Accessibility Standards Policy — full text

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1 of 26 POL-82 Accessibility Standards Policy Policy # POL-82 Effective Date September 18, 2024. Status Approved. Final Approver Council. 1.0 Interpretation 1.1 In this policy, unless the context requires otherwise: "AODA" means the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11; "career development and advancement" has the meaning given to it in the IASR; "City" means The Corporation of the City of Kingston; "City employee" means a person who performs work or supplies services directly to the City for monetary compensation under an employment contract but does not include council members; "CMT member" means a member of the City's corporate management team and includes the person appointed chief administrative officer by the City, the person appointed treasurer by the City, and a commissioner responsible for the leadership and operation of a portfolio of City departments; "communication" has the meaning given to it in the IASR; "Deputy City Clerk" means the person appointed as deputy city clerk by the City; "director" means the director of a City department; "disability" has the meaning given to it in the AODA; "FADS" means facility accessibility design standards which establish City-wide standards that build a universally designed and accessible community for residents, visitors and City employees; "guide dog" has the meaning given to it in the Blind Persons' Rights Act, R.S.O. 1990, c. B. 7; "Human Rights Code" means the Human Rights Code, R.S.O. 1990, c. H.19; 2 of 26 "IASR" means Ontario Regulation 191/11: Integrated Accessibility Standards, made under the AODA; "information" has the meaning given to it in the IASR; "kiosk" has the meaning given to it in the IASR; "MAAC" means the Municipal Accessibility Advisory Committee, the City's accessibility advisory committee established in accordance with subsection 29 (1) of the AODA; "manager" means a City employee who reports directly to a director; "performance management" has the meaning given to it in the IASR; "service animal" has the meaning given to it in the IASR; "specialized transportation services" has the meaning given to it in the IASR; "supervisor" means a City employee who reports directly to a manager; "support person" has the meaning given to it in the IASR; "transit bus" has the meaning given to it in the IASR; and "transit service" means the City's public passenger transportation service on transit buses; 1.2 In this policy, "include", "includes" and "including" indicate that the subsequent list is not exhaustive. 1.3 A reference to any legislation, regulation, by-law, rule, policy or provision thereof includes a reference to any legislation, regulation, by-law, rule or provision thereof enacted in substitution thereof or amendment thereof. 1.4 A reference to legislation includes all of the regulations made thereunder. 1.5 A reference to the position or title of any City employee includes a reference to any position or title created in substitution thereof. 2.0 Purpose 2.1 The purpose of this policy is to: (a) recognize the history of discrimination against persons with disabilities in Ontario; 3 of 26 (b) assist the City to achieve accessibility for persons with disabilities with respect to goods, services, facilities, accommodations, employment, buildings, structures and premises as required by the AODA; (c) make a statement of organizational commitment to meet the accessibility needs of persons with disabilities in timely manner; (d) recognize that achieving the purposes set out in clauses (a), (b) and (c) and working to the highest level of inclusion is to the benefit of all members of the community; and (e) be consistent with and complement the City's Accessible Consultation Process Policy. 3.0 Statutory Requirements - General 3.1 The City, as an organization, is committed to meet the accessibility needs of persons with disabilities in a timely manner. 3.2 The City must, in accordance with the AODA: (a) develop, implement and maintain policies governing how the City achieves, or will achieve, accessibility through meeting its requirements referred to in the IASR; (b) prepare one or more documents describing its policies developed under subsection 3.2 (a). 3.3 The Deputy City Clerk must make this policy, the City's Accessible Consultation Process Policy, and any other documents described in clause 3.2 (b), publicly available, and upon request, provide them in an accessible format. 3.4 Directors must take reasonable steps within their authority to ensure that the City complies with its obligations under section 3.2. 3.5 The director of Financial Services must ensure that the City: (a) incorporates accessibility features when designing, procuring or acquiring self-service kiosks; and (b) has regard to the accessibility for persons with disabilities when designing, procuring or acquiring self-service kiosks. 3.6 The director of Human Resources & Organization Development must ensure: 4 of 26 (a) that the City, as soon as practicable, provides training on the requirements of the accessibility standards referred to in the IASR and the Human Rights Code as it pertains to persons with disabilities to: (i) all City employees and persons who volunteer with the City; (ii) all persons who participate in developing City policies; and (iii) all other persons who provide goods, services or facilities on behalf of the City. (b) the training referred to in clause (a) is appropriate to the duties of the person receiving the training; and (c) the City provides training in respect of any changes to this policy, the City's Accessible Consultation Process Policy, or any other policies described in clause 3.2 (a) on an ongoing basis. 3.7 The City must keep a record of training provided under section 3.66, including the dates on which the training is provided and the number of persons to whom it is provided. 