This policy establishes the requirements for accessibility standards for customer service in accordance with the Accessibility Standards for Customer Service (Ontario Regulation 429/07) as set out within the Accessibility for Ontarians with Disabilities Act (AODA).
The AODA was enacted for the purpose of developing, implementing and enforcing accessibility standards to ensure that customer service is available to everyone, including persons with disabilities.
APPLICATION AND SCOPE
This policy applies to:
1. All Woodbine Entertainment employees including, but not limited to temporary staff, volunteers, contractors and third party service providers who deal with members of the public and other third parties on our behalf.
WEG is committed to the provision of goods and services to all persons we serve, including persons with disabilities. This commitment will be reflected in WEG’s policies, practices and procedures.
Disability: (Source: Guide to the Accessibility Standards for Customer Service, Ontario Regulation 429/07). The following definition is the same as the definition of disability in the Ontario Human Rights Code and applies to the customer service standard of the AODA.
- 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 impairment, 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 development 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.
The definition includes disabilities of different severity, visible as well as non-visible disabilities, and disabilities with effects that may come and go.
Personal Assistive Devices: (Source: Guide to the Accessibility Standards for Customer Service, Ontario Regulation 429/07)
Products or services that can help an individual carry out daily activities with greater ease and independence, such as a walker, a personal oxygen tank, TTY (Telephone Teletype), or amplification systems.
Service Animal: (Source: guide to the Accessibility Standards for Customer Service, Ontario Regulation 429/07) An animal is a service animal when it is readily apparent that the animal is used for reasons relating to a disability or the person with a disability has a letter from a physician or nurse that states the animal is required for disability related reasons.
Support Person: (Source: Guide to the Accessibility Standards for Customer Service, Ontario Regulation 429/07) A person who accompanies an individual with a disability to assist with communication, mobility, personal care of medical needs or with access to goods or services. The support person could be a paid personal support worker, a volunteer, a friend or a family member.
1. General Principles 1.1 WEG will use reasonable efforts to ensure that policies, practices and procedures are documented and consistent with the following core principles of the standard:
a) Dignity – Respect the dignity of a person with a disability. Treat them as customers and clients who are as valued and as deserving of effective and full service as any other customer.
b) Independence – People who may move or speak more slowly should not be denied an opportunity to participate in a program or service because of this factor. A WEG employee should not hurry them or take over a task for them if they prefer to do it themselves in their own way.
c) Integration – Allow people with disabilities to fully benefit from the same services, in the same place and in the same or similar way as other customers. Sometimes, integration does not serve the needs of all people with disabilities. In the case of services, it means that people with disabilities have the same opportunity to benefit from the way you provide goods or services as others. They should not have to make significantly more effort to access or obtain service. They should also not have to accept lesser quality or more inconvenience.
2 Communication and Documentation
2.1 When communicating with a person with a disability, employees will do so in a manner that takes into account the person’s disability
2.2 When providing a copy of a document to a person with a disability WEG shall give the person the document, or the information contained in the document, in a format that takes into account the person’s disability.
3 Personal Assistive Devices
3.1 WEG permits customers with disabilities to use their own personal assistive devices providing the assistive device does not jeopardize or interfere with the integrity, assets of the organization and safety of other customers, employees or equine athletes.
4 WEG Assistance Provided
4.1 WEG may offer a person with a disability other reasonable measures to assist the person in obtaining, using or benefiting from WEG’s goods and services. Where WEG provides assisted serviced they must be documented in policies, practices and procedures.
5 Support Persons
5.1 WEG ensures entry of customers with disabilities accompanied by a personal support person into WEG premises, with age restrictions in certain areas.
5.2 Where admission fees are charged, the support person will receive access free of charge.
6 Service Animals
6.1 A person with a disability may enter WEG premises accompanied by their guide dog or service animal in areas of the premises that are open to the public, unless the animal is excluded by another law or for safety considerations. If a service animal is excluded by law or for safety considerations, other measures to provide service to the person with a disability may be used.
7 Notice of Disruption in Service
7.1 WEG will make reasonable efforts to provide notice to customers, when possible, if services are unavailable.
7.2 When a disruption occurs unexpectedly, notice shall conspicuously be posted as soon as possible.
8.1 WEG will acknowledge feedback in a timely manner that takes into account the customer’s disability.
8.2 WEG will capture and track customer feedback.
9.1 All persons to whom this policy applies will receive training as required by the Accessibility Standards for Customer Service, including contractors, third parties and volunteers.
