Integrated Accessibility Standards Policy
Please note:
- · Under the Accessibility for Ontarians with Disabilities Act, 2005 all public and private sector organizations must meet the requirements of accessibility standards established by the regulation.
- · Where this policy varies from the Integrated Accessibility Standards under the Accessibility for Ontarians with Disabilities Act (AODA), the AODA Standard shall apply.
- · This policy may require revision as other standards are introduced under the AODA.
- · This policy establishes the Integrated Accessibility Standards in the areas of Employment, Information and Communication, and Transportation in accordance with Ontario Regulation 191/11.
Policy Statement
Lufthansa InTouch Peterborough is committed to providing persons with disabilities the same opportunity to access our resources and services, in a manner consistent with the principles of dignity, independence, integration, and equal opportunity.
Furthermore, Lufthansa InTouch Peterborough shall use every effort to ensure that we meet the needs of persons with disabilities, in a timely manner, through the implementation of this policy in accordance with the spirit and intent of all applicable legislation including the AODA, the Ontario Human Rights Code, and the Occupational Health and Safety Act.
Definitions
For the purpose of this policy, the following terms are defined as:
Accessible Formats:
Refers to materials that have been converted to accessible formats which include, but are not limited to, large print, recorded audio and electronic formats, Braille and other formats usable by persons with disabilities.
Accommodation:
The special arrangement made or assistance provided so that persons with disabilities can participate in the experiences available to persons with disabilities. Accommodation shall vary depending on the person’s specific accessibility needs.
Communications:
The interaction between two or more persons or entities, or any combination of them, where information is provided, sent or received.
Communication Supports:
Methods and aids that facilitate effective communications with persons with disabilities that include, but is not limited to, captioning, alternative and augmentative communication supports, plain language, and sign language.
Disability:
Disability is defined under the AODA and the Human Rights Code as:
- · 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 co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device;
- · a condition of mental impairment or a developmental disability;
- · a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
- · a mental disorder; 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.
Information:
Means data, facts and knowledge that exist in any format, including text, audio, digital or images, and that convey meaning.
Redeployment:
Means the reassignment of workers to other departments or jobs within the organization as an alternative to layoff, when a particular job or department has been eliminated.
Supervisor:
A person who has charge of a workplace or authority over a worker. Generally this would include those with a position title such as Director, Manager or Supervisor, as well as any other management type position, or those in a temporary supervisory position.
Unconvertible:
If it is not technically feasible to convert the information or communications; The technology to convert the information or communication is not readily available.
Worker:
Refers to any person regarding whom Lufthansa InTouch Peterborough pays wages or a salary, has control over their assigned work and has a right to control the details of their work.
This includes, but is not limited to:
- full-time workers
- part-time workers
- seasonal workers
- contract workers
Operating Principles
Multi-Year Accessibility Plan
Lufthansa InTouch Peterborough shall create a multi-year Accessibility Plan outlining a phased-in approach to prevent and remove barriers and address the current and future requirements of the AODA. The plan shall be reviewed and updated at least every five years or as required.
Training
Lufthansa InTouch Peterborough shall ensure that training is provided to all workers on the requirements of the accessibility standards referred to in the regulations and on the Human Rights Code as it pertains to persons with disabilities.
This training shall be provided within 3-4 weeks of, when the individual commences performing duties for Lufthansa InTouch Peterborough. Additional training shall be provided within 3-4 weeks of, any revisions made to this policy and/or related procedures and practices.
Information and Communication Standards
Lufthansa InTouch Peterborough shall create, provide and receive information and communication in methods that are accessible to persons with disabilities.
If it is determined that it is not technically feasible to convert the information or communication, or the technology to convert the information or communication is not readily available the person requesting the information shall be provided with:
- – an explanation as to why the information or communication is not convertible;
- – a summary of the unconvertible information or communication.
Emergency Information
Lufthansa InTouch Peterborough shall prepare emergency procedures, plans or public safety information and make the information available in an accessible format or with appropriate communication supports, as soon as practicable, upon request.
