Integrated Accessibility Standards - Multi Year Plan

Accessibility for Ontarians with Disabilities Act, 2005

Part I - General Requirements
SectionInitativeDescriptionActionStatusCompliance Date
3Establishment of Accessibility Policies3.(1) Every obligated organization shall develop, implement and maintain policies governing how the organization achieves or will achieve accessibility through meeting its requirements under the accessibility standards referred to in this Regulation.Review draft with Senior Management for approvalCompletedJanuary 1, 2014
4Accessibility Plans4.(1) Large organizations shall,

a) establish, implement, maintain and document a multi-year accessibility plan, which outlines the organization's strategy to prevent and remove barriers and meet its requirements under this Regulation;

b) post the accessibility plan on their website, if any, and provide the plan in an accessible format upon request; and

c) review and update the accessibility plan at least once every five years.
a) Attended workshop, started drafting plan

Identify and Review barriers by dealership

Consider establishing committee by dealership

b) to be posted upon approval
c) HR will review on regular basis

Once completed HR review will review every 5 years as required by legislation
CompletedJanuary 1, 2014
7Training7.(1) Every obligated organization shall ensure that training is provided on the requirements of the accessibility standards referred to in this Regulation and on the Human Rights Code as it pertains to persons with disabilities to,
(a) all employees, and volunteers;
(b) all persons who participate in developing the organization's policies; and
(c) all other persons who provide goods, services or facilities on behalf of the organization.
Policy consistent with training requirements

Method of training for management and employees is online videos

One training program; will explore to see if additional level of training needed
Initial training to employees Dec 2014

Ongoing with new employees
January 1, 2015
6Self-Serve Kiosks6.(2) Large organizations and small organizations shall have regard to the accessibility for persons with disabilities when designing, procuring or acquiring self-service kiosks.The Company uses banking machines which are in compliance.

Any new purchases need to comply with the accessibility requirements
CompletedJanuary 1, 2014
PART II - Information and Communications Standards
SectionInitativeDescriptionActionStatusCompliance Date
11Feedback11.(1) Every obligated organization that has processes for receiving and responding to feedback shall ensure that the processes are accessible to persons with disabilities by providing or arranging for accessible formats and communications supports, upon request.Review of feedback processes in company, both internally and externally

Determine what accessible formats we can make available by request

Ensure managers/staff are aware of accommodation by request (through training)
CompletedJanuary 1, 2015
12Accessible Formats & Communication Supports12.(1) Except as otherwise provided, every obligated organization shall upon request provide or arrange for the provision of accessible formats and communication supports for persons with disabilities,
a) in a timely manner that takes into account the person's accessibility needs due to disability; and
b) at a cost that is no more than the regular cost charged to other persons
Determine what accessible formats we will make available by request (PDF, Word, reading) both internally and externally

Determine what the timely manner is for each alternate format, for those not available immediately, will communicate back within how long (24 hours)? Yes we can, or no we can't, but can provide…

determine current costs
OngoingJanuary 1, 2016
1212.(2) The obligated organization shall consult with the person making the request in determining the suitability of an accessible format or communication support.Communicate to staff through training

Protocol when accommodation cannot be met (alternate accommodation)

Where questions arise, advice from HR is recommended
OngoingJanuary 1, 2016
1212.(3) Every obligated organization shall notify the public about the availability of accessible formats and communication supports.Post signs at reception, on website, intranet, printed materials

Based on how do we communicate with the public

How do we communicate with our employees

*look for examples, take pics
OngoingJanuary 1, 2016
13Emergency Procedures, Plans or Public Safety Info13.(1) In addition to its obligations under section 12, if an obligated organization prepares emergency procedures, plans or public safety information and makes the information available to the public, the obligated organization shall provide the information in an accessible format or with appropriate communication supports, as soon as practicable, upon request.Included in Emergency Response PlanCompletedJanuary 1, 2012
14Accessible Websites & Web Content14.(2) Designated public sector organizations and large organizations shall make their internet websites and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG)2.0, initially at Level A and increasing to Level AA, and shall do so in accordance with the schedule set out in this section.Review with Marketing Department who oversees company website Sent initial information to Marketing DepartmentCompleted / OngoingJanuary 1, 2016
New internet websites and web content on those sites must conform with WCAG 2.0 Level A.

January 1, 2021
All internet websites and web content must conform with WCAG 2.0 Level AA, other than,
  • success criteria 1.2.4 Captions (Live)
  • success criteria 1.2.5 Audio Descriptions (Pre-recorde d).
PART III - Employment Standard
SectionInitativeDescriptionActionStatusCompliance Date
22Recruitment - General22. Every employer shall notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment processes.Review recruitment process

Where are we advertising?

Wording in Job ads and Job Descriptions

"We are committed to providing accommodations for persons with disabilities. If you require accommodation we will work with you to meet your needs". - this should be woven in to all policies, training
OngoingJanuary 1, 2016
23Recruitment, Assessment or Selection Process23.(1) During a recruitment process, an employer shall notify job applicants, when they are individually selected to participate in an assessment or selection process, that accommodations are available upon request in relation to the materials or processes to be used.

