Accessibility Policy

The Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) is a provincial statute that aims to identify, remove and prevent barriers for people with disabilities. The Integrated Accessibility Standards Regulation (IASR) (O. Reg. 191/11) under AODA provides a detailed compliance framework for designated public sector organizations, including the Workplace Safety and Insurance Board (WSIB), to enable the WSIB business areas to implement accessibility requirements in the following areas, as applicable:

customer service
information and communications
employment
design of public spaces
transportation

The Accessibility Policy (the “Policy”) is developed to ensure that WSIB meets its obligations for accessibility set out in the AODA and IASR (collectively, “AODA”) and the AODA requirements as it pertains to people with disabilities in the Ontario Human Rights Code¹.

¹The Code protects people from discrimination and harassment due to “disability” in employment, services, goods, facilities, housing, contracts, and membership in trade and vocational associations.

Purpose

The Policy defines:

WSIB’s vision and goals for accessibility; and
Expectations of WSIB Employees and business areas to ensure compliance with the AODA, other applicable legislation and WSIB policies.

The overall goal is to increase accessibility for persons with disabilities in a way that is respectful of their dignity and independence, takes into account the person’s disability and embodies the principles of integration and equal opportunity.

Application and Scope

This Policy addresses accessibility needs of WSIB Employees and WSIB Clients.

The references to “Employees” include all individuals hired under employment contracts for an indeterminate or a predetermined period of time and includes appointees to the WSIB. For clarity, independent contractors are not “Employees” for the purposes of this Policy.

Policy Statement

WSIB is committed to establishing a barrier-free environment and meeting the requirements of the AODA and the organizational policies that address Clients’ and Employees’ human rights and privacy.

In fulfilling its mandate, WSIB strives to ensure that all people have equitable and barrier-free access to WSIB premises, products, programs and services, as well as employment opportunities.

WSIB is also committed to ensuring its hiring and employment practices are designed to meet the accessibility needs of its Employees and job applicants with disabilities.

To deliver on these commitments, WSIB shall identify, prevent, and remove barriers to accessibility that interfere with the ability of people with disabilities to interact with WSIB, obtain services in a timely manner, access WSIB premises, or work with dignity and productively in the WSIB’s workplace.

Definitions

For the purpose of this Policy:

AODA means the Accessibility for Ontarians with Disabilities Act, 2005 and its Regulations.

Accessibility means giving opportunities to people of all abilities to participate fully in everyday life. It is used to describe how widely a service, product, device, or environment is available to as many people as possible. Accessibility can be seen as the ability to access and benefit from a system, service, program, product or environment.

Accessible design refers to products, devices, information, services, facilities or public spaces that provide for independent, equitable and dignified access for people with disabilities, including but not limited to those with visual, auditory, sensory, cognitive and mobility related disabilities. The concept of accessible design ensures both “direct access” (i.e. unassisted) and “indirect access,” referring to compatibility with a person’s assistive technology.

Accessible formats may include, but are not limited to, large print, recorded audio and electronic formats, braille and other formats usable by persons with disabilities.

Accommodation refers to the obligation to eliminate the disadvantage, to the point of undue hardship, caused by barriers that exclude individuals or groups protected under the Ontario Human Rights Code from participating in all aspects of their employment and/or their receipt of services on the basis of disability.

Assistive devices are any technical aids, communication devices or medical aids that are used to increase, maintain or improve the experience of individuals with disabilities. Assistive devices include, but are not limited to, wheelchairs, walkers, white canes, prosthetic limbs, note taking devices, portable magnifiers, recording machines and electronic communication devices.

