AODA Policy

POLICY ON 

ACCESSIBILITY STANDARD FOR CUSTOMER SERVICE 

ACCESSIBILITY FOR ONTARIANS WITH DISABILITES ACT (AODA)

1. Purpose and Background Information

The Accessibility for Ontarians with Disabilities Act, 2005 (AODA) is a Provincial Act with the purpose of developing, implementing and mandating accessibility standards in order to achieve 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” (the Regulation), came into force on January 1, 2008.  The Regulation 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.

The objectives of this policy is to identify what the equal treatment provisions of the Ontario Human Rights Code, through the AODA and the Regulation, require as a minimum legal standard in program design and service delivery to persons with disabilities and addresses the following:

• The provision of goods and services to persons with disabilities
• The use of service animals by persons with disabilities
• The use of assistive devices by persons with disabilities
• The use of support persons by persons with disabilities
• Notice of temporary disruptions in services and facilities
• Notice of temporary disruptions in services and facilities
• Employment
• Staff training
• Information and communication for persons with disabilities
• Receiving and responding to feedback from our customers, employees, and members of the public who have a disability accessible when asked.
• Notice of availability and format of documents and meetings
• The development of multi-year accessibility plan which is maintained on an ongoing basis
• Where to ask questions about this policy

2. Scope

This policy applies to all NAVBLUE Inc. employees, volunteers, visitors and others who deal with the public or other third parties on their behalf.

3. Our Commitment

NAVBLUE strives at all times to provide its goods and services in a way that respects the dignity and independence of people with disabilities.  NAVBLUE is committed to giving people with disabilities the same opportunity to access the Company’s goods and services and allowing them to benefit from the same services, in the same place and in a similar way as other people.

NAVBLUE is committed to providing a working environment that promotes dignity, independence, integration, and equality of opportunity.

4. Policy Objectives

• To ensure that the goods and services provided by NAVBLUE are accessible to people with disabilities.
• To ensure that all NAVBLUE staff are aware of disabilities and interact with people with disabilities in a manner that ensures dignity, independence, integration, and equality of opportunity.
• To establish a mechanism for receiving and responding to feedback in a manner that is accessible to people with disabilities.
• To provide training to all NAVBLUE employees in how to interact with assistive devices, guide dogs, service animals, and support persons in an appropriate manner, as per the AODA.
• To ensure accessibility to information and communication via accessible formats and communication supports
• To ensure that accessibility is a regular part of finding, hiring and supporting employees with disabilities

5. Providing Goods and Services to Persons with Disabilities

NAVBLUE is committed to excellence in serving all customers including persons with disabilities and will carry out its functions and responsibilities to ensure that policies, practices and procedures are consistent with the following principles:

• NAVBLUE’s goods and services are provided in a manner that respects the dignity and independence of persons with disabilities;
• Persons with disabilities are given an opportunity equal to that of persons without disabilities to obtain use or benefit from NAVBLUE’s goods and services, and
• To ensure the best possible customer service, NAVBLUE encourages open two-way communication and expects persons with disabilities to communicate their need for accommodation or assistance if it is not readily apparent how that need can be met.

6. Use of Service Animals, Assistive Devices, and Support Persons

NAVBLUE will ensure that the access, use and benefit of goods or services are not compromised for persons with disabilities who require assistive devices, or who are accompanied by a service animal, guide dog or support person.

Service animals

• Service animals, such as, but not limited to Guide dogs, Hearing dogs, Seizure Response dogs, and other certified service animals shall be permitted entry to all NAVBLUE facilities and meeting rooms
• In the rare case where a service animal is to be denied access to a facility or meeting room, other accommodations may be afforded, such as: Alternate meeting format, e.g. teleconference where technology permits; delivery of goods or service at an alternate time or location; other assistive measures available to deliver a good or service to ensure equality of outcome.

7. Assistive Devices

Persons with disabilities shall be permitted to obtain, use or benefit from goods or services through the use of their own assistive devices.  Exceptions may occur in situations where NAVBLUE 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, NAVBLUE will accommodate the customer by providing an alternative where possible.

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

NAVBLUE will ensure that staff are trained as required to use assistive devices available on our premises, including, but not limited to computers and software, electronic recorders and other devices that may become available.

8. Support Persons

NAVBLUE is committed to welcoming customers with disabilities who are accompanied by a support person.  Any person with a disability who is accompanied by a support person will be allowed to enter NAVBLUE’s 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 NAVBLUE’s premises.

NAVBLUE holds conferences, events, and workshops sponsored by NAVBLUE or by third parties, that are outside of the regular office.  For such events, support persons shall be permitted entry to all NAVBLUE facilities and meeting rooms that are open to the public, except: when there are fees applied against participants by a third party and the support person was not pre-registered and/or no vacancy exists.  If admission to an event is permitted and fees are payable to a third party, the support person is permitted to attend the event at their own cost.  Cost for services (e.g. food, lodging etc.) will be the responsibility of the support person.

If admission to an event is permitted and fees are payable to NAVBLUE, the support person is permitted to attend at no cost for admission.  Cost for other services (e.g. food, lodging, etc.) will be the responsibility of the support person.

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, NAVBLUE will require the accompaniment of a support person on NAVBLUE premises.