4.0 Information and Communications Standard 4.1 The director of Communications & Customer Experience must ensure that: (a) the City's processes for receiving and responding to feedback are accessible to persons with disabilities by providing or arranging for the provision of accessible formats and communications supports, upon request; (b) the City notifies the public about the availability of accessible formats and communications supports with respect to the feedback process; (c) the City, upon request, provides or arranges for the provision of accessible formats and communication supports for persons with disabilities in a manner that takes into account the person's needs due to disability and at a cost that is no more than the regular cost charged to other persons. 4.2 The Chief Information Officer must ensure that the City makes its internet and intranet websites and web content conform with the World Wide Web Consortium Content Accessibility Guidelines (WCAG) 2.0 level AA. 4.3 The manager of Administration and Emergency Preparedness must ensure that if the City makes an emergency procedure, plan or public safety information available 5 of 26 to the public, it provides the information in an accessible format or with appropriate communications support, as soon as practicable, upon request. 5.0 Employment Standards 5.1 The director of Human Resources & Organization Development must ensure that the City: (a) notifies City employees and the public about the availability of accommodation for applicants with disabilities in its recruitment processes; (b) during a recruitment process: (i) notifies job applicants, when they are individually selected to participate in an assessment or selection process, that accommodations are available, upon request, in relation to the materials or processes to be used in the selection process; and (ii) if a selected applicant requests an accommodation, the City consults with the applicant and provides a suitable accommodation in a manner that takes into account the applicant's needs due to disability; (c) when making offers of employment, notifies the successful applicant of the City's policies for accommodating City employees with disabilities; (d) informs City employees of its policies used to support City employees with disabilities, including policies on the provision of job accommodations that take into account a City employee's accessibility needs due to disability; (e) provides the information required under clause (d) to new City employees as soon as practicable after they begin their employment; (f) provides updated information to City employees whenever there is a change to existing policies on the provisions of job accommodations that take into account a City employee's accessibility needs due to disability; (g) upon request from a City employee with a disability, consults with the City employee to provide or arrange for the provision of accessible formats and communications supports for: (i) information that is needed in order to perform the City employees job; and (i) information that is needed in order to perform the City employees job; and (ii) information that is generally available to City employees in the workplace; 6 of 26 (h) upon request from a City employee with a disability, consults with the City employee making the request to determine the suitability of an accessible format or communication support; (i) provides, as soon as practicable after the City becomes aware of the need for accommodation due to the City employee's disability, individualized workplace emergency response information to City employees, if the disability is such that the individualized information is necessary and the City is aware of the need for accommodation due to the City employee's disability; (j) reviews the individualized workplace emergency response information when: (i) the City employee moves to a different location in the organization; (ii) the City employee's overall accommodations needs or plans are reviewed; and (iii) the City reviews its general emergency response policies; (k) develops and has in place a written process for the development of individual accommodation plans for City employees with disabilities that complies with the requirements of subsection 28 (2) of the IASR; (l) develops and has in place a return to work process for City employees that have been absent from work due to disability and requires disability-related accommodations in order to return to work, and documents the process; (m) the City's return to work process outlines the steps the City will take to facilitate the return to work of City employees who were absent because their disability required them to be away from work and uses a documented individual accommodation plan, as described in clause (k), as part of the process; (n) in its performance management and career development and advancement processes, takes into account the accessibility needs of City employees with disabilities, as well as any individual accommodation plans, when using those processes in respect of City employees with disabilities. 6.0 Transportation Standards 6.1 The director of Transportation & Transit Services must ensure that the City's transit service: 7 of 26 (a) makes available to the public current information on accessibility equipment and features of its vehicles, routes and services; (b) upon request, provides the information referred to in clause (a) in an accessible format; (c) if the accessibility equipment on a transit bus is not functioning and equivalent service cannot be provided, takes reasonable steps to accommodate persons with disabilities who would otherwise use the equipment and repairs the equipment as soon as is practicable; (d) conducts City employee and volunteer accessibility training which includes training on: (i) the safe use of accessibility equipment and features; (ii) acceptable modifications to procedures in situations where temporary barriers exist or accessibility equipment on a transit bus fails; and (iii) emergency preparedness and response procedures that provide for the safety of persons with disabilities; (e) keeps a record of the training provided under clause (d), including the dates on which the training is provided and the number of individuals to whom it is provided; (f) establishes, implements, maintains and documents emergency preparedness and response policies that provide for the safety of persons with disabilities, makes those policies available to the public, and, upon request, provides those