Barriers means anything that keeps a person with a disability from participating in all aspects of society. Examples of barriers include:

Physical and architectural barriers: occur in the environment and prevent access for people with disabilities. Examples include narrow doorways, stairs, dim lighting or high glare surfaces.
Information or communications barriers: arise when a person with a disability cannot easily receive and/or understand information that is available to others (e.g. publications that are not available in large print, digitally, Braille or other accessible formats);
Technological barriers: occur when technology or the way it is used does not meet the needs of people with disabilities (e.g., a website that does not support screen reading software);
Attitudinal barriers: may result in people with disabilities being treated differently than people without disabilities (e.g., a receptionist who talks to an individual’s support person rather than the individual with a disability); or
Systemic barriers in policies, practices and procedures result in people with disabilities being treated differently than others or sometimes excluded altogether.

Clients means the subset of the general public to whom WSIB provides services in the ordinary course of business, including, but not limited to, people with injuries, employers, and other representatives of the public.

Communication supports may be used to access information or increase communication effectiveness. These supports include, but are not limited to, captioning, alternative and augmentative communication supports (i.e. methods used to supplement or replace speech or writing for those with impairments in the production or comprehension of spoken or written language), plain language, sign language, and other supports that facilitate effective communication.

Disability, as defined by the AODA and the Ontario Human Rights Code, is:
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 in 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; and
e) An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

This definition includes disabilities of different severity, visible as well as non-visible disabilities, and disabilities the effects of which may come and go.

Employees include all individuals hired under employment contracts for an indeterminate or a predetermined period of time and includes appointees to the WSIB. For clarity, independent contractors are not “Employees” for the purposes of this Policy.

Guide Dog means a highly-trained working dog that has been trained at one of the facilities listed in Ontario Regulation 58 under the Blind Persons' Rights Act, to provide mobility, safety and increased independence for people who are blind.

Information means data, facts, and knowledge that exists in any format, including text, audio, digital or images, and that conveys meaning.

Person Requiring Assistance (PRA) means a person identified as requiring assistance at the time of an evacuation. This can be due to a medical condition or some other reason.

Person with Disabilities means an individual who has a disability.

Public spaces refers to an area or place, such as a parking lot or a service counter, which must be open and accessible to all people.

Service Animal means a service animal for a person with a disability if:
a) the animal can be readily identified as one that is being used by the person for reasons relating to the person’s disability, as a result of visual indicators such as the vest or harness worn by the animal; or
b) the person provides documentation from one of the following regulated health professionals confirming that the person requires the animal for reasons relating to the disability:
A member of:

the College of Audiologists and Speech-Language Pathologists of Ontario;
the College of Chiropractors of Ontario;
the College of Nurses of Ontario;
the College of Occupational Therapists of Ontario;
the College of Optometrists of Ontario;
the College of Physicians and Surgeons of Ontario;
the College of Physiotherapists of Ontario;
the College of Psychologists of Ontario; or
the College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario.

Support Persons means any person whether a paid professional, volunteer, family member, or friend who accompanies a person with a disability in order to help with communication, mobility, personal care or medical needs or with access to goods, services or facilities.

Temporary Disruption means a short term planned or unplanned disruption to WSIB premises or services that persons with disabilities usually use to obtain WSIB’s goods and/or services.

Undue Hardship is the extent to which the WSIB must attempt to meet its Accommodation obligation. When determining what constitutes undue hardship, the Ontario Human Rights Code provides that consideration is given to: the cost of accommodation, health and safety requirements, and any outside sources of funding that may be available to the WSIB.

Web Content Accessibility Guidelines means the World Wide Web Consortium Recommendation entitled Web Content Accessibility Guidelines (WCAG).

Requirements

1. Accessible Client Service

1.1. WSIB shall make every reasonable effort to ensure that its policies, practices and procedures are consistent with the principles of dignity, independence, integration and equal opportunity by:

ensuring that all Clients receive the same value and quality;
allowing Clients with disabilities to do things in their own way and at their own pace when accessing services, as long as this does not pose a safety risk;
using alternative methods when possible, to ensure that Clients with disabilities have access to the same services, in the same place and in a similar manner;
taking into account individual needs when providing services; and
communicating in a manner that takes into account the Client’s disability.

