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POLICY STATEMENT

Niagara-on-the-Lake Hydro (NOTL Hydro) respects the dignity and independence of people with disabilities. NOTL Hydro is committed to developing, implementing, and maintaining accessibility standards that will achieve accessibility for people with disabilities with respect to goods, services, facilities, employment, and physical premises. NOTL Hydro strives at all times to act in accordance with the principles set out in AODA and the Integrated Standards to create an inclusive environment for people with disabilities so that they may have the same opportunities, in the same places, and the same ways as other individuals.

PURPOSE

To provide the overarching framework that guides the review and development of other corporate policies, standards, procedures and guidelines with a commitment to creating an inclusive and supportive environment while complying with the standards developed under the Accessibility for Ontarians with Disabilities Act (“AODA”), 2005.
To provide a Statement of Commitment that highlights NOTL Hydro’s organizational commitment to meet the accessibility needs of persons with disabilities ensuring a culture of inclusivity and care. This is reflected in the policy statement above.
To provide the general requirements of the Customer Service Accessibility Standards and Employment Accessibility Standards.
To provide the general requirements that are applicable to all NOTL Hydro IASR (Integrated Accessibility Standards Regulation) procedures, prioritizing accessibility, respect and the well-being of all employees.
To establish the Integrated Accessibility Standards, Ontario Regulation 191/11 for NOTL Hydro in accordance with the AODA, 2005.

SCOPE

Customer Service Accessibility Standards apply to all persons (employees, volunteers, contractors, agents, etc.) in all facilities of NOTL Hydro in Ontario that deal with members of the public on behalf of NOTL Hydro, and to those people who establish NOTL Hydro policies, practices and/or procedures.

Employment Standard Accessibility Standards apply to all applicants, prospective employees and paid employees, and all facilities of NOTL Hydro in Ontario. However, it does not apply to volunteers and other non-paid employees.

This is a corporate policy which is designed to augment other corporate policies and is not intended to replace or preclude them. Should there be a conflict between the application of this Policy and any other policy, the policy most specific to the situation will apply.

RESPONSIBILITY

Employee / Volunteer / Contractor responsibilities are to:

Attend all applicable training and training on this policy provided by NOTL Hydro as it pertains to the duties of the employee/volunteer/contractor.
Apply and follow this policy diligently every day.
Keep up to date with any updates and new accessibility policies and procedures including training sessions.
Report any disruption, feedback or issues in service and access, as well as when providing goods and services to Supervisors/Managers, as appropriate.

Supervisors/Managers/Department heads are responsible to:

Understand the programs, procedures and policies that are being implemented.
Ensure accessibility procedures pertaining to their department are in place.
Implement and communicate this policy to all employees, volunteers, and customers.
Ensure that all employees/volunteers/contractors follow the guidelines set out in this policy.
Ensure all employees/volunteers/contractors are trained under the applicable accessibility standards and the AODA, including this policy.
Undergo training themselves and actively seek information on the issues of effective customer service and workplace accessibility, as well as to keep informed of changes to the law or policy.
Have signs and posters in their department, as may be required, that are easy for persons with disabilities to understand.
Ensure the guidelines are applied and monitored for effectiveness.
Deal positively with any feedback received regarding this policy or any guidelines or measures in place.

Responsibility of Employer:

Ensure all relevant programs, policies and procedures are developed and implemented.
Ensure all policies are up-to-date and communicated to all employees.
Ensure policies are posted in a conspicuous place and available in an accessible format that meets the needs of persons with disabilities when requested.
Make training available for all employees/volunteers/contractors as soon as practicable.
In collaboration with Supervisors/Managers ensure this policy and customer service accessibility procedures are effective; and if not, take corrective action, modify the policy, communicate changes to employees/volunteers/contractors, re-train employees /volunteers/contractors if necessary and continue to monitor the effectiveness of this policy and its procedures.
Ensure information on disruptions to goods and services is posted in the affected facility and location and is communicated when necessary.
Ensure a feedback process is in place to receive and respond to any comments, complaints or issues on this policy or accessibility measures.

TRAINING

NOTL Hydro will ensure that training is provided on the requirements of the accessibility standards referred to in the Regulation and continue to provide training on the Human Rights Code as it pertains to persons with disabilities, to:

All its employees.
All persons who participate in developing NOTL Hydro policies.
All other persons who provide goods, services, or facilities on behalf of the company.