9.2 Accessible Customer Service training will be provided to all WEG employees.
9.3 Records of training will be kept by the Director, Guest Services, including the dates that training was provided and the number of individuals who received the training.
9.4 Training information will be available to customers upon request while maintaining personnel privacy considerations.
10. Availability of WEG Accessibility Plan
10.1 Public access to the annual WEG Accessibility Plan will be available in alternative formats upon request here.
11.1 Annual reporting to the Ministry. 11.2 Annual reporting to WEG’s CSR Officer.
Woodbine Entertainment Group is committed to ensuring equal access and participation for people with disabilities. We are committed to treating people with disabilities in a way that allows them to maintain their dignity and independence.
We believe in integration, and we are committed to meeting the needs of people with disabilities in a timely manner. We will do so by removing and preventing barriers to accessibility and by meeting our accessibility requirements under Ontario’s accessibility laws.
This policy establishes Woodbine Entertainment Group’s (WEG’s) commitment to meet the accessibility needs of persons with disabilities in compliance with the Integrated Accessibility Standards Regulation in the areas of Employment, Information and Communications, Transportation and Public Spaces in accordance with Ontario Regulation 191/11 (the “Regulation”).
Scope and Responsibilities
This policy has been written in accordance with the Regulation and addresses how Woodbine Entertainment Group (WEG) achieves accessibility through meeting the Regulation’s requirements. It provides the overall strategic direction that we will follow to provide accessibility supports to Ontarians with disabilities.
The requirements of the Regulation include the following four (4) items:
- Establishment, implementation, maintenance and documentation of a multi-year accessibility plan, which outlines the organization’s strategy to prevent and remove barriers and meet its requirements under the Regulation;
- Incorporation of accessibility criteria and features when procuring or acquiring goods, services, or facilities;
- Training; and
- Other specific requirements under the Information and Communications, Employment, and Public Spaces Standards.
Policy Statement and Organizational Commitment
WEG is committed to and guided by the following four (4) core principles:
- Equal Opportunity
We support the full inclusion of persons as set out in the Ontario Human Rights Code and the Accessibility for Ontarians with Disabilities Act, 2005.
WEG shall endeavor to ensure that we meet the needs of people with disabilities, in a timely manner, through the implementation of this policy.
Below is a list of fifteen (15) definitions used in this policy, listed in alphabetical order:
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 arrangement 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.
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.
Conversion Ready means an electronic or digital format that facilitates conversion into an accessible format.
IAP means Individualized Accommodation Plan.
Information includes data, facts and knowledge that exists in any format, including text, audio, digital or images, and that conveys meaning.
Internet Website means a collection of related web pages, images, videos or other digital assets that are addressed relative to a common Uniform Resource Identifier (URI) and is accessible to the public.
Maintenance of Public Spaces means activities that are intended to keep existing public spaces and elements in existing public spaces in good working order or to restore the spaces or elements to their original condition, examples of which include painting and minor repairs.
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, wheelchair, scooter or similar aid.
New Internet Website means either a website with a new domain name or a website with an existing domain name undergoing a significant refresh.
Redeployment means the reassignment of employees to other departments or jobs within the organization as an alternative to layoff, when a particular job or department has been eliminated.
Unconvertible means that it is not technically feasible to convert the information or communications. It also means that the technology to convert the information or communications is not readily available.
Web Content Accessibility Guidelines means the World Wide Web consortium recommendation, dated December 2008, entitled “Web Content Accessibility Guidelines” (WCAG) 2.0.
This section covers the general requirements of the Integrated Accessibility Standards Regulation.
Multi-Year Accessibility Plan
WEG’s Multi-Year Accessibility Plan outlines a phased-in strategy to prevent and remove barriers and addresses the current and future requirements of the Accessibility for Ontarians with Disabilities Act (AODA). WEG will review the progress and implementation of the plan, post the plan on our website and will provide it in alternative formats upon request. The plan will be reviewed and updated at least once every five years.
