The purpose of this policy is to identify, remove and prevent barriers for people with disabilities in obtaining, using and benefiting from the services offered by the Canadian Bar Association.
“Disability” is defined in Appendix A attached hereto.
This policy consists of six parts:
- Part 1 – Policy Scope
- Part 2 – Commitments to Accessibility
- Part 3 – Training
- Part 4 – Feedback
- Park 5 – Documentation
- Part 6 – Responsibility for the Policy
Part 1 – Policy Scope
1.1 The policy requires all CBA staff, individuals in a volunteer role with the CBA, and all third-party contractors providing goods and services on behalf of the CBA, to accept responsibility under the policy and be accountable for its successful implementation. The policy refers to these individuals as “service providers”.
1.2 The policy applies to any individual not mentioned in section 1.1, including CBA members, who has a disability and enters the CBA’s premises, or interacts with the CBA by telephone, over the internet, or through any other means of communication. The policy refers to these individuals as “service recipients”.
1.3 The policy does not override the CBA’s legal obligations to a service recipient as a result of any law including, for example, a provincial human rights code.
Part 2 – Commitments to Accessibility
2. The CBA will respect the dignity and independence of a service recipient and provide him or her with an equal opportunity to access, use and benefit from the services offered by the CBA.
2.2 For the purpose of the policy “communications” means a process of providing, sending, receiving, and understanding information.
2.3 Service providers will communicate with service recipients in a way that accommodates the service recipient’s disability. The service provider will make it a practice to ask “how can I help you?” and work with the service recipient to try to find the most accommodating means of providing the information, document, or service required by the service recipient.
2.4 The CBA will provide an accessible telephone service to accommodate the needs of service recipients through the use of clear pronunciation, plain language and an appropriate pace. The CBA will offer to communicate with service recipients through alternate means of communication, such as e-mail, fax, or mail, where telephone communication is not suitable.
2.5 CBA members may use the CBA’s secure access portal to communicate with the CBA.
2.6 Service providers will accommodate service recipients in using personal assistive devices to access CBA’s services. CBA staff will be trained to be familiar with assistive devices, and on where they can secure the necessary support to assist service recipients in accessing CBA services.
2.7 Service providers will accommodate the use of service animals by service recipients, as allowed by law. In situations where the entry of a service animal is excluded by law, the service provider will work with the service recipient to make alternate arrangements to provide CBA’s services.
2.8 When a service recipient is accompanied by a support person, the service provider will ensure that both individuals may enter the premises, and that the service recipient has access to the support person at all times while on the premises.
2.9 When the CBA is charging an admission fee for an event, it will clarify in its advance publicity what fee, if any, applies to a support person.
Notice of Service Disruption
2.10; When a disruption in a service or facility used by a service recipient is anticipated, the CBA will provide advance notice of the disruption by posting a notice in a conspicuous place near the affected service or facility, as well as by any other method deemed reasonable under the circumstances. The notice will set out the reason for the disruption, a description of alternate facilities or services available, if any, and the expected time period for the disruption. In circumstances where the disruption occurs suddenly or unexpectedly, the CBA will provide the notice as soon as possible.
Part 3 – Training
3.1 All service providers will receive training on accessible customer service. The CBA will provide ongoing training for new service providers and updated training when changes are made to its policies or procedures.
3.2 Training will include information on:
- Why Ontario needs accessibility standards, the purpose behind the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard;
- The CBA’s policies, procedures and practices relating to the provision of accessible customer service;
- The assistive devises a service recipient might use;
- The ways to provide effective customer service to service recipients, including a person who uses an assistive device, works with a service animal, or requires the assistance of a support person; and
- What to do when a person with a disability is having difficulty accessing the CBA’s goods or services.
3.3 Trainers will include in the training information about the policy, the CBA’s Accessibility Training for Customer Service documents, and other relevant material.
3.4 The Human Resources department will maintain training records, including a record of the trainers, the individuals who received training, their positions, and the dates training was provided.
Part 4 – Feedback
4.1 The CBA will invite feedback on the accessibility of its goods and services by service recipients. Feedback may be provided:
- by mail;
- by telephone;
- in person;
- by e-mail; and
- through the CBA website.
4.2 Feedback received will be forwarded to the appropriate personnel, and the response will be documented and tracked.
4.3 A person providing feedback to the CBA will receive a response from the CBA within 30 days from the date theCBA received the feedback.
Part 5 – Documentation
5.1 The CBA will provide the following information on the CBA website, and will make it available in the appropriate formats to service recipients on request:
- the policy;
- the process for providing feedback on the accessibility of CBA goods and services; and
- the annual accessibility report.
5.2 The CBA will post a notice in the reception area welcoming service recipients to use assistive devices and encouraging them to ask for support from CBA staff.
Part 6 – Responsibility for the Policy
6.1 The Senior Management Team:
- sets corporate administrative policy and program direction.
- implements corporate administrative policy and program direction set by the Senior Management Team;
- monitors and ensures consistency in the application of the policy across the CBA;
- reviews and approves recommendations arising from feedback on the policy;
- maintains and annually reviews the policy; and
- receives and reviews all feedback related to customer service accessibility and ensures appropriate follow up with those providing the feedback.
6.3 Directors and Supervisors:
- oversee the consistent application of the policy and related processes within their departments and with third-party providers;
- foster an environment that reflects and supports the purpose of the policy; and
- work in compliance with the policy and related processes.
6.4 The Director, Human Resources:
- coordinates or administers mandatory training for employees on accessibility standards for customer service, including tracking the training provided;
- coordinates assessments of the impact of the applicable legislation on CBA services and service delivery; and
- coordinates the preparation of documents, including the annual accessibility report, as required by legislation.
6.5 Service Providers – Employees, Volunteers and Third-Party Contractors:
- work in compliance with the policy and related processes; and
- attend training and education sessions on accessible customer service when required.
Accessibility for Ontarians with Disabilities Act, 2005
- 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, 1997; (“handicap”)