any degree of paralysis;
- Lack of physical coordination;
- Blindness or visual impediment;
- Deafness or hearing impediment;
- Muteness or speech impediment; or
- Physical reliance of 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.
- An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety & Insurance Act, 1997.
Support Persons: any person, whether a paid professional, volunteer, family member of friend, who accompanies a person with a disability to help with communications, mobility, personal care or medical needs while accessing our goods and services.
III. Meeting the Requirements
We know that training provides people the tools and resources they need to serve our customers effectively. Training also helps our employees develop their skills. Named by Advertising Age as a “best place to work” Edelman is a leader in ensuring that our employees can stretch and grow and serve our clients in the best way possible.
To that end, Edelman Canada’s training meets all requirements of the AODA in the areas of Customer Service, the Integrated Accessibility Standards Regulation and the Ontario Human Rights Code. Training has been delivered to all employees who deal with clients, the public or third parties on our behalf as well as to people involved in the development of policies, plans, practices and procedures related to the provision of our goods and services.
Training will also be included as part of onboarding for new employees and refreshed on a regular basis. Edelman Canada commits to ensuring that all employees within its community are aware of their rights and responsibilities to create an inclusive environment with and for people with accessibility needs.
As required AODA training covers:
- An overview of the AODA and its regulations
- All requirements of the Customer Service Standard including:
- How to interact and communicate with people with various types of disabilities
- How to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person
- What to do if a person with a disability is having difficulty accessing Edelman’s goods and services
- Requirements related to information and communications including:
- The elements of accessible websites
- Types of accessible formats
- Colour contract and accessibility
- Developing accessible documents
- Requirements of the Employment Standard and Edelman’s policy, including:
- Recruitment, assessment and selection
- Accessible formats and communications
- Workplace emergency response information
- Documented individual accommodation plans
- Return to work
- Performance management
- Career development and advancement
- An overview of the Design of Public Spaces and Transportation Standards recognizing that Edelman’s customers can come from any sector
- The Ontario Human Rights Code as it relates to people with disabilities
- Similarities and differences between the AODA and the Ontario Human Rights Code
2. Best Practices
At Edelman Canada, we know that being good at something is not good enough. We understand that the AODA standards represent the minimum requirements for all public and private sector organizations in Ontario. As a leading communications marketing company, we take seriously the requirement in section 4 of the IASR to examine how we can prevent and remove barriers for people with disabilities. We particularly commit to examining best practices in the areas of information and communications and incorporating those best practices into our business practices where appropriate. By using principles of universal design wherever possible, we will be able to deliver on consistent high quality services to our clients.
As required, we will endeavor to incorporate accessibility provisions into our procurement practices. We understand that when accessibility is used as one of the criteria for purchasing decisions, the outcome will be products and services that that are universally accessible to everyone. Where applicable, our procurement practices may outline the desired accessibility elements to be met. Examples where accessible procurement may be relevant may include computer purchases, software, office equipment, and leasing space.
4. Customer Service Policy
Edelman Canada is committed to excellence in serving all customers including people with disabilities. Edelman is committed to providing people with disabilities the same opportunity to access our goods and services in a similar way as other clients. For the purposes of this customer service policy, employee means every person who deals with clients or members of the public on behalf of Edelman Canada whether the person does so an employee, volunteer, agent or intern.
We will ensure that our staff are trained and familiar with various assistive devices we have on site or that we provide that may be used by customers with disabilities while accessing our goods or services.
We will communicate with people with disabilities in ways that take into account their disability. Prior to making final decisions on alternate forms of communication when requested, we will consult with the affected individual. Edelman will train employees who communicate with clients as how to effectively communicate with people with various types of disabilities.
We welcome people with disabilities and their service animals. Service animals are allowed on all parts of our premises unless prohibited by law.