(2) If a selected applicant requests an accommodation, the employer 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.
Determine how we notify all applicants

Appropriate language to use - only through HR

Identify interview room

Develop interview guidelines

Review Orientation/training processes
OngoingJanuary 1, 2016
24Notice to Successful Applicants24. Every employer shall, when making offers of employment, notify the successful applicant of its policies for accommodating employees with disabilitiesCommon language for all applicants

Notification through HR
OngoingJanuary 1, 2016
25Informing Employees of Supports25.(1) Every employer shall inform its employees of its policies used to support its employees with disabilities, including, but not limited to, policies on the provision of job accommodations that take into account an employee's accessibility needs due to disabilityDevelop and train managers on interviewing checklist

Circulating policy to all employees - through email, intranet, HR Bulletin Boards, added to New Hire Package

Training of employees
OngoingJanuary 1, 2016
2525.(2) Employers shall provide the information required under this section to new employees as soon as practicable after they begin their employment.Build in to Orientation programOngoingJanuary 1, 2016
2525.(3)Employers shall provide updated information to its employees whenever there is a change to existing policies on the provision of job accommodations that take into account an employee's accessibility needs due to disability.See 25.1 aboveOngoingJanuary 1, 2016
26Accessible Formats & Communication Supports for Employees26.1 In addition to its obligations under section 12, where an employee with a disability so requests it, every employer shall consult with the employee to provide or arrange for the provision of accessible formats and communication supports for,

(a) information that is needed in order to perform the employee's job; and

(b) information that is generally available to employees in the workplace.
Review format of Job Descriptions, SOP, MSDS sheets, New Hire Forms, other information staff is required to have to do their job - what is available and how is it available

Be open to accommodations

Create process, including HR department
2626.2. The employer shall consult with the employee making the request in determining the suitability of an accessible format or communication support.See 26.1 aboveOngoingJanuary 1, 2016
27Workplace Emergency Response Information27.(1) Every employer 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 due to the employee's disability.In Emergency Response PlanCompletedJanuary 1, 2012
27(2) If an employee who receives individualized workplace emergency response information requires assistance and with the employee's consent, the employer shall provide the workplace emergency response information to the person designated by the employer to provide assistance to the employee.In Emergency Response PlanCompletedJanuary 1, 2012
27(3) Employers shall provide the information required under this section as soon as practicable after the employer becomes aware of the need for accommodation due to the employee's disability.In Emergency Response PlanCompletedJanuary 1, 2012
27(4) Every employer shall review the individualized workplace emergency response information,

(a) when the employee moves to a different location in the organization;
(b) when the employee's overall accommodations needs or plans are reviewed; and
(c) when the employer reviews its general emergency response policies.
In Emergency Response PlanCompletedJanuary 1, 2012
28Documented Individual Accommodation Plans28.(1) Employers, other than employers that are small organizations, shall develop and have in place a written process for the development of documented individual accommodation plans for employees with disabilities.Will review template process and Develop process with HR

Create individual Accommodation Plan template with HR

*include in New Hire Forms
OngoingJanuary 1, 2016
2828 (2) The process for the development of documented individual accommodation plans shall include the following elements:

1. The manner in which an employee requesting accommodation can participate in the development of the individualaccommodation plan.

2. The means by which the employee is assessed on an individual basis.

3. The manner in which the employer can request an evaluation by an outside medical or other expert, at the employer's expense, to determine if and how accommodation can be achieved.

4. The manner in which the employee can request the participation of a representative from their bargaining agent, where the employee is represented by a bargaining agent, or other representative from the workplace, where the employee is not represented by a bargaining agent, in the development of the accommodation plan.

5. The steps taken to protect the privacy of the employee's personal.

6. The frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done.

7. If an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee.

8. The means of providing the individual accommodation plan in a format that takes into account the employee's accessibility needs due to disability.
Will review template process and adopt - meets all 8 requirements

*include in New Hire Forms
OngoingJanuary 1, 2016
29Return to Work Process29.(1) Every employer, other than an employer that is a small organization,
(a) shall develop and have in place a return to work process for its employees who have been absent from work due to a disability and require disability-related accommodations in order to return to work; and
(b) shall document the process
Review RTW Process to ensure it meets requirementsOngoingJanuary 1, 2016
2929. (2) The return to work process shall,
(a) outline the steps the employer will take to facilitate the return to work of employees who were absent because their disability required them to be away from work; and
(b) use individual documented accommodation plans, as described in section 28, as part of the process.
Review current process

Review template for Job Task Analysis with HR
OngoingJanuary 1, 2016
2929. (3) The return to work process referenced in this section does not replace or override any other return to work process created by or under any other statute.Review current processOngoingJanuary 1, 2016
30Performance Management30.(1) An employer that uses performance management in respect of its employees shall take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when using its performance management process in respect of employees with disabilities.Review current process, using accommodation if applicable

Review written, verbal, how long to review

Contact association for deaf, blind to see how they can assist with accommodation
OngoingJanuary 1, 2016
31Career Development & Advancement31.(1) An employer that provides career development and advancement to its employees shall take into account the accessibility needs of its employees with disabilities as well as any individual accommodation plans, when providing career development and advancement to its employees with disabilities.Review current process

How persons with disabilities can access and apply for advancement

Contact association for deaf, blind to see how they can assist with accommodation
OngoingJanuary 1, 2016
32Redeployment32.(1) An employer that uses redeployment shall take into account the accessibility needs of its employees with disabilities, as well as individual accommodation plans, when redeploying employees with disabilitiesReview current process

Contact association for deaf, blind to see how they can assist with accommodation
OngoingJanuary 1, 2016
Document Management

Effective Date: January 1, 2014
Revision Date: December 2014
Revision Date: January 2015