The training will be appropriate to the duties of employees and other persons. Employees will be trained when changes are made to the accessibility policy. New employees will be trained as required. NOTL Hydro will keep a record of the training it provides.

ONLINE TRAINING

AODA Training	https://aoda.ca/free-online-training/ Time to complete – Approx 60-75 minutes.
Ontario Human Rights Code Training:	Certificate Version \| Ontario Human Rights Commission (ohrc.on.ca) Time to complete – Approx 20-30 minutes.
Access Forward Ontario Training	https://accessforward.ca/ Customer Service Standard (40-50 min) General Requirements (12-17 min) Employment Standard (12-17 min)

DEFINITIONS

ACCESSIBILITY STANDARD	AN ACCESSIBILITY STANDARD OUTLINED IN THE IASR.
Accessible	means capable of being entered or reached, approachable; easy to get at; capable of being influenced, obtainable; able to be understood or appreciated.
Accessible formats	may include, but are not limited to, large print, recorded audio and electronic formats, braille, and other formats usable by persons with disabilities.
Accommodation	means the special arrangements made or assistance provided so that persons with disabilities can participate in the experiences available to persons without disabilities. Accommodation will vary depending on the person’s unique needs.
Assistive devices	are auxiliary aids such as communication aids, cognition aids, personal mobility aids and medical aids (e.g., canes, crutches, wheelchairs, or hearing aids).
Barrier	means anything that prevents a person with a disability from fully participating in all aspects of society because of his or her disability, including a physical barrier, an architectural barrier, an information or communications barrier, an attitudinal barrier, a technological barrier, a policy, or a practice; (“obstacle”)
Career Development and Advancement	includes providing additional responsibilities within an employee’s current position and the movement of an employee from one job to another in an organization that may be higher in pay, provide greater responsibility or be at a higher level in the organization or any combination of them and, for both additional responsibilities and employee movement, is usually based on merit or seniority or a combination of them.
Communication supports	may include, but are not limited to, captioning, alternative, and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications.
Communications	means the interaction between two or more persons or entities, or any combination of them, where information is provided, sent, or received
Customers	people who receive goods or services from your organization.
Dignity	means respecting and treating every person, including persons with a disability, as valued and deserving of effective and full service, just as any other customer.
Dignity	means service is provided in a way that allows the individual to maintain self-respect and the respect of other persons.
Disability	as per the Ontario *Human Rights Code, means: 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.An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act*.
Employees	means every person who deals with members of the public or other third parties on behalf of NOTL Hydro, whether the person does so as an employee (part-or full-time), agent, volunteer, consultant or otherwise.
Equal opportunity	means service is provided to individuals in such a way that they have an opportunity to access goods or services equal to that given to others.
Guide dog	is defined in section 1 of the Blind Persons’ Rights Act. A “guide dog” means a dog trained as a guide for a blind person and having the qualifications prescribed by the Guide Dogs Regulations (R.R.O. 1990, Reg. 58).
Independence	means freedom from control or influence of others, freedom to make your own choices.
Information	includes data, facts and knowledge that exists in any format, including text, audio, digital or images, and that conveys meaning.
Integration	means service is provided in a way that allows the individual to benefit from equivalent services, in the same place and in the same or similar way as other individuals, unless an alternate measure is necessary to enable the individual to access goods or services.
Mobility aid	means a device used to facilitate the transport, in a seated posture, of a person with a disability.
Mobility assistive device	means a cane, walker, or similar aid.
Performance Management	means activities related to assessing and improving employee performance, productivity, and effectiveness with the goal of facilitating employee success.
Persons with Disabilities	are individuals who have a disability, as defined under the Ontario Human Rights Code (and above).
Redeployment	means the reassignment of employees to other departments or jobs as an alternative to layoff when a particular job or department has been eliminated by the organization.
Service Animal	the animal can be readily identified as one that is being used by the person for reasons relating to the person’s disability, because of visual indicators, such as a vest or harness worn by the animal; orthe person provides documentation from one of the following regulated health professionals confirming that the person requires the animal for reasons related to the disability:A member of the College of Audiologists and Speech-Language Pathologists of Ontario.A member of the College of Chiropractors of Ontario.A member of the College of Nurses of Ontario.A member of the College of Occupational Therapists of Ontario.A member of the College of Optometrists of Ontario.A member of the College of Physicians and Surgeons of Ontario.A member of the College of Physiotherapists of Ontario.A member of the College of Psychologists of Ontario.A member of the College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario. O. Reg. 165/16, s. 16. Note: Service animals have training to perform specific tasks for people with disabilities. Emotional support animals provide comfort and security. However, they do not have training for specific tasks. Therefore, emotional support animals do not qualify as service animals under the AODA.
Support person	in relation to a person with a disability, is another person who accompanies them to help with communication, mobility, personal care, medical needs or with access to goods, services or facilities.
WCAG guidelines	explain how to make web content more accessible to people with disabilities. Web content generally refers to the information on a web page or a web application, including but not limited to text, images, and forms.