1.2. WSIB Employees and service providers who provide services under WSIA on WSIB's behalf are encouraged to be proactive in seeking solutions and removing barriers, as well as alerting all Clients to the range of available accommodations.
1.3. It is recommended that WSIB Employees use the term “persons with disabilities” or “people with disabilities” and if a specific condition must be referenced, the condition be referenced last (e.g., person with low vision). To guide communication and interaction with or about people with all types of disabilities:

It is important to put people first. It is more appropriate to say “person with a disability”, rather than “disabled person” or “the disabled”.
It is best not to make assumptions. Wait until an individual describes their disability to you. Disabilities can be complex and our assumptions may be inaccurate.

1.4.   Guide Dogs and Service Animals
1.4.1.   If a person with a disability is accompanied by a guide dog, a service dog, or another service animal, the person may enter any WSIB facility with the animal and keep the animal with them.
1.4.2.   If it is not readily apparent that the animal is being used by the Client for reasons related to their disability, WSIB may request verification from the Client. It is the responsibility of the person with a disability to ensure that their service animal is under their control at all times.
1.5.   Use of Support Persons
1.5.1.   If a person with a disability is accompanied by a support person, WSIB shall ensure that both persons are allowed to enter its premises together, and that the person with a disability is not prevented from having access to the support person.
1.5.2.   WSIB may require the person with a disability to be accompanied by a support person when on WSIB’s premises in the event that a support person is necessary to protect the health and safety of a person with a disability or the health and safety of others on the premises. This may only occur after consulting with the person with a disability.
1.6.   Use of Assistive Devices
1.6.1.   Persons with disabilities may use their own assistive devices as required when accessing WSIB’s services. In cases where the assistive device presents a safety concern or where a barrier may exist, other reasonable measures may be used to ensure the access of services.
1.6.2.   WSIB shall ensure that its Employees and service providers who provide services under WSIA on WSIB's behalf are familiar with the use of assistive devices available on WSIB’s or its service provider’s premises, as appropriate to their duties, and inform persons with disabilities of the available assistive devices.
1.7.   Notice of Temporary Disruptions
1.7.1.   Service or WSIB premises related disruptions may occur due to reasons that may or may not be within the control or knowledge of WSIB. When a temporary disruption occurs, the WSIB will take steps to continue assisting people with disabilities where possible.
1.7.2.   WSIB shall provide Clients with notice in the event of a planned disruption in the premises or services usually used by people with disabilities.
1.7.3.   In the event of an unexpected disruption, WSIB shall make reasonable efforts to contact Clients with disabilities that may be impacted by the disruption prior to their scheduled services.
1.7.4.   The notice shall include information about the reason for the disruption, its anticipated duration, and a description of alternative premises or services, if available.
1.7.5.   Notice(s) will be placed at visible place(s) on the premises (e.g., public entrances, service counters) and posted on the WSIB website. When posted notices are used, there must also be a plan to convey the information to people who may not see or cannot understand the signage.
1.8.   Accessibility Feedback Process
1.8.1.   The ultimate goal of WSIB is to meet Client expectations while serving Clients with disabilities.
1.8.2.   The Accessibility Office shall ensure that the accessibility feedback process allows Clients to provide comments through its website, by email, phone or in-person.
1.8.3.   Accessible formats and communication supports shall be made available upon request to anyone wishing to provide feedback. Privacy shall be respected throughout the feedback process.
1.8.4.   When complaints or suggestions related to accessibility are received, Clients can expect the following:

Upon receipt of the feedback, regardless of the format, Clients shall receive a response acknowledging receipt of the feedback within two (2) business days and the actions that will be taken to address any issues.
Feedback received by telephone, mail, email, web chat, or in-person (reception at any WSIB office or field staff) shall be acknowledged in accordance with this Policy.
The applicable WSIB business area must follow up with any required action within the time frame noted.
All feedback responses shall be made through the Client’s selected communication channel or through the format requested by the Client. Additional time may be required for follow-up depending on the format of response required. If conversion to a certain format or communication support is not possible, WSIB shall inform the requestor and provide rationale. WSIB must then summarize the information for the requestor.
If the Client wishes to remain anonymous or indicates that receipt of acknowledgement or a response is not required, the Client’s anonymity must be respected.
All accessibility feedback shall be reviewed by the Director of the Accessibility Office, or a designate, to improve the WSIB’s services. The Director, Accessibility Office, or a designate, may forward the feedback to the responsible area, and will follow up as necessary.