A person with a disability who is accompanied by a support person will be allowed to have that person accompany them on our premises. At no time will a person with a disability who is accompanied by a support person be denied to his or her support person while on our premises. Permission will be obtained from the person with a disability prior to a confidential conversation taking place with the support person present.
Notice of temporary disruption
In the event of a planned or unexpected disruption to services or facilities for customers with disabilities including elevator access to third floor offices and accessible washroom facilities, Edelman will notify customers promptly. This clearly posted notice will include information about the reason for the disruption, its anticipated length of time, and a description of alternative facilities or services, if available.
The notice will be placed at the main reception area.
Edelman is committed to providing accessible billing to all of our clients. Upon request, invoices will be provided in hard copy, large print or email.
Ensuring that our clients are able to participate effectively in meetings is key to our success. Edelman commits to ensuring that we provide for high levels of accessibility both in terms of meeting space as well as in the content and proceedings of meetings.
Our goal is to surpass the expectations of our clients. Comments on how our services are met are appreciated. Customers who wish to provide feedback on how Edelman provides goods and services to people with disabilities can do so by email or verbally by telephone.
All feedback, including complaints, will be directed to the SVP of Human Resources, Julia Cartwright (Julia.firstname.lastname@example.org or 416-850-0648)
Customers can expect to hear back within 10 business days.
5. Employment Policy
Edelman Canada is committed to an accessible and inclusive workplace where all employees are encouraged to excel without being hampered by barriers. For the purpose of the Employment Policy, employees include all paid employees, whether full-time, part-time or seasonal. Volunteers or other unpaid persons are not covered by the employment standard.
Edelman Canada recognizes that both Ontario Human Rights Code policies and the AODA have specific requirements related to employment accommodation. While there is close alignment between the two pieces of legislation, they are not the same. This policy is specific to AODA Employment Standard requirements.
Recruitment, assessment and selection
During the recruitment process, Edelman shall notify job applicants and the public about its commitment to accommodate those with disabilities, and shall advise those selected for an interview that accommodation is available upon request. If a selected applicant requests an accommodation, Edelman shall consult with the applicant and provide or arrange for the provision of a suitable accommodation in a manner that takes into account the applicant’s accessibility needs due to disability.
Advertisements will include a statement that people with disabilities are invited to apply. (NOTE – alternative – Advertisements will include a statement that Edelman Canada is an inclusive workplace and welcomes all qualified applicants to apply.).
Successful applicants and employees shall be notified of Edelman Canada’s policies regarding accommodating employees with disabilities as soon as possible after their employment begins and whenever a change in policy takes place.
Accessible formats and communications supports
As part of an approved accommodation plan, accessible formats and communication supports may be provided. Appropriate formats will be provided in consultation with the individual. The final decision of what to provide rests with Edelman Canada.
Workplace emergency response information
Individual and documented emergency and evacuation plans will be provided to any employee with accessibility needs as well as to any person designated to assist the employee, with the consent of that employee, and shall review the individualized workplace response information upon the following events:
- When the employee moves to a new location in the workplace;
- When the employee’s overall accommodation needs are reviewed; and
- Upon review of Edelman’s general emergency response policies.
Documented individual accommodation plans
Any employee requesting an accommodation will have a documented plan that will be reviewed and updated regularly. An individualized plan will take into account the nature and severity of the disability, the nature of the work and the workplace environment. It will also include any emergency-related information, accessible formats and communications supports and any other accommodations a person needs to perform the essential duties of their job.
Return to work process
A documented process will be established for supporting employees who return to work for reasons related to disability. If an individual’s illness or injury is covered by the Workplace Safety and Insurance Act, then the Act’s return to work processes apply.
Performance management, career advancement and reassignment
An employee’s accommodation needs will be taken into effect during the performance management process, when determining advancement opportunities and when a reassignment is being contemplated.
Review of job descriptions
Job descriptions will be reviewed to ensure that stated requirements are necessary and any barriers are removed.