policies in an accessible format; (g) does not charge a fare to a support person who is accompanying a person with a disability where the person with a disability has a need for a support person, provided that the person with a disability demonstrates their need for a support person to accompany them and ensures that the appropriate designation for the support person is in place; (h) develops and identifies, in the City's accessibility plan: (i) the process for managing, evaluating and taking action on customer feedback; (ii) the process for estimating the demand for specialized transportation services; and 8 of 26 (iii) steps to reduce wait times for specialized transportation services; and (iv) a description of the transit service's procedures for dealing with accessibility equipment failures on its transit buses; (i) deploys lifting devices, ramps or portable bridge plates upon the request of a person with a disability; (j) provides adequate time to persons with disabilities to safely board, be secured and deboard transit buses and provides assistance, upon request, for these activities; (k) assists with safe and careful storage of mobility aids or mobility assistive devices used by persons with disabilities; (l) allows a person with a disability to travel with a medical aid; (m) upon request, makes the information on the matters referred to in clauses (i), (j), (k) and (l) available in an accessible format; (n) does not charge a higher fare to a person with a disability than the fare that is charged to a person without a disability; (o) makes persons with disabilities able to board or deboard a transit bus at the closest available safe location, as determined by the operator after considering the preferences of the person with a disability, that is not an official stop, if the stop is not accessible and the safe location is along the same transit route; (p) requires transit bus operators to promptly report to a supervisor where a transit stop is temporarily inaccessible or where a temporary barrier exists; (q) if safe storage is possible, store mobility aids and mobility assistive devices in the passenger compartments of its transit buses within reach of the person with the disability who uses the aid or device; (r) does not charge a fee for the storage of a mobility aid or mobility assistive device; (s) clearly marks priority seating for persons with disabilities on its transit buses and ensures that the priority seating meets the following standards: (i) the priority seating for persons with disabilities must be located as close as practicable to the entrance door of the transit bus; 9 of 26 (ii) the priority seating must be signed to indicate that passengers, other than persons with disabilities, must vacate the priority seating if its use is required by a person with a disability; (t) develops a communication strategy designed to inform the public about the purpose of priority seating; (u) where a route or scheduled service is temporarily changed and the change is known in advance of the commencement of the trip: (i) makes available alternate accessible arrangements to transfer persons with disabilities to their route destination where alternate arrangements for persons without disabilities are inaccessible; and (ii) communicate information on alternate arrangements in a manner that takes into account the person's disability; (v) on request, has electronic pre-boarding announcements of the route, direction, destination or next major stop on its transit buses that satisfy the requirements set out in section 58 of the IASR; (w) has audible verbal announcements of all destination points or available route stops on its transit buses while the transit bus is on route or while the transit bus is being operated; (x) has announcements of all destination points or available route stops through electronic means and legibly and visually display all destination points or available route stops through electronic means; and (y) makes all of its transit buses comply with the technical requirements set out in sections 53 to 61 of the IASR. 7.0 Design of Public Spaces Standards 7.1 The director of the department responsible for a project described in clauses (a) through (i) must ensure that, if newly constructing or redeveloping public space, the City complies with the technical requirements for: (a) recreational trails, set out in section 80.9 of the IASR; (b) beach access routes, set out in section 80.10 of the IASR; (c) recreational trails and beach access routes, set out in sections 80.11 to 80.15 of the IASR; 10 of 26 (d) outdoor public eating areas, set out in sections 80.16 and 80.17 of the IASR; (e) outdoor play spaces, set out in sections 80.18 to 80.20 of the IASR; (f) exterior paths of travel, set out in sections 80.21 to 80.31 of the IASR; (g) accessible parking, set out in sections 80.32 to 80.39 of the IASR; (h) obtaining services, set out in sections 80.40 to 80.43 of the IASR; and (i) maintenance, set out in section 80.44 of the IASR. 8.0 Customer Service Standards 8.1 The Chief Administrative Officer must ensure that the City: (a) develops, implements and maintains policies governing its provisions of goods, services or facilities, as the case may be, to persons with disabilities and the City uses reasonable efforts to ensure that the policies are consistent with the following principles: (i) the goods, services or facilities must be provided in a manner that respects the dignity and independence of persons with disabilities; (ii) the provision of goods, services or facilities to persons with disabilities must be integrated with the provision of goods, services or facilities to others, unless an alternative measure is necessary, whether temporarily or on a permanent basis, to enable a person with a disability to obtain, use or benefit from the goods, services or facilities; (iii) persons with disabilities must be given an opportunity equal to others to obtain, use and benefit from the goods, services or facilities; and (iv) when communicating with a person with a disability, the City must do so in a manner that takes into account the person's disability; (b) makes the policies established under clause (a) deal with the use of assistive