1.9.   Availability of Accessibility Documents
1.9.1.   All documents required by the AODA, shall be available upon request, subject to the Freedom of Information Policy.
1.9.2.   When providing these documents to a person with a disability, WSIB shall endeavor to provide the document, or the information contained in the document, in a format that takes the person’s disability into account.

2. AODA Mandatory Training

2.1. The WSIB shall ensure that training that supports the goals of AODA, using appropriate methodologies, is provided to the following person(s):

all Employees and appointees to the Board of Directors;
every person who provides, services or premises on WSIB’s behalf, as required by the AODA; and
any person involved in developing WSIB policies, as required by the AODA.

2.2.   Training shall be appropriate to the duties of all groups listed in Section 2.1 above and provided as soon as reasonably practicable.
2.2.1.   Ongoing training shall be provided in connection with changes to WSIB’s policies, practices and procedures governing the provision of services to persons with disabilities.
2.2.2.   The WSIB shall require its service providers to ensure AODA training requirements have been met by anyone who provides services on behalf of the WSIB.
2.2.3.   The Accessibility Office may monitor and track service providers’ compliance with applicable accessibility training including by requesting and reviewing documentation to confirm completion of required training, and to ensure compliance with this Policy and applicable contract provisions with service providers.
2.3.   WSIB shall maintain a training plan for all groups listed under the Application and Scope section of this Policy that integrates the requirements of the AODA and a record of the dates on which training was completed.
2.4.   WSIB shall ensure that the amount and format of training shall be in relation to the person’s level of interaction with WSIB Clients.
2.5.   Regardless of the format, training shall cover the following:

A review of the purposes of the AODA and the requirements of the Accessibility Standards for Customer Service
Instructions on how to interact and communicate with people with various types of disabilities
Instruction on how to interact with people with disabilities who:
- use an assistive device(s); or
- require the assistance of a guide dog, service dog or other service animal; or
- require the use of a support person
Instructions on how to use equipment available on the WSIB premises or that WSIB provides that may help people with disabilities
Instructions on what to do if a person with a disability is having difficulty accessing our services
WSIB’s policies, procedures and practices pertaining to providing accessible customer service to Clients with disabilities.

3. Information and Communication

3.1.   Alternate Formats Available Upon Request
WSIB shall provide Clients with appropriate accessible formats and/or communication supports upon request. Such formats and/or supports shall be provided in a timely manner and take into account the accessibility needs of the person with a disability. The formats and/or supports will be provided at a cost that is no more than the regular cost charged to other persons.
3.2.   WSIB shall notify the public about the availability of accessible formats and communication supports through its website and shall engage in an ongoing process of identifying additional accessible formats and communications supports that may be offered by WSIB.
3.3.   Where WSIB determines that information or communications cannot be converted into an accessible format, WSIB shall provide the person requesting the information or communication with:

an explanation as to why the information or communications are inconvertible; and
a summary of the inconvertible information or communication.

