Accessibility

Primacy’s Accessible Customer Service Policy

Purpose

The Accessibility for Ontarians with Disabilities Act, 2005 (the AODA) is a Provincial Act that legislates the development, implementation and maintenance of accessibility standards in the workplace.  The goal of this Act is to implement measures that support equity and accessibility for persons with disabilities with respect to goods, services, facilities, accommodation, employment, buildings, structures and premises.

Under the AODA, Ontario Regulation 429/07 entitled “Accessibility Standards for Customer Service” establishes accessibility standards specific to customer service for public sector organizations and other persons or organizations that provide goods and services to members of the public or other third parties.

This policy has been developed in accordance with the Accessibility Standards for Customer Service (Ontario Regulation 429/07) and addresses the following, as related to persons with disabilities:

• The provision of goods and services 
• The use of assistive devices, service animals, and/or support persons 
• Notice of temporary disruptions in services and facilities
• Training services and resources
• Customer feedback processes regarding the provision of goods and services 
• Notice of availability and accessibility formats 

This policy applies to all persons who deal with members of the public or other third parties on behalf of Primacy, whether the person does so as an employee, agent, contractor, volunteer, student on placement, or otherwise and all persons who participate in developing Primacy’s policies, practices and procedures governing the provision of goods and services to members of the public or other third parties.

Definitions:

Assistive Device

A device used to assist persons with disabilities in carrying out activities or in accessing the services of persons or organizations covered by the Customer Service Standard.

Barrier

As defined by the Accessibility for Ontarians with Disabilities Act, 2005, “barrier” means anything that prevents a person with a disability from fully participating in all aspects of society because of their disability, including a physical barrier, an architectural barrier, an information or communications barrier, an attitudinal barrier, a technological barrier, a policy or practice.

Disability

• 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 coordination, 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.

Guide Dog

A guide dog as defined in section 1 of the Blind Persons’ Rights Act is a dog trained as a guide for a blind person and having qualifications prescribed by the regulations under the Blind Persons’ Rights Act.

Service Animal

Any animal used by a person with a disability for reasons relating to the disability and where it is readily apparent that the animal is used by the person for reasons relating to their disability; or where the person provides a letter from a physician or nurse confirming that the individual requires the animal for reasons relating to their disability; or a valid identification card signed by the Attorney General of Canada or a certificate of training from a recognized guide dog or service animal training school.

Support Person

A person who accompanies an individual with a disability in order to assist with communication, mobility, personal care, or medical needs or with access to goods or services.

General Principles:

The Provision of Goods and Services to Persons with Disabilities

Primacy will use reasonable efforts to ensure that its policies, practices and procedures are consistent with the following principles:

• Primacy’s goods and services are provided in a manner that respects the dignity and independence of persons with disabilities;
• The provision of Primacy’s goods and services to persons with disabilities are integrated with those provided to persons who do not have disabilities unless an alternative measure is necessary to enable a person with a disability to obtain, use or benefit from Primacy’s goods or services and,
• Persons with disabilities are given an opportunity equal to that of persons without disabilities to obtain, use or benefit from Primacy’s goods and services.

Communication with Persons with Disabilities

When communicating with a person with a disability, Primacy will do so in a manner that takes into account the person’s disability.

Recruiting

Primacy values diversity and is an equal opportunity employer. Primacy is committed to being responsive to the diverse needs of its members, employees, and others, by striving to prevent and remove systemic barriers.

Notice of Temporary Disruptions in Services and Facilities

Temporary disruptions in Primacy’s services and facilities may occur due to reasons that may or may not be within Primacy’s control or knowledge. When temporary disruptions occur to Primacy services or facilities, Primacy will provide notice by posting the information in visible places, or on Primacy website, www.primacy.ca, or by any other method as soon as reasonably possible. Primacy will make reasonable effort to provide notice of the disruption to the public or third parties, including information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if any, that may be available.  Primacy will make reasonable effort to provide prior notice of planned disruption if possible, recognizing that in some circumstances such as in the situation of unplanned temporary disruption, advance notice will not be possible. In such cases, Primacy will provide notice as soon as possible.

Assistive Devices and other Measures that Assist with Accessibility

A person with a disability may provide their own assistive device for the purpose of obtaining, using and benefitting from Primacy’s goods or services.  Exceptions may occur in situations where Primacy has determined that the assistive devices may pose a risk to the health and safety of a person with a disability or the health and safety of others on the premises.

In these situations, and others, Primacy may offer a person with a disability other reasonable measures to assist the individual in obtaining, using and benefiting from Primacy’s goods or services, where Primacy has such other measures available.

It should be noted that it is the responsibility of the person with a disability to ensure that the assistive device is operated in a safe and controlled manner at all times.

Service Animals

Persons with a disability may enter premises owned and/or operated by Primacy accompanied by a service animal and may keep the animal with them if the public has access to such premises and the animal is not otherwise excluded by law.  If a service animal is excluded by law, Primacy will ensure that alternate means are available to enable the person with a disability to obtain, use or benefit from Primacy’s goods or services.

It should be noted that it is the responsibility of the person with a disability to ensure that the service animal is kept in control at all times.

Support Persons

A person with a disability may enter premises owned and operated, or operated, by Primacy with a support person and have access to the support person while on the premises.

Primacy may require a person with a disability to be accompanied by a support person while on Primacy’s premises in situations where it is necessary to protect the health or safety of the person with the disability or the health and safety of others on the premises.

Feedback

Primacy is committed to providing high quality goods and services to all members of the public or third parties it serves.  Feedback from the public or third parties is welcomed as it may identify areas that require change and encourage continuous service improvements.

Feedback from a member of the public or third party about the delivery of goods and services to persons with disabilities may be given by telephone, in person, in writing, in electronic format at [email protected] or through other methods.

Information about the feedback process will be readily available and notice of the process is posted on Primacy website, www.primacy.ca, and in other appropriate locations.

Training

Primacy will ensure that all persons to whom this policy applies receive training as required by the Accessibility Standards for Customer Service and the Ontario Human Rights Code as it applies to persons with disabilities. When any changes are made to the accessibility policy, employees and staff will be given updated training as needed. All training will be documented and available upon request. The content of the training will include:

• A review of the purposes of the AODA;
• Requirements of the Accessibility Standards for Customer Service (Ontario Regulation 429/07) and the Ontario Human Rights Code;
• Instructions on Primacy’s policies, procedures and practices pertaining to the provision of goods or services to persons with disabilities;
• How to interact and communicate with persons with various types of disabilities;
• What to do if a person with a particular type of disability is having difficulty accessing our goods or services;
• How to interact with persons with disabilities who use assistive devices or who require the assistance of a support person or service animal; and
• Information about the equipment or devices available on Primacy’s premises, if applicable.

Availability and Format of Documents Required by the Accessibility Standards for Customer Service (Ontario Regulation 429/07)

All documents required by the Accessibility Standards for Customer Service including Primacy’s Accessible Customer Service policies, procedures, and practices, notices of temporary disruptions, training records, and written feedback process are available upon request.

When providing a document to a person with a disability, Primacy will provide the document, or the information contained in the document, in a format that takes the person’s disability into account.

Notice of the Availability of Documents

Notice of the availability of all documents required by the Accessibility Standards for Customer Service will be posted on Primacy’s website and posted in a prominent location on our premises.

Annual Reviews

Primacy will conduct annual reviews of our policies and multi-year plan to ensure that we are meeting all accessibility standards as outlined in the Accessibility for Ontarians with Disabilities Act and Integrated Accessibility Standards Regulations. We will update our policies and plans in accordance with changes to the legislation.

This policy may be made available in alternate formats upon request.