devices by persons with disabilities to obtain, use or benefit from the goods, services or facilities or with the availability of other measures, if any, which enable them to do so; 11 of 26 (c) prepares one or more documents describing the policies established under clause (a) and, on request, gives a copy of any such document to any person; (d) notifies persons to whom it provides goods, services or facilities that the documents required by clause (c) are available on request; (e) at premises owned by the City where goods, services or facilities are provided to members of the public or other third parties and the public or third parties have access to the premises: (i) permits a person with a disability accompanied by a guide dog or service animal to enter the premises and to keep the animal with the person, unless the animal is otherwise excluded by law from the premises; (ii) if a guide dog or service animal is excluded by law from the premises, makes other measures available to enable a person with a disability to obtain, use or benefit from the City's goods, services or facilities; (iii) if a person with a disability is accompanied by a support person, permits both persons to enter the premises together and does not prevent the person with a disability from having access to the support person while on the premises; (iv) only requires a person with a disability to be accompanied by a support person after consulting with the person with a disability, considering the available evidence, and determining that a support person is necessary to protect the health or safety of the person with a disability or the health or safety of others on the premise, and there is not other reasonable way to protect the health or safety of the person with a disability and the health or safety of others on the premises; (f) posts this policy at a conspicuous place on premises owned or operated by the City, by posting it on the City's website or by otherwise notifying persons to whom the City provides goods, services or facilities as is reasonable in the circumstances; (g) if, in order to obtain, use or benefit from the City's goods, services or facilities, persons with disabilities usually use other particular facilities or services of the City and if there is a temporary disruption of those facilities or services in whole or in part, the City gives notice of the disruption to the public in accordance with section 80.48 of the IASR; 12 of 26 (h) provides, as soon as practicable, the following persons with training about the provision of the City's goods, services or facilities, as the case may be, to persons with disabilities: (i) all City employees and persons who volunteer with the City; (ii) all persons who participate in developing City policies; and (iii) all other persons who provide goods, services or facilities on behalf of the City; which training must include a review of the purposes of the AODA, the requirements of the IASR, and instruction on the matters required by subsection 80.49 (2) of the IASR; (i) keeps records of the training provided under clause (h), including the dates on which the training is provided and the number of individuals to whom it is provided; (j) prepares a document that describes its training policy, summarizes the content of the training and specifies when the training is to be provided and, on request, gives a copy of the document to any person; (k) notifies persons to whom it provides goods, services or facilities that the document required by clause (j) is available on request by posting this policy at a conspicuous place on premises owned or operated by the City, by posting it on the City's website or by other method as is reasonable in the circumstances; (l) establishes a process for receiving and responding to: (i) feedback about the manner in which it provides goods, services or facilities to persons with disabilities; and (ii) feedback about whether the feedback process established for the purposes of subclause (i) is accessible to persons with disabilities; which is accessible to persons with disabilities by providing, or arranging for the provision of, accessible formats and communication supports, on request; (m) prepares a document describing the feedback process and, on request, giving a copy of the document to any person; (n) notifies persons to whom it provides goods, services or facilities that the document required by clause (m) is available on request by posting the 13 of 26 information in a conspicuous place on premises owned or operated by the City, by posting it on the City's website or by such other method as is reasonable in the circumstances; and (o) on request, provides or arranges the provision of any document required to be given under this section to the person in an accessible format or with communication support: (i) in a timely manner that takes into account the person's accessibility needs due to disability; and (ii) at a cost that is no more than the regular cost charged to other persons; and (iii) after consulting with the person making the request in determining the suitability of an accessible format or communication support. 9.0 Administration 9.1 CMT members must take reasonable steps within their authority to direct compliance with this policy. 9.2 Directors must take reasonable steps within their authority to direct compliance with this policy. 9.3 Managers must take reasonable steps within their authority to direct compliance with this policy. 9.4 Supervisors must take reasonable steps within their authority to direct compliance with this policy. 9.5 The Deputy City Clerk is responsible for: (a) resolving any issues or conflicts relating to this policy; (b) approving any terms or conditions negotiated outside of this policy; and (c) updating the policy to ensure consistency with provincial legislation or other City policies or procedures. 9.6 A City employee who breaches this policy may be subject to discipline up to and including dismissal. 10.0 Application 10.1 This policy applies to all City employees. 14 of 26 11.0 Approval Authority Role Position Date Approved Quality Review Subject Matter Expert Deputy City Clerk July 29, 2024 Legal Review Senior Legal Counsel July 29, 2024 Management Review .CMT Final Approval .... 