The customer shall determine whether a support person is necessary, however, where an employee believes that a support person should be in attendance to protect the health and safety of the customer or others, the following criteria shall 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 (the mere possibility of risk is insufficient);
• 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 severity of the potential harm, the likelihood that the potential harm will occur, and the imminence of the potential harm; and
• When the assessment of the risk is based on the individual’s actual characteristics, not merely on generalizations, misperceptions, ignorance or fears about a disability.

Customers are required to provide their own support person(s).  Customers are expected to inform NAVBLUE that they will be on premises with a support person.

9. Billing

NAVBLUE is committed to providing accessible invoices to all of our customers in Ontario and will make every effort to provide alternative formats of invoices in a timely manner upon request. We will answer any questions customers may have about the content of the invoice in person, by telephone or email.

10. Notice of Temporary Disruption to Facilities or Services

In the event that a planned, temporary service disruption occurs that would limit a person with disabilities from gaining access to NAVBLUE facilities, goods, or services, NAVBLUE will make the disruption known to customers in the following ways:

• The Accelerator Centre property management company will post notice of the service disruption on company premises in the area where the service disruption is located.
• Notices of service disruption will be announced on NAVBLUE’s email systems.

Notices will include information about the reason for the disruption, its anticipated duration, alternate service locations if applicable, and a description of alternative facilities or services if available.

If an unexpected disruption occurs, persons with disabilities will be accommodated by the use of other possible means, such as:

• NAVBLUE may use an alternative place and time to provide the goods or service directly to the person with a disability.
• Any other appropriate assistive measures available to deliver goods and services or accommodate an employee with a disability.

11. Employment

NAVBLUE will ensure that accessibility is a regular part of finding, hiring and supporting employees with disabilities.  To that end, NAVBLUE is committed to:

• Informing job applicants that recruitment and hiring processes will be modified to accommodate their disabilities, if requested.
• Consulting with applicants and making adjustments to the selection process that best suit the applicant’s needs, when requested.
• Supporting employees with disabilities by:
• Developing and documenting individual accommodation plans for employees with disabilities
• Creating and maintaining written processes for developing and documenting individual accommodation plans for employees with disabilities.
• Helping employees with disabilities return to work
• Taking accessibility needs of our employees into consideration with regards to performance management and career development opportunities
• Helping employees stay safe in emergencies by providing them with individualized emergency response information when necessary.
• Informing employees about policies for supporting employees with disabilities when these policies come into effect in or organization, whenever new employees are hired, and whenever accessibility policies are changed.

12. Staff Training

NAVBLUE will provide training to all Ontario based staff, and all those who are involved in the development and approval of policies practices and procedures on the Accessibility for Ontarians with Disabilities Act Customer Service standards and Integrated Accessibility Standards Regulation.

This training will be provided as a condition of employment to all new staff and on an ongoing basis for staff to ensure all staff stay current with any policy or procedural changes as it relates to the AODA Standards.  Training is provided through Human Resources.

Training will be made available in accessible formats and in multiple formats, including, but not limited to, face to face instruction, procedural documentation and electronic versions of the training module.

The training will include:

• The purposes of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard.
• 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 support person.
• How to use the assistive devices available on the premises that may assist with the provision of goods or services to people with disabilities, which include, but are not limited to, computers and software, electronic recorders, and other devices that may become available.
• What to do if a person with a disability is having difficulty accessing goods and services at NAVBLUE
• Current policies, practices and procedures relating to the customer service standard.
• NAVBLUE’s obligations under the Ontario Human Rights Code (related to disabilities)
• NAVBLUE’s accessibility plan to ensure compliance with Ontario’s accessibility laws and prevent and remove accessibility barriers

13. Information & Communication

NAVBLUE is committed to providing information and goods and services to persons with disabilities in ways that take into consideration their disability.  To ensure this:

• NAVBLUE staff will be trained in how to interact and communicate with people with disabilities and how to provide NAVBLUE’s goods and services to customers with disabilities guided by the principles of dignity, independence, and equality;
• Upon request, people with disabilities will be offered alternative communication formats that will meet the needs of the customer as promptly as feasible;
• Documents will be provided to employees and customers in an alternative format that will meet the needs of the individual in a timely fashion; and,
• If telephone communication is not suitable for a person’s needs, alternative forms of communication will be offered as required.

14. Feedback Process

The ultimate goal of NAVBLUE is to meet the needs of our customers, while paying attention to the unique requirements of our customers with disabilities.  Comments on our services regarding how well those expectations are being met are welcomed and appreciated.

Feedback regarding the way NAVBLUE provides goods and services to people with disabilities can be made via email at hr@navblue.aero or in person, by telephone.

Feedback will be used to improve customer service.  In addition, the author of the feedback will be provided with a response in the format in which the feedback was received.  The feedback may outline actions deemed appropriate, if any.

15. Format of Policies

NAVBLUE develops and updates policies, procedures and practices in such a manner as to respect and promote the dignity and independence of people with disabilities, as well as integration and equality of opportunity.  NAVBLUE will provide policy and procedure documents produced by the company in an alternative format upon request, within a reasonable amount of time.  Any policy of NAVBLUE that does not respect and promote the dignity and independence of people with disabilities will be modified or removed.

16. Design of Public Spaces

NAVBLUE will meet the Accessibility Standards for the Design of Public Spaces when building or making major modifications to public spaces. Public spaces include parking and meeting rooms.

17. Questions about this Policy

If anyone has questions about the policy, or if the purpose of the policy is not understood, an explanation should be provided by or referred to Human Resources at hr@navblue.aero.