3.4.   Website Accessibility
3.4.1.   Any new or significant modification to internet websites or web-based applications controlled directly by the WSIB or through a contractual relationship that allows for modification of a product shall conform to the Web Content Accessibility Guidelines (WCAG) Level A and increasing to level AA.
3.4.2.   WSIB shall continue to work towards increasing the accessibility of its existing web content, website(s) and web-based applications per WCAG requirements.
3.4.3.   At a minimum, WSIB web content will conform to WCAG 2.0 Level AA except where impracticable (WSIB web content should conform to WCAG 2.1 Level AA where possible). This criteria does not apply to live captions, pre-recorded audio descriptions, unconvertible information or communications, information not directly or indirectly in the WSIB’s control, or web content published before 2012.
3.5.   Multi-Year Accessibility Plan and Annual Progress Reports
3.5.1.   WSIB shall maintain and make public a Multi-Year Accessibility Plan to improve the accessibility of its services and premises and meet the compliance requirements of the AODA. The Plan shall be updated by the Accessibility Office within Enterprise Statutory Compliance at least once every five years and then posted on WSIB’s external website.
3.5.2.   WSIB shall prepare an annual status report on the progress of measures taken to implement the Multi-Year Accessibility Plan.
3.5.3.   The Accessibility Office shall ensure that the report is prepared in consultation with Employees with disabilities and posted on WSIB’s external website.
3.6.   Publicly Available Emergency Procedures and Safety Information
3.6.1.   WSIB prepares for emergency situations and develops emergency specific protocols for the protection of, and assistance to, everyone on WSIB’s premises during a life safety event. Publicly available emergency specific protocols and safety information will be made available in an accessible manner upon request.
3.6.2.   WSIB works with our building landlords to provide publicly available emergency procedures and safety information related to the WSIB’s premises, to Clients, upon request, in an accessible format or with appropriate communication supports. Where a WSIB building landlord is unable to provide this information in an accessible format or with appropriate communication support, WSIB will assist the Client.

4. Procurement

4.1. When procuring or acquiring goods or services or facilities, WSIB shall incorporate accessible design, criteria and features, except where it is not practicable to do so, as identified by the applicable business area, in consultation with the Accessibility Office. Where applicable, procurement documents shall specify the desired accessibility criteria to be met and provide guidelines for the evaluation of proposals in respect of those criteria.
4.2. Where WSIB determines that it is not practicable to incorporate accessible design, criteria and features when procuring or acquiring goods, services or facilities, WSIB shall provide a written explanation upon request.

5. Employment

5.1.   Notice and Provision of Accommodation in Recruitment and Selection
5.1.1.   WSIB shall notify its Employees and external applicants about the availability of accommodation for applicants with disabilities in its recruitment and selection process.
5.1.2.   WSIB shall make appropriate accommodation available, for applicants with disabilities upon their request for accommodation.
5.1.3.   WSIB shall notify successful applicants of its policies for accommodating Employees with disabilities when making offers of employment and, where applicable, provide information about policies used to support Employees after they begin employment as part of the orientation program.
5.2.   Informing Employees of Supports
Human Resources shall ensure that Employees are informed of all accessibility-related policies (and any updates to those policies) used to support Employees with disabilities, including policies on the provision of job accommodations that take into account an Employee’s accessibility needs due to disability.
This information will be provided to new Employees as soon as possible after starting employment.
5.3.   Accessible Formats and Communication Supports for Employees
5.3.1.   Upon request by an Employee with a disability, where suitable, WSIB shall provide, or arrange for, accessible formats and communication supports for information that is needed to perform their job, and information that is available to other Employees. In order to determine the suitability of an accessible format or communication support, WSIB shall consult with the Employee making the request.
5.3.2.   Accessible formats and communications supports for general workplace information shall also be provided to Employees with disabilities.
5.3.3.   WSIB shall ensure that a formalized process is in place for development of documented individual accommodation plans for Employees with disabilities.
5.4.   Individualized Workplace Emergency Response Information
5.4.1.   WSIB shall provide Employees with disabilities with individualized workplace emergency response information, in an accessible format or with appropriate communication supports, if their disability is such that individualized information is necessary and the WSIB is aware of their need for accommodation.
5.4.2.   The Healthy Workplace Centre (HWC) shall work with Employees who require individualized workplace emergency response information as soon as practicable upon receipt of a completed “Persons Requiring Assistance Form” from any such Employee. Individualized workplace emergency response information shall be shared with those designated to assist Employees in an emergency, where necessary with Employee consent.
5.4.3.   The HWC shall review individualized workplace emergency response information with Employees as required to ensure it is up to date. Individualized workplace emergency response information shall be reviewed where:

the Employee moves to a different location in the organization;
when the Employee’s overall accommodation needs or plans are reviewed; and
when WSIB reviews its emergency response protocols.