Procuring or Acquiring Goods, Services or Facilities
WEG will use accessibility criteria and features when procuring or acquiring goods, services or facilities, except where it is not practical to do so, in which case, if requested we will provide an explanation.
WEG will ensure that training is provided to employees on the requirements of the accessibility standards referred to in the Regulation and in the Human Rights Code as it pertains to persons with disabilities. Training will be provided as soon as practicable following the hiring of new employees, and will be refreshed for existing employees from time to time. If any changes are made to this policy, further training will be provided. We shall maintain a record of the dates when training is provided and the number of individuals to whom it was provided.
Information and Communications Standards WEG will create and provide information and communications in ways that are accessible to people with disabilities. If WEG determines that it is not technically feasible to convert the information or communications, or the technology to convert the information or communications is not readily available, we will provide the person that requires the information with an explanation as to why the information or communications are unconvertible; and a summary of the unconvertible information or communications.
If WEG prepares emergency procedures, plans or public safety information and makes the information available to the public, we shall provide the information in an accessible format or with appropriate communication supports, as soon as practicable, upon request.
WEG shall provide all feedback received with respect to its compliance with the Regulation and/or this Policy from customers to WEG’s Customer Service Department. WEG’s Customer Service Department shall respond to customer feedback and will ensure that any responses are provided in accessible formats and with communication supports upon request. We will notify the public about the availability of accessible formats and communication supports. Where feedback is received from an employee with respect to WEG’s compliance with the Regulation and/or this Policy, the employee’s supervisor will provide such feedback to WEG’s Human Resources Department, who will respond to the employee.
Accessible Formats and Communication Supports
WEG shall provide or arrange for accessible formats and communication supports for persons with disabilities in the following manner:
- Upon request in a timely manner that takes into account the persons’ accessibility needs due to a disability;
- At a cost that is no more than the regular cost charged to other persons;
- In consultation with the person making the request to determine the suitability of an accessible format or communication support;
Woodbine Entertainment Group (Woodbine) is committed to digital accessibility, and to conforming to the Web Content Accessibility Guidelines (WCAG) 2.0, Level AA and complying with the Accessibility for Ontarians with Disabilities Act (AODA) effective communication requirements, and other applicable regulations.
We want to hear from you if you encounter any accessibility barriers on our digital properties. Please contact our Customer Support at HZA@woodbine.com.
The Employment Standards of the Regulation build upon the existing requirements under the Ontario Human Rights Code in relation to how we provide accessibility throughout the entire employment cycle. It applies with respect to employees but does not apply to volunteers and other non-paid individuals.
The requirements of the Employment Standard shall be met by WEG by January 1, 2016 unless otherwise specified.
WEG shall notify employees and the public about the availability of accommodations for applicants with disabilities as listed below:
- Specify that accommodation is available for applicants with disabilities on job postings;
- If a selected applicant requests an accommodation, WEG shall consult with the applicant and provide or arrange for the provision of a suitable accommodation that takes into account the applicant’s disability;
- Notify successful applicants of the policies for accommodating employees with disabilities.
WEG 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 a disability.
WEG shall provide information required under this section to new employees as soon as practicable after they begin their employment and 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 a disability.
In addition and where an employee with a disability requests it, WEG will consult with the employee to provide or arrange for the provision of accessible formats and communication supports as listed below:
- information that is needed in order to perform the employee’s job; and
- information that is generally available to employees in the workplace.
WEG shall consult with the employee making the request in determining the suitability of an accessible format or communication support.
Individual Accommodation Plan (IAP)
An IAP shall be provided to an employee with a disability upon request. WEG will develop and document such individual accommodation plans for employees with disabilities in accordance with the following:
- The employee’s participation in the development of the IAP;
- Assessment on an individual basis;
- Identification of accommodations to be provided;
- Timelines for the provision of accommodations;
- WEG may request an evaluation by an outside medical or other expert, at our expense, to assist with determining accommodation and how to achieve accommodation;
- The employee may request the participation of a representative from their bargaining agent, where represented, or otherwise a representative from the workplace if not from a bargaining agent;
- Steps taken to protect the privacy of the employee’s personal information;
- Frequency with which the IAP will be reviewed and updated and the manner in which it will be done;
- If denied, the reasons for denial are to be provided to the employee;
- A format that takes into account the employee’s disability needs;
- If requested, any information regarding accessible formats and communication supports provided;
- Identification of any other accommodation that is to be provided.