12.0 Revision History Effective Date Revision Description of Change Date of the change describe the sections that have been changed, added or deleted 13.0 Appendix 13.1 14.0 Accessibility Standards Best Practices for Staff 15 of 26 14.0 Appendix A - Accessibility Standards Best Practices for Staff The following document provides City of Kingston staff with a plain language guide for meeting accessibility standards required by provincial legislation. Where possible, reference is made to existing policies and resources that can be used to assist staff in achieving the highest level of accessibility in providing goods, services or facilities to persons with disabilities. Foundational Principles and Statement of Commitment As required by subsection 3(2) of the Integrated Accessibility Standards (Ontario Regulation 191/11) the City of Kingston is committed to meeting the accessibility needs of persons with disabilities in a timely manner. The foundational principles to achieve this work include: - Staff will work to ensure the creation of no new barriers to accessibility; - Staff will strive to achieve the highest level of inclusion in all work, where possible, above and beyond meeting the requirements of Accessibility for Ontarians with Disabilities Act and its regulations; - The City of Kingston's provision of goods, services and facilities will: o Respect the dignity and independence of persons with disabilities; o Be integrated into the provision of services for all, unless an alternative measure is necessary; o Be of an equal opportunity for persons with disabilities; and o Account for the nature of a person's disability. Customer Service Individual departments are responsible for any additional costs that may be required to meet accessibility requirements for residents. An example of this would be hiring an ASL interpreter or producing a document in an alternate format. Assistive Devices Assistive devices can be generally categorized as follows: - Mobility aids, such as wheelchairs, scooters, walkers or canes; - Hearing aids to help people hear, or hear more clearly, closed captioning on videos, or assistive listening devices that provide personal sound ampliﬁcation; 16 of 26 - Cognitive aids, including computer or electrical assistive devices; and - Tools or devices, such as automatic page turners, gripping devices or reach extending devices. Persons using assistive devices or requiring the use of assistive devices provided by the City of Kingston will be allowed to access City goods, services, and facilities. An exception may occur for the above if it is determined by staff that the use of an assistive device as part of accessing City goods, services, or facilities may pose a safety risk to the person with a disability, staff, or to other facility users. In such cases, staff will work with the person with a disability to offer alternate means to accessing the good, service, or facility, where possible. Where assistive devices are provided by the City for use by the public, staff will be trained on the safe operation of the assistive devices. Staff will also be trained on proper etiquette with respect to providing customer service to persons with disabilities that use assistive devices. Service animals A service animal is an animal that has been task-trained to provide assistance to a person with a disability. A common type of service animal is a guide dog, which provides assistance to persons who are blind or partially sighted. Service animals may provide assistance to persons with a variety of disabilities, both visible and invisible, such as medical response, mobility assistance, hearing, and combinations thereof. A person using a service animal, also known as a handler, may access all City facilities and services that are available to the public unless otherwise prohibited by law. For example, in the Health Protection and Promotion Act, service animals are permitted to enter dining areas of a restaurant but are prohibited from being in areas where food is manufactured or prepared for public consumption. If a person with a service animal wishes to access a City facility or service where in the opinion of staff the presence of the service animal would pose a hazard to the handler, the service animal, staff, or other facility users, staff will make all reasonable efforts to provide the service in an alternate method. For example, staff at Artillery Park created a service animal rest area on the pool deck to allow a handler to access the pool while keeping their service animal within close distance. During any interactions with a person with a service animal, refrain from acknowledging or distracting the service animal. Interact directly with the handler. 17 of 26 Service animals are not required to wear any sort of identiﬁcation, such as a vest. As a result, it can be difﬁcult to differentiate between a service animal and non-service animal. Behaviour is the best indicator as to whether or not an animal is a service animal. A service animal will not interact with persons or other animals, bark or make audible noise. An exception to this may be in cases where the service animal is alerting that their handler is experiencing distress. If an animal is behaving properly, regardless of status, the best practice is to allow access to the facility. If an animal is not behaving in a professional manner staff do have the ability to request a handler provide documentation of their service animal's status from one of the professionals listed below. Note, people may be visiting from outside of Ontario where documentation requirements may differ. Residents of Ontario require the following documentation: - 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; and - A member of the College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario. Regardless of status, if an animal is not behaving properly, or poses a safety risk to staff, the handler, or other facility users, the service animal and their handler can be asked to leave the facility. A handler is responsible for maintaining care and control of their service animal at all times. Support persons A person with a disability accessing a City facility or service