5.5.   Documented Individual Accommodation Plans
5.5.1.   WSIB shall accommodate the disability-related needs of its Employees as required under the Ontario Human Rights Code. WSIB shall develop individual accommodation plans for its Employees with disabilities, where the WSIB is made aware of their disability related needs.
5.5.2.   The written process for the development of documented individual accommodation plans for Employees with disabilities shall be developed by the HWC.
5.5.3.   The documented process for the development of individual accommodation plans shall include:

How an Employee participates in the development of their individual accommodation plan
How an Employee is assessed on an individual basis
How a Bargaining Unit Employee can ask for a representative from their bargaining agent to participate in the development of their accommodation plan
How a Non-Bargaining Unit Employee can ask for a representative from the workplace to participate in the development of the accommodation plan
How WSIB, as an employer, can request assistance from an outside expert, at WSIB’s expense
The steps WSIB must take to protect the privacy of an Employee’s personal information
How and when WSIB provides an Employee with their individual accommodation plan
How and when a plan shall be reviewed and updated
How WSIB informs an Employee that their individual accommodation plan has/has not been accepted, including how reasons for denial will be provided
How WSIB provides a plan in an accessible format

5.5.4. A documented individual accommodation plan must include:

if requested, any information regarding accessible formats and communications supports provided (as described in Section 5.3 of this Policy);
if required, individualized workplace emergency response information (as described in Section 5.4 of this Policy); and
any other accommodation that is to be provided.

5.5.5.   WSIB as an employer, in consultation with the applicable Employee, shall determine and implement appropriate accommodation(s), in accordance with the related WSIB policies on accommodation.
5.5.6.   WSIB shall implement and maintain measures to maintain the privacy of its Employees with disabilities.
5.6.   Return to Work (RTW) Process and Accommodation Plans
5.6.1.   WSIB has an approved process for development of RTW individual accommodation plans for Employees returning to work who have been absent due to a disability and who now require accommodation and support in order to return to work.
5.6.2.   The RTW process clearly defines and outlines steps WSIB shall make to facilitate an Employee’s return to work and includes a documented individual accommodation plan for each Employee as part of the process. The above stated RTW process shall not replace, hinder or override any other RTW process created by or under any other statute (i.e. the Workplace Safety and Insurance Act, 1997).
5.7.   Accommodation in Performance Management, Career Development and Advancement and Redeployment
5.7.1.   WSIB shall ensure its performance management process in respect of Employees with disabilities takes into account their accessibility needs as well as individual accommodation plans.
5.7.2.   When providing career development and advancement to Employees with disabilities, the WSIB shall take into account their accessibility needs as well as individual accommodation plans.
5.7.3.   Where the WSIB redeploys Employees with disabilities, the WSIB shall take into account their accessibility needs, as well as individual accommodation plans.

6. Design and Layout of WSIB Premises

6.1. WSIB shall ensure that the design and layout of its premises are accessible to persons with disabilities. When planning new office space or renovations to existing space, within its control, WSIB shall ensure accessibility requirements are incorporated into the planning, design, and construction phases.

7. Accessibility Reporting

7.1.   WSIB, as a designated public sector organization, shall file accessibility compliance reports every two years in accordance with the requirements set out in the AODA.
7.2.   Notice of report availability shall be provided on the WSIB’s website, through printed materials and posted within WSIB premises.
7.3.   Report copies shall be provided in an alternate format or with communication support upon request, and in a timely manner that takes into account the person’s accessibility needs due to disability.

8. Roles and Responsibilities

8.1. The President and CEO is accountable for:

approving this Policy; and
ensuring implementation of this Policy.

8.2. The Chief Risk Officer is responsible for

providing a framework and methods to WSIB management to enable AODA compliance aligned with the overall risk management approach; and
providing leadership to WSIB’s Accessibility Office.