Return to Work
WEG will develop and document a return to work process for employees who have been absent from work due to a disability and require disability-related accommodation in order to return to work. Such process shall outline the steps that WEG will take to facilitate the return to work and include an individual accommodation plan.
Performance Management, Career Development and Advancement, and Redeployment
WEG will take into account the accommodation needs and/or individual accommodation plans of employees when:
- Using performance management processes;
- Providing career development and advancement information;
- Using redeployment procedures.
Workplace Emergency Response Information
WEG shall provide individualized workplace emergency response information to employees who have a disability as per the four (4) points below:
- If the disability is such that individualized information is necessary and WEG is aware of the need for accommodation due to the employee’s disability;
- If the employee who receives individual workplace emergency response information requires assistance and with the employee’s consent, WEG shall provide the workplace emergency information to the person designated by WEG to provide assistance to the employee;
- As soon as practicable after becoming aware of the need for accommodation due to the employee’s disability;
- Review the individualized workplace emergency response information when the employee moves to a different location in the company, when overall accommodations needs or plans are reviewed and when WEG reviews its general emergency response policies.
Public Spaces Standards:
WEG will incorporate accessibility into public spaces that are newly constructed or redeveloped on and after January 1, 2017. WEG will follow the existing requirements stated under the Design of Public Spaces Standards (Accessibility Standards for the Built Environment). WEG will provide maintenance and restoration of public spaces, where applicable, and notify the public of temporary disruptions and alternatives available.
Policies & Procedures
|Create Policies with Statement of Organizational Commitment in written form||Completed|
|Approval and Sign off||Completed|
|Make available to the Public||Completed|
|Available in Alternative Formats – upon request||Completed|
Accessibility Plan – Multi Year
|Develop Accessibility Plan||Completed|
|Accessibility Plan – Post to website||Completed|
|Continue to work on Accessibility Plan, review progress and update. Update regularly and every five years.||Ongoing|
|Provide in alternative format upon request||Completed|
|Accessibility Self Service Kiosk – have regard for accessibility when purchasing||Completed and ongoing|
|Training delivery||Online & in person where applicable|
|Training schedule for current staff and new staff||Annually|
|Ensure training attendance electronically recorded||Yes|
|Training completed||All annual training completed to date|
|Continue to train new staff as part of orientation||Ongoing|
Information & Communications
|Feedback – ensure feedback system accessible via Customer Service||Completed|
|Accessible formats and communication supports upon request||Completed|
|If creating a new Website WCAG 2.0 Level AA (other than closed caption live pre-recorded audio)||Completed and ongoing|
|All internet websites and web content WCAG 2.0 Level AA by 2021||Completed|
|Review all content on website back to 2012 to ensure everything is accessible by 2021||Completed|
|Provide individual Workplace Emergency Response for staff, if needed||Completed and ongoing|
|Recruitment – notify employees and public regarding availability of accommodation, if requested||Completed and ongoing|
|Notify applicants of availability of accommodation upon request for assessments or selection process||Completed and ongoing|
|Inform employees of policies regarding job accommodations||Completed and ongoing|
|Providing accessible formats and communication supports available to perform job||Completed and ongoing|
|Have a Documented Individual Accommodation Plan (IAP), if needed||Completed and ongoing|
|Have a Return to Work Process, if needed||Completed and ongoing|
|Performance Management takes into account accessibility needs||Completed and ongoing|
|Career Development and Advancement Process takes into account accessibility needs||Completed and ongoing|
|Redeployment process takes into account accessibility needs||Completed and ongoing|
|Continue to proactively remove barriers across employment life cycle allowing employees to reach their full potential||Ongoing|
|Incorporate Design of Public Spaces on newly developed or redeveloped outdoor public use eating areas, exterior paths of travel, accessible parking and service related elements||Completed and ongoing|
|Provide maintenance and restoration||Ongoing|
|Develop procedures for preventative and emergency maintenance of accessible elements in public spaces||Completed|
|Develop procedures for dealing with temporary disruptions when accessible elements under public spaces not working||Completed|
|Report on Public Spaces every three years||Ongoing|