with a support person may have that support person accompany them at all times on premises. If there is a cost associated with accessing a program or service, the support person will be permitted to attend at no additional cost. This does not apply to third party 18 of 26 events held on City property, however, those event organizers are encouraged to comply with this policy. Staff may require a person with a disability to be accompanied by a support person if it is determined that is in the best interest of the safety of a person with a disability or others accessing the service or program. Support persons may be subject to the same conﬁdentiality requirements of the person with a disability. The support person may be required to sign a waiver with respect to any conﬁdentiality issues. Notice of temporary service disruptions When a City service becomes unavailable, or if part of a City facility cannot be accessed by the public, it is important to advise users of the service or facility, as well as the general public of this disruption. The following best practices should be used: - Provide as much advance notice as possible. If the service disruption is unplanned, provide notice as quickly as possible after learning of the disruption; - Provide notice directly to users of the service or facility, if possible, and to the general public, if necessary; - Provide information as to why the service is unavailable and the length of time until the service becomes available; - Advise of alternate methods for obtaining service; and - Post notice of the service disruption in the physical location (if applicable) and through general media sources such as social media, website, emails, etc. A template Notice of Temporary Service Disruption can be found on SharePoint. Please use this notice for posting in physical locations and provide a copy to the Communications Department, your department communications ofﬁcer and Customer Experience Agents. Where appropriate staff may use alternate signage to indicate a Temporary Service Disruption, based on site conditions and the nature of the service disruption. Alternate signage should contain the same information as found on the Notice of Temporary Service Disruption and information forwarded to the email addresses above. 19 of 26 Due to the differing nature of the service provided by Kingston Transit compared to other City services, Kingston Transit will maintain its own Notice of Temporary Service Disruption template. Training All staff and volunteers are required to complete accessibility training upon their hiring. The training will consist of the following topics: - The Accessibility for Ontarians with Disabilities Act, the Integrated Accessibility Standards regulation, the Ontario Human Rights Code and how these pieces of legislation interact and complement each other; and - How to provide accessible customer service. Whenever there are signiﬁcant changes to accessibility legislation, all staff will be required to complete training regarding those changes. Additional training resources for staff may also be found on the IIDEA Resources SharePoint. Individual departments are responsible for providing training to staff on the use of any assistive devices that may be made available for use by the public as part of their operations. Staff are encouraged to seek out and provide additional accessibility training for staff based on job-speciﬁc duties. Human Resources and Organizational Development Service staff are available to assist departments in coordinating training opportunities. Staff may also wish to consult the City Learning Hub or IIDEA Resources SharePoint regarding opportunities for training and development. Tips The following are tips for providing customer service to persons with disabilities. One tip to remember above all is to ask before you help - people with disabilities often have their own way of doing things. A simple, 'How can I help you?' goes a long way. The list below is not inclusive of all disability types, and persons with disabilities may often have multiple disabilities, both visible and invisible. A visible, or apparent, disability may present itself in a physical form that is noticeable on a person's appearance, or through the use of devices such as an assistive cane, service animal or wheelchair. An invisible, or non-apparent, disability may be a physical, mental or neurological condition that is not visible from the outside yet can limit or challenge a person's movements, sense or activities. 20 of 26 Treat each interaction with a person with a disability as a unique situation. - Do not touch assistive devices or equipment without permission from the person with a disability. - When assisting a person with vision loss, identify yourself when you approach and speak directly to the person. Be precise and descriptive when providing directions or instructions. For example, if guiding them to a seat, indicate if the seat is in front, to the left or the right of the person. Offer your elbow to help guide, if needed. If you need to leave the person let them know you will be back and guide them to a comfortable location before you leave. When you return, identify yourself again. - When assisting a person with hearing loss, make sure you are in a well-lit area where they can see your face and read your lips. Try to remove background noise if possible. If necessary, ask if another method of communication would be easier (such as using a pen and paper). If the person is with a sign language interpreter, speak directly to the person, not the interpreter. - When assisting a person with speech or language disabilities, try asking questions that can be answered with a 'yes' or 'no'. Be patient and do not try to ﬁnish the person's sentences. Conﬁrm your understanding of what the person has said by summarizing or repeating. - When assisting a person with learning or developmental disabilities, be patient and do not make assumptions about what a person can or cannot do. Use plain language and provide information one piece at a time. Try to provide information in a way that works for the person. - When assisting a person with mental health disabilities, treat them with the same respect and consideration as any other person. Be conﬁdent and reassuring while respecting the person's personal space. Try to limit distractions that could affect the person's ability to focus or concentrate. - When assisting a person with a service animal, do not touch or interact with the animal. If the person cannot access a service with the service animal, provide an explanation as to why and ﬁnd another way to provide the service. See the Service Animals section of this document for more details. - When assisting a person with a disability who is accompanied by a support person, always communicate directly with the person with a disability. An exception can be provided if the person with a disability directs you to interact directly with their support person. 