Procedure for an employee requesting an accommodation
The purpose of accommodation is to allow a person to perform the essential duties of the job and to allow for equal participation in the workplace. The accommodation process will respect confidentiality and privacy. The accommodation will be collaborative and will involve the requestor.
Requests for accommodation will be formalized according to the following process:
- 1.01 Employees who wish to raise a potential accommodation issue shall do so by submitting a request for accommodation, preferably in writing, to their immediate manager. The request shall describe, in detail, the accommodation sought to address limitations in performing the essential duties of the job.
- 1.02 When necessary to facilitate the assessment and determination of the accommodation, the employee may be required to participate in the development of the accommodation plan and provide relevant medical information to Edelman such as a functional capacity evaluation. Medical professionals are not required to submit a diagnosis. The purpose of any medical documentation is to determine the type of accommodation required. Employees seeking accommodation are expected to provide their fullest cooperation in providing any information or medical assessments relevant to determination of the accommodation request.
- 1.03 The VP of Human Resources and the General Manager will jointly assess the accommodation issue in light of the information provided and the individual needs of the employee. During the assessment phase, Edelman reserves the right to require further information, including relevant medical information or opinions that will assist Edelman to determine if accommodation can be achieved and how it can be achieved. Edelman further reserves the right to require the employee to participate in a formal needs assessment by a qualified medical practitioner or other trained professional in order to assist in determining what accommodation is needed, how much it will cost, and how it can be provided. The costs of any assessment required by Edelman will be covered by Edelman. The employee may request the participation of an employee representative in the development of the accommodation plan.
- 1.04 The VP of Human Resources and General Manager will jointly finalize a decision regarding the accommodation issue. The manager shall notify the employee in writing or other format as required by the employee’s disability, the decision and the reason(s) for the decision.
- 1.05 If the employee is not satisfied with the written decision regarding the request for accommodation, the employee may appeal the decision to the General Manager for further review. The decision of the General Manager shall be final and binding upon the parties.
- 1.06 Edelman shall ensure that the employee’s personal information shall be kept confidential and only disclosed to those necessary in the assessment and development of the accommodation in accordance with SPP 5.07.ON – Personal Information Protection.
- 1.07 All complaints regarding Edelman’s accessibility and accommodation plan will be brought to the VP of Human Resources at Edelman. Each complaint will be addressed individually and followed up on in writing within seven business days.
6. Information and Communications Policy
At Edelman, we are passionate about communications and leaders in our industry. Ensuring that our clients can communicate effectively with customers is at the heart of what we do. Our vision is to ensure that our communications are inclusive to everyone.
This policy relates to print and digital media as well as two-way communication through via telephone, email, meetings and presentations. It does not apply to commercial products or product labels, information that is not controlled directly by Edelman, or information or communications that cannot be converted.
We will ensure that we provide information and communications to our customers and the public in alternate formats upon request and in a timely manner. Depending on the situation this may include, and is not limited to:
- Large print
- Closed captioning,
- High colour contrast
- American Sign Language
- Text transcription of audio or visual information
- Information written in plain language
- A electronic format formatted to be accessible for use with a careen reader
In determining an appropriate format, we commit to consulting with the requestor.
Edelman Canada is committed to achieving the Worldwide Consortium Accessible Guidelines (WCAG) as outlined in section 14 of the Integrated Accessibility Standards Regulation. Accessible websites will ensure that all of our clients and the public will have access to our groundbreaking work and thought leadership.
Edelman Canada will work with building management to ensure that accessibility is considered in emergency procedures and that alternate formats are provided upon request.
7. Design of Public Spaces
Edelman Canada is not an organization generally open to the public. Areas when our clients or others may visit are our reception area, common space and meeting rooms. We will strive to ensure that we meet principles of universal design all of our meeting or reception areas and implement the AODA design requirements for any planned renovations to relevant areas.
In order to serve our clients effectively, we will endeavor to make them aware of universal design and accessible features when planning events.