CUSTOMER SERVICE ACCESSIBILITY STANDARDS

The standards described in this Section and the Plan are designed to ensure NOTL Hydro identifies, prevents, and removes barriers with respect to goods, services, facilities, employment, information provided to, and communications with, all individuals who have disabilities.

Customer Service Accessibility Standards standard applies to all persons/ employees/ volunteers/ contractors/ agents in all facilities of NOTL Hydro in Ontario that deal with members of the public on behalf of NOTL Hydro, and those people who establish NOTL Hydro’s policies/procedures/practices.

COMMUNICATION AND COMMUNICATION SUPPORTS

NOTL Hydro will communicate with people with disabilities in a manner that is accessible and in ways that respectfully consider their disabilities.

On request, NOTL Hydro will consult with people with disabilities to provide or arrange for support for communication to ensure that communications are accessible. If telephone communication is not suitable for a customer’s needs, alternative forms of communication will be offered, as required and when requested.

FORMAT OF DOCUMENTS

On request, NOTL Hydro will provide documents, or the information contained in documents, to a person with a disability in a format that takes the person’s disability into account. NOTL Hydro will consult with the individual making the request when determining the suitability of the accessible format.

WEBSITE AND CONTENT

NOTL Hydro is committed to creating and maintaining web content that is accessible for people with disabilities. In accordance with the AODA (and IASR), NOTL Hydro will generate and maintain material on the internet in accordance with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, at Level AA standards. Areas that are not compliant will be addressed on an ongoing basis.

USE OF ASSISTIVE DEVICES

NOTL Hydro is committed to serving people with disabilities who use assistive devices to obtain, use, access or benefit from our goods, services, and facilities by.

Ensuring that the access, use and benefit of goods, services or facilities are not compromised for persons with disabilities who require assistive devices.
Allowing persons with disabilities to obtain, use or benefit from goods or services using their own assistive devices. Exceptions may occur in situations where NOTL Hydro has determined that the assistive device 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, if a person with a disability is hindered from accessing goods or services or facilities, NOTL Hydro will accommodate the customer by providing an alternative, where possible.
It is the responsibility of the person with a disability to ensure that his or her assistive device is always operated in a safe and controlled manner.
NOTL Hydro will ensure that employees are trained as required to use assistive devices that we make available on our premises.

INCLUSIVE MEETINGS

NOTL Hydro will ensure that meetings are inclusive, planned and organized in a manner that integrates products and services that maximize the participation of persons with disabilities.

SERVICE ANIMALS

NOTL Hydro is committed to welcoming people with disabilities who are accompanied by a service animal on the parts of our premises that are open to the public and other third parties by:

Ensuring that the access, use and benefit of goods or services or facilities are not compromised for persons with disabilities who are accompanied by a service animal, guide dog or support person.
Service animals, including guide dogs are permitted entry to all NOTL Hydro areas that would normally be accessible to the public, the only exceptions being as follows,
Service animals are not permitted where otherwise disallowed by law. In the rare case where a service animal is to be denied access to goods, services or a facility, other accommodations may be afforded, such as alternate format, e.g., teleconference, where technology permits; delivery of goods or service at an alternate time or location; other assistive measures available to deliver goods or service to ensure equality of outcome.
- Service animals are not permitted where a severe allergy to, or fear of, an animal is known by NOTL Hydro. In the rare case where a service animal is to be denied access to goods, services or a facility, other accommodations may be afforded, such as alternate format, e.g., teleconference, where technology permits; delivery of goods or service at an alternate time or location; other assistive measures available to deliver goods or service to ensure equality of outcome.
- Where the service animal or guide dog behaves badly and cannot be controlled. In the rare case where a service animal is to be denied access to goods, services or a facility, other accommodations may be afforded, such as alternate format, e.g., teleconference, where technology permits; delivery of goods or service at an alternate time or location; other assistive measures available to deliver goods or service to ensure equality of outcome.
Employees should avoid touching or addressing service animals or making eye contact with service animals. These animals are working and have to pay attention to their owner at all times.
The customer is responsible for the care and supervision of the service animal.