21 of 26 Information and Communications Feedback process Staff will encourage easy access to feedback through a variety of channels. Staff will record and analyze all feedback received, including suggestions, complaints, and compliments, with a goal of identifying how to improve service delivery. Timelines will be established for responding to feedback and to contacting a customer with a response, including keeping the customer informed if a response is unable to be provided within the set timeline. Staff can receive feedback regarding the accessibility of City goods, services, and facilities from the public in a variety of ways including: - By telephone, 613-546-0000, monitored weekdays from 8 a.m. to 5 p.m.; - By e-mail at [email protected]; - In writing to: City of Kingston Customer Service 216 Ontario Street Kingston ON K7L 2Z3; - Via the MyKingston Customer Relationship Management (CRM) system; and - In-person conversation by speaking with staff at City facilities who will document the feedback. The best practice is to work with the person providing the feedback to determine the appropriate method for receiving their feedback. The following steps may act as a guide for staff: Step 1: Identify and record feedback at the point of delivery. - The staff member receiving the initial feedback at the point of delivery will be responsible for ensuring that the information is documented. All feedback must be recorded, including suggestions, complaints, and compliments. - All resident concerns regarding accessibility are to be logged into the CRM system to ensure the feedback is documented and forwarded to the proper department. When entering the concern, click the 'Details' tab, and select yes under 'Accessibility Conﬁrm' and chose the appropriate 'Accessibility Category'. Documenting accessibility feedback and concerns via the CRM ensures tracking within the statistics kept by the Accessibility Ofﬁce. 22 of 26 Step 2: Staff response to the feedback. - All suggestions and compliments received or logged by staff in the CRM system will be acknowledged within ﬁve business days. If required, suggestions or compliments will be forwarded to the appropriate department for response and direct follow up with the customer. - Staff receiving a complaint will attempt to provide a resolution, if possible. If the problem is resolved the complaint will be logged into the CRM as complete. If the problem cannot be resolved at ﬁrst contact, details will be recorded in the CRM system and acknowledged within ﬁve business days. The appropriate department will provide a direct response to the resident within ﬁve to 10 business days. Step 3: Learning from feedback. - The Accessibility Ofﬁce will report quarterly to the MAAC on the feedback captured in the CRM system. Trends and performance will be monitored with information and suggestions to be provided directly to appropriate departmental staff. - Individual departments are encouraged to generate and review their own reports with regards to accessibility feedback to note areas of success and for potential improvement. Accessible formats and communications All documents created for public and internal corporate use should be created in accordance with Accessible Documents Guide and Accessible Documents Checklist. Documents produced on behalf of the City by outside agencies or consultants should also follow the guidelines above. It is recommended that staff provide the above guide to outside agencies and consultants in the early stages of work. All documents should contain the following statement in an obvious location to the reader: 'Alternate formats available upon request. Contact 613-546-0000 or [email protected]' Alternate formats of documents will be made available to residents upon request. The format required should be determined through discussion with the person making the request and meet their individual needs. Any additional costs for production of the alternate format are the responsibility of the individual department. Staff can contact their Communications Ofﬁcer or the Communications Department for 23 of 26 assistance in the creation of alternate formats. Certain alternate formats may require the use of a private company. Emergency information Information related to emergency procedures, plans or public safety will conform to the Accessible Documents Guide and Accessible Documents Checklist. This information will also follow the practices outlined above for accessible formats and communications. Web content standards At minimum all City website content will conform to Web Content Accessibility Guidelines (WCAG) 2.0AA standards. Staff will strive to implement accessibility practices above and beyond the WCAG 2.0AA standards where possible. Semi-annual reviews will be conducted of website navigation and content for accessibility. This work will occur in consultation with members of the MAAC. Where possible, web content will be posted in alternate methods to the use of PDFs. Any PDF content that is posted to the website will be created using the Accessible Documents Guide and Accessible Documents Checklist and remediated for use by screen readers prior to posting to the website. Employment Recruitment Throughout the recruitment process, including advertisement, interview, and offers of employment, as well as all communications during the recruitment process, it will be clearly indicated that accommodations will be made for persons requiring them. Staff will work directly with a person with a disability to coordinate reasonable accommodations that take into consideration the nature of a person's disability. When staff are made aware of a person's disability, or a person with a previously disclosed disability has received an offer of employment, Occupational Health and Safety staff will work directly with the person to develop an individual accommodation plan including an individual emergency response plan. As part of the offer of employment, a person will be made aware of the City's accessibility policies with respect to employment. Workplace Accommodations The process of determining workplace accommodation requirements will follow the City of Kingston Accommodating Disability Policy. 