Feedback Process
Lufthansa InTouch Peterborough has established a process for receiving and responding to feedback from individuals about the manner in which it conducts business with persons with disabilities. Information about this process shall be made readily available in an accessible format or with appropriate communication supports. The feedback process shall permit persons to provide their feedback in person, by telephone, in writing, or by delivering an electronic text by email or on diskette or otherwise.
The feedback process shall specify the actions to be taken by Lufthansa InTouch Peterborough in the event that a complaint is received.
Lufthansa InTouch Peterborough is committed to excellence in serving all customers, including people with disabilities. Should you wish to provide feedback, you are welcome to do so in writing via the below contact information. Please include your full name, indicate your preferred method of response (email or mail), and include all relevant contact information.
Lufthansa InTouch Global TeleSales of Canada, Inc.
1900 Fisher Drive
Peterborough, ON
K9J 6X6
Canada
Phone: +1 (705) 872 3000 (ext. 3)
Fax:+1 (705) 755 1172
Email: YPQXRCEN@dlh.de
All feedback will be reviewed. Where required, customers will receive a response within 10 business days.
Accessible Formats and Communication Supports
Lufthansa InTouch Peterborough shall provide or arrange for accessible formats and communication supports for persons with disabilities:
- – Upon request, and in a timely manner that takes into account the person’s accessibility needs due to a disability;
- – At a cost that is no more than the regular cost charged to another person;
- – In consultation with the person making the request determine the suitability of an accessible format or with appropriate communication supports.
Education, Training and Materials
Lufthansa InTouch Peterborough shall provide access to or prepare for the provision of access to accessible materials where they exist, make information about the availability of accessible materials publicly available, and provide the information in an accessible format or with appropriate communication supports, upon request.
Website Accessibility
Lufthansa InTouch Peterborough shall make their company Internet and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 initially at Level A and increasing to Level AA. By January 1, 2014, any new web content shall conform to WCAG 2.0 Level A. By January 1, 2021 all website and web content shall conform to WCAG 2.0 Level AA.
EMPLOYMENT STANDARDS
The Employment Standards build upon the present requirements under the Human Rights Code in relation to whereby accommodate persons with disabilities through the job application process and the employment relationship. It applies in respect to workers and does not apply to volunteers and other non-paid individuals.
Recruitment and Selection
Lufthansa InTouch Peterborough shall notify internal and external job applicants about the availability of accommodations upon request for applicants with disabilities. This may take the form of a notice posted to the company website or a statement on a job posting for which ’accommodation for applicants with disabilities is available upon request.’ In addition, job applicants who have been selected to participate in an assessment or selection process shall be notified that accommodations are available. The related materials or processes required specific to the job applicant’s disability shall be discussed in consultation with the applicant.
Worker Notification
Lufthansa InTouch Peterborough shall inform workers of policies and procedures including those on the provision of job accommodation that take into account a worker’s accessibility needs. This information shall be provided to new workers as soon as practical after they commence performing their duties with Lufthansa InTouch Peterborough. Once the applicable support is identified, Lufthansa InTouch Peterborough shall determine how best to accommodate the worker in consultation with the reporting supervisor, human resources specialist and the worker.
Accessible Formats and Communication Supports for Workers
In addition, and where a worker with a disability requests it, Lufthansa InTouch Peterborough shall consult with the worker to provide or arrange for the provision of accessible formats and communication supports for:
- – Information that is needed in order to perform the job tasks;
- – Information that is generally available to workers in the workplace;
- – Consult with the worker making the request in determining the suitability of an accessible format or communication support.
Individual Accommodation Plan
Lufthansa InTouch Peterborough shall develop, maintain and document an individual accommodation plan for workers with disabilities to meet requirements under the Employment Standards. Information regarding accessible formats and communication supports shall be covered in individual accommodation plans.