SUPPORT PERSONS

NOTL Hydro is committed to welcoming customers with disabilities who are accompanied by a support person by doing the following:

Allowing any person with a disability who is accompanied by a support person to enter NOTL Hydro premises with his or her support person.
At no time will a person with a disability who is accompanied by a support person be prevented from having access to his or her support person while on the NOTL Hydro premises.
If a support person is necessary for the health and safety of a person with disabilities, or for the health and safety of other persons, NOTL Hydro will require the accompaniment of a support person on the premises. The customer will determine whether a support person is necessary, however, where an employee believes a support person should be in attendance to protect the health and safety of the customer or others, the following criteria will be used in consulting with the customer:
When there is a significant risk to the health and safety of the person with a disability, or to others:
- When the risk cannot be eliminated or reduced by other means
- When the assessment of the risk is based on consideration of the duration of the risk, the nature and the severity of the potential harm, the likelihood that the potential harm will occur, and the imminence of the potential harm.
- When the assessment of the risk is based on the individual’s actual characteristics, not merely on generalizations, misperceptions, and ignorance or fears about a disability.
Customers are required to provide their own support person (s). Customers are expected to inform NOTL Hydro in advance where possible that they will be using the premises with a support person.

NOTICE OF TEMPORARY DISRUPTIONS

If a planned or unexpected service disruption occurs that would limit a person with a disability from gaining access to NOTL Hydro facilities or services, NOTL Hydro will provide appropriate notice to make the disruption known to staff, employees, customers, and visitors in the following ways:

Where possible, the person(s) with a disability will be directly informed of the disruption.
When feasible, a notice of the service disruption will be posted on the premises where the service disruption occurs.
Messages will be posted on the NOTL Hydro website, where possible.
Notices of service disruption will be announced over NOTL Hydro voicemail and email systems, where applicable.
Where possible, persons with disabilities will be notified directly if the person has made prior arrangements with NOTL Hydro to be notified directly by telephone, email, or another alternative format.

FEEDBACK PROCESS

The ultimate goal of NOTL Hydro is to meet and surpass customer expectations while serving customers with disabilities. Comments on our services regarding how well those expectations are being met are welcome and appreciated. Feedback may be provided on the accessibility of the provision of goods and services by NOTL Hydro and its affiliates in the manner deemed most convenient to:

Niagara-on-the-Lake Hydro
Manager, Corporate Services
PO Box 460, 8 Henegan Road
Virgil, Ontario L0S 1N0

Phone – 905-468-4235
Email – accessibility@notlhydro.com

A feedback form can be obtained from NOTL Hydro reception and from NOTL Hydro’s website (www.notlhydro.com) under CUSTOMER SERVICE > CORPORATE POLICIES > Accessibility. Responses (when requested), will follow within ten (10) business days, or as soon as possible

All feedback will be kept in strict confidence and will be used to improve customer service.

EMPLOYMENT STANDARDS

This policy applies to all applicants, prospective employees and paid employees, and all facilities of NOTL Hydro in Ontario. For clarity, it does not apply to volunteers and other non-paid employees.

CAREERS AT NOTL HYDRO

NOTL Hydro recognizes the value and importance of a diverse and inclusive workforce. Equal employment opportunities will be made available to employees and applicants with disabilities in a manner that respects their independence and dignity.

When recruiting for a position, NOTL Hydro will notify potential and actual applicants (both internal and external) about the availability of accommodation. Where accommodation is requested, NOTL Hydro will consult with the individual requesting it to provide a suitable accommodation. During recruitment, NOTL Hydronotifies both the public and its employees that it will provide accommodation for applicants with disabilities. It does this by including the following statement in its job postings.

“NOTL Hydro welcomes and encourages applications from candidates with disabilities. Accommodations are available on request for candidates taking part in the selection process.”

Upon request, employees with disabilities will be provided with performance management and career development tools (e.g., performance appraisals, job postings, and job descriptions) that are accessible.

Where an employee with a disability changes positions within NOTL Hydro, accommodations will be implemented as required for the new position, which will respect the employee’s dignity and independence, and foster an inclusive work environment.

COMMUNICATION AND COMMUNICATION SUPPORTS

Where the person with a disability is an Employee, NOTL Hydro will provide the communication supports and document formats necessary to enable them to perform their job meaningfully and effectively, and, on request, will make accessible any information otherwise available to employees in a manner that respectfully considers their disability.

