Accessibility and Accommodation Policy
1. Statement of Commitment
The Human Rights Legal Support Centre (“HRLSC”) is committed to creating, safeguarding and delivering a barrier-free environment for all stakeholders including staff, board members, clients, job seekers, students, visitors or any third party that may enter our premises, access our information or use our services. Our goal is to make the HRLSC barrier-free by being proactive in having our services, policies and procedures, including all HRLSC services and facilities, fully accessible to meet the needs of people with disabilities.
The HRLSC is committed to providing its services in a manner that accommodates a person’s disability related needs and provides its services in a way that is respectful and dignified. The HRLSC values and respects all clients and is committed to providing its services in a way that supports accessibility, diversity and the equitable treatment of all clients and client groups.
The HRLSC is further committed to complying with the spirit, intent and provisions of the Human Rights Code (“Code”), the Ontarians with Disabilities Act, 2001 (ODA, 2001) and the Accessibility for Ontarians with Disabilities Act, 2005 (AODA, 2005). You can also find the HRLSC’s anti-ableism commitment here: Anti-Ableism: Statement of Commitment.
The AODA, 2005 aims to identify, remove and prevent barriers for people with disabilities. Based on the four principles of Dignity, Independence, Integration, and Equality of Opportunity. The AODA 2005 lays the framework for the development of province-wide mandatory standards on accessibility in all areas of daily life. It is comprised of various accessibility standards and general requirements that all public and private sector organizations must meet.
This policy will ensure that all people, including people with disabilities, using the services of the HRLSC have equal access to and obtain the equal benefit of its services. This policy applies to accessible services and supports to persons with disabilities. The HRLSC’s Human Resources office will be responsible for the administration and communication of this policy
This policy shall apply to every employee, management personnel, board members, clients, job seekers, students, volunteers, visitors or any third party that may enter our premises, access our information or use our services at the HRLSC.
4. Information and communication standards
The HRLSC will communicate with people with disabilities in ways that consider their disability. When asked, we will provide information about our organization and its services, including public safety information, in accessible formats or with communication supports.
For an alternative format or a paper copy of this policy, please contact the HRLSC at our toll-free phone number: 1-866-625-5179, Local: 416-597-4900, TTY Toll Free: 1-866-612-8627, or TTY Local: 416-597-4903.
Accessible Websites and Web Content
The HRLSC will ensure that our Internet websites, including web content, conform to the internationally recognized World Wide Web Content Accessibility Guidelines (WCAG) 2.0 at Level AA website requirements in accordance with Ontario’s accessibility laws, except where this is impracticable.
The HRLSC strives to meet and exceed client expectations while serving clients with disabilities. Comments on our services regarding how well those expectations are being met are welcome and appreciated.
Clients who have requested accommodation may be asked to fill out an evaluation form about the services at the HRLSC so that you can tell us how we are doing at meeting accommodation needs.
If you would to like to provide us with feedback about our accessibility or accommodations, please complete this survey.
5. Accommodation of persons requesting services
Under the Code, the HRLSC is committed to preventing and removing barriers and providing reasonable accommodation to the point of undue hardship to persons seeking to access its services. Accommodation issues and requests may arise in many different contexts, including requests based on creed, family status, sex (e.g., pregnancy), disability and/or age.
At the HRLSC most requests for accommodation arise in the context of disability. However, whatever the accommodation request made, the HRLSC is committed to providing an effective and respectful process to those seeking accommodation in the provision of our services.
The HRLSC supports the full inclusion of all persons. The HRLSC wants to ensure that our services are as barrier-free as possible and are provided in a manner that respects the dignity and independence of people with disabilities. Please note that the HRLSC, due to its Ontario wide mandate and its limited resources, generally provides its legal support services to Ontarians by a phone intake and phone interviews.
When you contact us. please tell our staff the details of your accommodation request. Our number is 416-597-4900 or Toll Free at 1-866-625-5179.
7. Requesting accommodation if unable to communicate by telephone
If you are unable to communicate by telephone because of a Code protected reason, such as a disability, please e-mail us your request at accommodation@HRLSC.on.ca.
In the email, please clearly state that you are making a request for accommodation and explain why you are unable to use the HRLCS’s telephone intake service. An HRLSC representative will respond to your request for accommodation. It is important to understand that reasonable accommodation will be provided in accordance with your disability-related needs and not merely based on your preferences.
Alternatively, if e-mail is not an option or otherwise unavailable to you, you may request accommodation by any one of the following ways:
TTY 416-597-4903 (toll free 1-866-612-8627);
Mail to 180 Dundas Street West, 8th Floor Toronto (Ontario) M7A 0A1; or
Fax to 416-597-4901.