Return to Work Process
Lufthansa InTouch Peterborough shall maintain a return to work process for its workers who have been absent from work due to a disability and who require disability-related accommodations in order to return to work. The process shall take into account individualized accommodation plans suitable for the worker. This return to work process shall not replace or override any current return to work processes overseen by the Human Resources Department.
Performance Management, Career Development, Advancement, and Redeployment
Lufthansa InTouch Peterborough shall examine the accessibility needs of workers with disabilities when handling performance management, providing career development and advancement to workers, and if redeploying workers to other locations or workgroups.
Workplace Emergency Response
Where the worker with a disability requires assistance, Lufthansa InTouch Peterborough shall, in consultation with the worker, provide an assigned support person(s) to assist during emergency situations that require evacuation of the premises. The individualized workplace emergency plan or process shall be shared with the support person(s), only with full agreement by the worker ensuring their privacy at all times. Lufthansa InTouch Peterborough shall review the individual workplace emergency information when or if the worker moves to a different location or workgroup, or there is a change to their disability, with the reporting supervisor, human resources specialist and the worker.
In addition, a general, emergency evacuation process shall be in place for any facility that may have visitors with disabilities that require further assistance. This process shall be communicated to all workers.
TRANSPORTATION STANDARDS
The Transportation Standards make it easier for people to travel on specialized and public transportation and in taxicabs in Ontario, including persons with disabilities, older Canadians, and families with children in strollers.
Lufthansa InTouch Peterborough is not a provider of specialized or public transit and does not license taxicabs; therefore the Transportation Standards requirements do not apply to the company.
Monitoring and Contraventions
Supervisors shall monitor current practices to ensure compliance. Failure to comply with this policy may result in disciplinary action, up to and including dismissal.
ACCESSIBILITY STANDARDS FOR CUSTOMER SERVICE POLICY
Policy Statement
Global TeleSales of Canada, Inc (Lufthansa InTouch Peterborough) is committed to preventing, identifying and removing barriers that impede the ability of people with disabilities to access care and services. This includes customers, visitors, and employees.
In June, 2005 the Ontarion government passed the Accessibility for Ontarians with Disabilities Act (AODA). The purpose of this enhanced Act is to develop, implement and enforce standards of accessibility for all Ontarians. Lufthansa InTouch Peterborough’s Accessibility Policy is consistent with the AODA 2005 and the Accessibility Standards for Customer Service, Ontario Regulation.
Purpose
The purpose of this policy is to outline practices and procedures in place at Lufthansa InTouch Peterborough to help identify and remove barriers that impede a person’s ability to access care and services.
Definitions
Assistive Devices and Measures:
Assistive devices and measures are supports made available by providers to improve access to care for patients with disabilities. For example, wheelchairs, volunteers, real-time captioning services, sign language interpreters or deaf-blind interveners. Other examples include, Telephone Teletypes (TTY) to communicate with clients who are deaf, hard of hearing, have speech impairments, or are deaf-blind (Guide to the Accessibility Standards for Customer Service, Ontario Regulation).
Disability
According to the Ontario Human Rights Code, a ’Disability’ is defined as:
- a. 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 co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device.
- b. a condition of mental impairment or a developmental disability
- c. a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language
- d. a mental disorder,or
- e. any 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 the effects of which may come and go.
Personal Assistive Devices
For the purpose of this policy, Personal Assistive Devices are personal supports used by persons with disabilities that enable them to carry out the activities of daily living and allow access to hospital services. Patient owned equipment such as power-mobility devices (power wheelchairs or scooters) are regarded as Personal Assistive Devices.
Service Animals
Service animals are used by people with many different kinds of disabilities. Examples of serviced animals include dogs used by people who are blind, hearing alert animals for people who are deaf, deafened or hard of hearing, and animals trained to alert an individual to an oncoming seizure and lead them to safety.
Support Person
A “Support Person” accompanies a person with a disability, in order to help with communication, mobility, personal care or medical needs or with access to goods or services. Medical needs may include, but are not limited to, monitoring an individual’s health or providing medical support by being available in the event of a seizure. A Support Person may be a paid professional, a volunteer, family member or friend of the person with a disability.