24 of 26 Return to Work For a workplace or non-workplace injury, when an employee with a disability returns to work they will be offered the opportunity to work in their home position with appropriate restrictions or limitations. If it is not possible for an employee with a disability to return to work in their home position due to the nature of their disability, staff will work with the employee with a disability to offer a temporary or permanent change in position that allows for accommodation of their disability. Any modiﬁcations of duties that are required will be documented in a Modiﬁed Work Plan Form and require the approval of the employee with a disability, union representative, the employee's supervisor, and a representative of the City's Occupational Health and Safety group. Individual emergency response plans An employee with a disability that requires individualized workplace emergency response information is responsible for advising their supervisor of this need. Upon being advised of this need, the supervisor and employee with a disability will complete the Workplace Emergency Response Information Form. At minimum, components of the workplace emergency response information should include: - Making the employee with a disability aware of accessible entry and exits points to their workplace; - Removal of all barriers and obstacles leading to, from, and in any location the employee is required to move back and forth from, ensuring a width of travel of no less than 1.5 metres; and - Identifying an employee(s) in the employee with a disability's workplace with the responsibility for ensuring that the employee with a disability is able to safely exit the workplace in case of an emergency or evacuation of the workplace. Performance management and career development Learning and Development staff are available to assist supervisors and other staff in the creation or acquisition of learning materials that meet the needs of staff. Alternate formats can be made available for training and professional development materials, in a format that takes into account the nature of a person's disability. 25 of 26 Inclusive performance management involves the creation of an environment between a supervisor and employee where a comfort level can be established for information sharing with respect to ability the employee's ability to complete work and the need for accommodations. Supervisors will be made aware of the resources and materials available to assist in developing performance management relationships that allow for the development of beneﬁcial employee-supervisor relationships. Much of this information can be found on the City Learning Hub. Systems are compatible with assistive technology and staff will ensure that systems are kept up to date to provide a positive user experience for both development and performance related activities. Transportation Transit staff will host an annual public meeting to receive feedback regarding the accessibility of Kingston Transit services. The format of this public meeting will take into consideration the needs of persons with disabilities. Staff will work to ensure that all general responsibilities and technical requirements required of Kingston Transit are met as detailed in Part IV of Ontario Regulation 191/11: Integrated Accessibility Standards. Taxi The Kingston and Area Taxi Commission will be invited, on an annual basis, to present to the MAAC and receive feedback regarding the proportion of accessible taxicab services required in Kingston. Design of Public Spaces Staff responsible for the design of public spaces as detailed in Section 7.0 of this Policy will meet, at minimum, the requirements outlined the Ontario Building Code, Ontario Regulation 191/11, and the City of Kingston Facility Accessibility Design Standards. Where practicable, staff will work to achieve the highest level of accessibility and inclusion. For consultation requirements with the MAAC, persons with disabilities, and the general public, staff will follow the procedures outlined in the City of Kingston Accessible Consultation Process Policy. 26 of 26 Procurement Discussion will take place between the Financial Services Department Procurement Division and departmental staff seeking to issue a request for proposals (RFP) on how accessibility elements can be incorporated into the procurement process. This may take the form of applying score weighting or the integration of accessibility elements into the deliverables scope with possible scoring applied. Included in the RFP template are standard accessibility elements to provide staff who will be issuing an RFP a starting point for accessibility considerations. These elements may include: - Requesting the proponent to provide a statement of compliance with Ontario Regulation 191/11 (Integrated Accessibility Standards), Part IV.2 Customer Service Standards; - For organizations with 20 or more employees, requesting the proponent to provide a copy of their Customer Service Accessibility Compliance report as ﬁled through Service Ontario; and - Conﬁrming that any ﬁnal reporting documents or similar deliverables will be provided in an accessible format for posting to the City's website. For projects involving the construction or renovation of City owned, leased or operated facilities, staff have the option to include accessible design requirements as detailed in the City of Kingston Facility Accessibility Design Standards as part of the scope of work and evaluation of non-price criteria.