If your question is about something other than accommodation and our services, please contact the HRLSC’s main telephone line at 416-597-4900 or 1-866-625-5179.
8. Responding to accommodation requests
All requests for accommodation will be considered and evaluated on a case by case basis, as every situation is unique. In many cases, the accommodation request is relatively simple and there is no issue in granting the request for accommodation. Other accommodation requests, however, may be more complicated.
Not every request for accommodation at the HRLSC may be granted simply on the basis that a request has been made. This is because the accommodation requested must be in accordance with your actual disability related needs. In some cases, the HRLSC may need to make inquiries as to the nature and extent of your disability related restrictions in order to properly respond to your request. This may include a request for medical information to support your request for accommodation.
You may be asked, depending on the specific circumstances of your accommodation request, to provide some information about your disability related needs. Each person’s needs are individual, and each accommodation request is a unique process. The HRLSC will respond to each request for accommodation in a way that is respectful and treats everyone as valued and with dignity.
The principles of accommodation do not mean that every request for accommodation made to the HRLSC must be agreed to or provided by the HRLSC. Accommodation means making sure that a person receives the full benefit of our services by providing the services in a way that ensures equal opportunity to access and benefit from our services, depending on that person’s disability related needs.
In addition, in some very rare cases, the accommodation requested may not be able to be provided by the HRLSC because it creates extreme financial costs or significant health and safety risks. This is known as “undue hardship” under the Code.
9. Providing support services to clients
The HRLSC is committed to excellence in serving all clients, including people with disabilities and we will carry out or functions and responsibilities in the following ways:
The HRLSC will communicate with people with disabilities in ways that consider their disability. Accommodations may include, depending on your circumstances, communicating in ways that take your specific needs into account. The HRLSC staff speak in clear and plain language over the phone.
The HRLSC may provide you with an interpreter (including ASL and LSQ sign language interpreters) or may offer to communicate in other ways, including by e-mail, TTY and relay services.
The HRLSC is committed to serving people with disabilities who use assistive devices to obtain, use or benefit from our services. The HRLSC’s facilities are accessible to people with disabilities. Accommodations may include, depending on the circumstances, making sure the physical space is wheelchair accessible or enable the use of other mobility devices and aids.
The HRLSC is committed to provide access to documents to people with disabilities in ways that consider their disability. Documents created by the HRLSC are available, upon request, in alternative formats.
For example, if you have a vision impairment the HRLSC may provide you with the documents in an alternative format, such as Braille, to accommodate your disability related needs.
The HRLSC 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. A service animal can be easily identified through visual indicators, such as when it wears a harness or a vest, or when it helps the person perform certain tasks.
If service animals are prohibited by another law the HRLSC will, in order to ensure people with disabilities can access our services or facilities, explain why the animal is excluded and discuss with the client another way of providing services or facilities
The HRLSC is committed to welcoming people with disabilities who are accompanied by a support person. A person with a disability who is accompanied by a support person will be allowed to have that person accompany them on our premises. The HRLSC will notify clients about support persons by posting a notice on our website www.hrlsc.on.ca and posting in the HRLSC front lobby in the reception area.
In some cases, the HRLSC may require a person with a disability to be accompanied by a support person for the health or safety reasons of the person with a disability and/or other people on the HRLSC premises.
The HRLSC will, before deciding that a person with a disability ought to be accompanied by a support person, consult with the person with a disability to understand their needs, consider relevant health or safety factors based on the available evidence and determine if there is no other reasonable way to protect the health or safety of the person with a disability or other people on the premises.
10.Notice of temporary disruption
In the event of a planned or unexpected disruption to services or facilities for clients, including clients with disabilities, the HRLSC will notify the public promptly. The HRLSC’s services and facilities include accessing our intake phone line, walk-in clients using the HRLSC to access our intake phone line, clients coming into the HRLSC to drop off or pick up documents and clients meeting with HRLSC staff.
A clearly posted notice will include information about the reason for the disruption, its anticipated length of time, and a description of alternative facilities or services, if available.
The notice will be made publicly available on our website at www.hrlsc.on.ca and will be posted in our front lobby at the HRLSC reception area.
The HRLSC is committed to provide a scent free environment. Please do not wear perfume, after-shave or any other chemically scented product if you are attending at our office or meeting with HRLSC staff in person.