Procedure
Lufthansa InTouch Peterborough will ensure we are identifying and removing barriers to access for people with disabilities by:
- – Encouraging people with disabilities to use their own personal assistive devices to improve access to Lufthansa InTouch Peterborough’s goods and services;
- – Enabling people with disabilities to access our goods and services and utilize our services and offering assistive measures;
- – Communicating with a person with a disability in a manner that takes into account his or her disability;
- – Allowing people with disabilities to bring their guide dog or service animal with them to areas of the premises that are open to the public;
- – Permitting people with disabilities who use a support person to accompany them and ensuring that a person with a disability has access to his or her support person while on the premises;
- – Training staff about key principles and accessibility strategies and tools;
Providing notice when facilities or services that people with disabilities rely on to access our services are temporarily disrupted;
- – Establishing a process for people to provide feedback on how goods or services are delivered and explaining how Lufthansa InTouch Peterborough will respond to any feedback and what action will be taken. It is the responsibility of every staff member to be attentive to the concerns of employees, their families and visitors and to resolve concerns related to accessibility. There are a number of strategies that are available to staff/families/visitors to provide feedback regarding accessibility.
References & Appendix
Relevant Policies, Procedures and Practices
- – Accessibility for Ontarians with Disabilities Act, 2005
- – Equal Opportunity
Guide to the Accessibility Standards for Customer Service, Ontarian Regulation Standards of Accessibility under the AODA
- – Transportation: This standard needs to reflect a variety of environments, financial capabilities of the users/providers and the differing modes of travel including conventional and specialized modes, and on-demand taxi services.
- – Information and Communication: Information and communications provided to the consumer or end-user through print, telephone, electronic devices, and in person; also includes publications and software applications.
- – The Built Environment: Access to, and from and within buildings and outdoor spaces; also includes counter heights, aisle and door widths, parking, signage, pedestrian access routes and signal systems.
- – Employment: Hiring and retaining employees; also includes employment practices, policies and processes such as job advertisements and interviewing.
- – Dignity: Refers to policies, procedures and practices that treat a person with a disability as a client who is as valued and deserving of effective and full services as any other client. They do not treat people with disabilities as an afterthought or force them to accept lesser service, quality or convenience. Service delivery needs to take into account how people with disabilities can effectively access and use services and show respect for these methods.
- – Independence: In some instances, independence means freedom from control or influence of others’ freedom to make your own choices. In other situations, it may mean the freedom to do things in your own way. People who may move or speak more slowly should not be denied and opportunity to participate in a program or service because of this factor.
- – Integration: Integrated services are those services that allow people with disabilities to fully benefit from the same services, in the same place and in the same or similar way as other clients. Integration means that policies, practices and procedures are designed to be accessible to everyone including people with disabilities. Sometimes integration does not serve the needs of all people with disabilities. In these cases, it is necessary to use alternate measures to provide goods or services. Alternate measures are ways of serving people that are not completely integrated into the regular business activities of the organization, for example, email.
- – Equal Opportunity: Equal opportunity means having the same chances, options, benefits and results as others. In the case of services, it means that people with disabilities have the same opportunity to benefit from the way you provide 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.
Feedback
Lufthansa InTouch Peterborough is committed to excellence in serving all customers, including people with disabilities. Should you wish to provide feedback, you are welcome to do so in writing via the below contact information.Please include your full name, indicate your preferred method of response (email or mail), and include all relevant contact information.
Lufthansa InTouch
Global TeleSales of Canada, Inc.
1900 Fisher Drive
Peterborough, ON
K9J 6X6
Canada
Phone: +1 (705) 872 3000 (ext. 3)
Fax: +1 (705) 755 1172
Email: YPQXRCEN@dlh.de
All feedback will be reviewed. Where required, customers will receive a response within 10 business days.