EMERGENCY RESPONSE INFORMATION

NOTL Hydro ensures that individualized workplace emergency response information is provided to employees with a disability provided the disability is such that individualized information is necessary and the organization has been made aware of the need for accommodation due to the disability. NOTL Hydro provides the necessary information as soon as practicable after becoming aware of the need for accommodation.

If an employee who receives individualized workplace emergency response information requires assistance, NOTL Hydro will, with the consent of the employee, provide such information to the person designated to help the employee.

NOTL Hydro will review individualized workplace emergency response information:

When the employee moves to a different location in the organization.
When the employee’s overall accommodation needs or plans are reviewed.
When the organization reviews its general emergency response procedures.

INDIVIDUAL ACCOMMODATION PLANS

NOTL Hydro has a written process in place for the development of documented individual accommodation plans for employees with disabilities. NOTL Hydro’s written process address:

How the 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.
How the company can request an evaluation by an outside medical or other expert, at the company’s expense, to assist in determining if accommodation can be provided and, if so, how it can be provided.
How the employee can request to have a representative of their bargaining unit, or another workplace representative if the employee is not a member of a bargaining unit, participate in the development of the accommodation plan.
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 how this will be done.
How the reasons for denying an individual accommodation plan will be provided to an employee if accommodation is denied.
How the company will ensure that the individual accommodation plan is provided in a format that considers the employee’s accessibility needs due to a disability.

NOTL Hydro provides individual accommodation plans that:

Include, if requested, any information regarding accessible formats and accommodation support provided.
Include, if required, individualized workplace emergency response information.
Identify any other accommodation to be provided.

RETURN-TO-WORK

NOTL Hydro has a written return-to-work policy and process for employees who have been absent from work due to a disability and require disability-related accommodation to return to work. This includes the requirements under the AODA and it does not replace or override any other return-to-work process created as a result of any other statutory obligations under the Workplace Safety and Insurance Act and requires NOTL Hydro to develop, put in place and document 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. The return-to-work policy and process includes:

An outline of the steps NOTL Hydro will take to facilitate the return to work of employees who were absent because their disability required them to be away from work.
The use of documented individual accommodation plans as part of the process.
Accessibility awareness training for all staff involved in program or course design, delivery and instruction related to these responsibilities.

PERFORMANCE MANAGEMENT

In administering performance management processes in respect of employees with disabilities, NOTL Hydro will consider the accessibility needs of employees with disabilities as well as individual accommodation plans.

CAREER DEVELOPMENT

Where NOTL Hydro provides career development and advancement opportunities for its employees, NOTL Hydro will consider the accessibility needs of employees with disabilities as well as any individual accommodation plans.

REDEPLOYMENT

Where NOTL Hydro has a redeployment process in place, it will consider the accessibility needs of employees with disabilities as well as any individual accommodation plans during the redeployment process.

MAINTAINING COMPLIANCE

No changes will be made to this policy before considering the impact on people with disabilities.

Any policy of NOTL Hydro that does not respect and promote the dignity and independence of people with disabilities will be modified and/or removed.
Policies governing how the organization is committed to providing accessible customer service will be reviewed at least annually or when there are changes in the law or procedures, or when an incident or breach occurs.

LEGISLATIVE CONTEXT

The Accessibility for Ontarians with Disabilities Act, 2005

The Accessibility for Ontarians with Disabilities Act, 2005 (“AODA” or the “Act”) is a law passed by the Ontario legislature with the goal of creating standards to improve accessibility for people with disabilities across the province. AODA allows the government to develop specific standards of accessibility and to enforce them. The standards are made into laws called regulations, and they provide the details to help meet the goal of the AODA. The standards set requirements in a number of key areas and will be reviewed at least every five years.

The Integrated Accessibility Standards (O. Reg. 191/11)

The Integrated Accessibility Standards for the Accessibility for Ontarians with Disabilities Act, 2005 – O. Reg. 191/11 (the “Integrated Standards”) are a set of accessibility standards developed under the AODA to establish accessibility in the following areas: information and communications (the “Information and Communication Standard”), employment (the “Employment Standard”), transportation (the “Transportation Standard”), the design of public spaces (the “Design of Public Spaces Standard”), and customer service (the “Customer Service Standard”). These standards apply to every person or organization that provides goods, services or facilities to the public or other third parties and that has at least one employee in Ontario.