The HRLSC will ensure that all staff receive training as required by applicable legislation. This training will be provided as soon as practicable following a new employee commencing employment with the HRLSC. HRLSC staff will also be trained on an ongoing basis when changes are made to any policies, practices and procedures about accessibility and accommodation and the provision of HRLSC services..
Training of HRLSC staff will include the following:
- the purposes of applicable laws, including the AODA, 2005 and the requirements of the service standards;
- how to interact and communicate with people with various types of disabilities;
- how to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person;
- what to do if a person with a disability is having difficulty in accessing the HRLSC’s services; and
- training on policies, practices and procedures that affect the way the HRLSC’s services are provided to people with disabilities.
13.Accessibility and Procurement
The HRLSC’s procurement practices include flexibility and openness. The HRLSC will incorporate accessibility criteria and features when procuring or acquiring goods, services or facilities.
If it is not possible and practical to do so in the circumstances, the HRLSC will provide an explanation upon request.
The HRLSC shall:
maintain and comply with its Accessibility & Accommodation Policy.
ensure that the Accessibility & Accommodation Policy and the Anti-Ableism Statement of Commitment are available to the public on our website.
include the Accessibility & Accommodation Policy and the Anti-Ableism Statement of Commitment in orientation materials for all new staff and board members.
provide staff training on issues relating to access, accommodation, and ableism.
provide clients the opportunity to provide feedback on how the HRLSC responded to and/or accommodated their disability related needs;
review any client feedback on anti-ableist service delivery and on accommodation of disability;
conduct a survey of staff that includes the opportunity to comment on accommodation of disability-related needs in the workplace, and on compliance with this policy; and
resolve any complaints in accordance with the HRLSC’s policies for dealing with public complaints and internal complaints.
15. Employment standards
The HRLSC will notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment process.
Recruitment, Assessment or Selection Process
The HRLSC will notify job applicants, when they are individually selected to participate further in an assessment or selection process that accommodations are available upon request in relation to the materials or processes to be used.
If a selected applicant requests an accommodation, the HRLSC will consult with the applicant and provide, or arrange for the provision of, a suitable accommodation in a manner that considers the applicant’s accessibility needs due to disability.
Notice to Successful Applicants
When making offers of employment, the HRLSC will notify the successful applicant of its policies for accommodating employees with disabilities, upon request.
Informing Employees of Supports
The HRLSC will continue to inform its employees of its policies (and any updates to those policies) used to support employees with disabilities, including policies on the provision of job accommodations that consider an employee’s accessibility needs due to disability.
This information will be provided to new employees as soon as practicable after commencing employment.
Accessible Formats and Communication Supports for Employees
Upon the request of an employee with a disability, the HRLSC will consult with the employee to provide, or arrange for the provision of, accessible formats and communication supports for information that is needed to perform the job, and information that is generally available to other employees.
In determining the suitability of an accessible format or communication support, the HRLSC will consult with the employee making the request.
Workplace Emergency Response Information
The HRLSC will provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary, and if the HRLSC is aware of the need for accommodation due to the employee’s disability. The HRLSC will provide this information as soon as practicable after becoming aware of the need for accommodation.
Where the employee requires assistance, the HRLSC will, with the consent of the employee, provide the workplace emergency response information to the person designated by the HRLSC to help the employee.
The HRLSC will review the individualized workplace emergency response information if the employee moves to a different location in the organization, when the employee’s overall accommodation needs, or plans are reviewed.
Documented Individual Accommodation Plans
The HRLSC will maintain a written process for the development of documented individual accommodation plans for employees with disabilities.
If requested, information regarding accessible formats and communications supports provided will also be included in individual accommodation plans.
In addition, the plans will include individualized workplace emergency response information (where required) and will identify any other accommodation that is to be provided.
Return to Work Process
The HRLSC maintains a documented return to work process for its employees who have been absent from work due to a disability and who require disability-related accommodations in order to return to work.
The return to work process outlines the steps the HRLSC will take to facilitate the return to work and will include documented individual accommodation plans as part of the process.
This return to work process will not replace or override any other return to work process created by or under any other statute (i.e., the Workplace Safety Insurance Act, 1997).
Performance Management, Career Development and Advancement & Redeployment
The HRLSC will consider the accessibility needs of employees with disabilities, as well as individual accommodation plans, when conducting performance management, providing career development and advancement to employees, or when redeploying employees.
16. Design of public space
The HRLSC is physically accessible to all persons that may enter our building and office suite. The HRLSC will meet accessibility laws when building or making major changes to its public spaces.
The HRLSC will put procedures in place to prevent service disruptions to the accessible parts of our public spaces.
17. Periodic review
We welcome your suggestions to improve this policy.