8.3. The Vice President of Enterprise Statutory Compliance is responsible for:

leading the design, implementation, delivery and operation of the Accessibility Program and working collaboratively with WSIB’s management and stakeholders to support implementation; and
overseeing WSIB’s compliance with applicable AODA requirements.

8.4. Senior Management is responsible for:

supporting and promoting this Policy in their area of direct report and throughout the organization;
being aware of corporate liability for non-compliance with legislative requirements, including fiscal responsibility, and human rights issues;
building accessibility planning into the existing corporate and strategic business cycles as well as other planning processes and budgets;
implementing this Policy and developing or amending applicable divisional procedures or documents in order to adhere to this Policy;
designating an accessibility champion to implement accessibility policies and procedures in their clusters and making sure the related cluster/ divisional documents remain in step with WSIB’s accessibility plans; and
approving accessibility reports as required.

8.5. Accessibility Office is responsible for:

documenting, maintaining and updating this Policy;
receiving accessibility feedback and ensuring that the accessibility feedback process is documented and working effectively;
assisting with the conversion of information to an alternate format, and/or the use of appropriate communication supports, where applicable;
preparing the AODA Multi-Year Accessibility Plan and annual status report in consultation with areas that have specific AODA responsibilities and people with disabilities;
ensuring AODA Multi-Year Accessibility Plan, the annual status report and relevant AODA information are available on WSIB’s external website;
providing advice and developing accessibility requirements for projects and procurements;
consulting with key stakeholders and advisory groups on emerging or changing accessibility requirements;
overseeing mandatory AODA training completion of the groups listed in Section 2.1 of this Policy;
assessing AODA compliance risk in accordance with the Corporate Compliance Policy and determining the best compliance action (e.g. audit, reporting discovered non-compliance);
filing the AODA Compliance Report with the Ontario Government; and
addressing AODA concerns escalated to the Accessibility Office.

8.6. WSIB Managers and Supervisors are responsible for:

raising awareness to facilitate understanding of this Policy;
demonstrating sensitivity to and respecting the privacy of personal information; and
participating in and facilitating workplace accommodation, including the development of contingency plans.

8.7. Human Resources is responsible for:

acting as a resource for all parties and participants in workplace accommodation;
supporting and educating managers in their obligations by providing training on the workplace accommodation guidelines and Disability Management Program;
ensuring that individual accommodation plans are formalized and reviewed and updated as required;
developing emergency response information for persons requiring assistance during emergency situations, in consultation with the “person requiring assistance”;
overseeing recruitment and selection; performance management; career development and advancement opportunities, and re-deployment processes and practices are accessible to and inclusive of people with disabilities; and
ensuring HR developed learning products and knowledge content are accessible for WSIB Employees.

8.8. Communications is responsible for:

developing accessible design standards for posting information to internet and intranet sites and informing WSIB business areas of these requirements;
ensuring accessible design guidelines such as WCAG are being followed when posting content on WSIB’s external website and intranet sites;
maintaining the emergency and public safety information in digital format for easy conversion to accessible formats; and
developing a procedure so that WSIB communications are available to Employees with disabilities at the same time as everyone else.

8.9. WSIB Internet, Intranet and SharePoint Content Owners are responsible for:

ensuring internet, intranet and SharePoint content conforms to WSIB accessible design standards.

8.10. Real Estate and Facilities Management is responsible for:

incorporating accessible design, criteria and features when procuring or redesigning any space owned or leased by WSIB;
redesigning office space where required; and
working with WSIB building landlords and other relevant WSIB business areas as required to ensure emergency procedures, plans or public safety information is available in an accessible format or with appropriate communication supports where requested.

8.11. Customer Experience and Digital Office is responsible for:

ensuring the development of accessible design standards for digital products and to inform WSIB business areas of requirements;
ensuring accessible design guidelines such as WCAG are being followed with WSIB’s online services and digital products;
implementing accessible primary research practices with WSIB Employees and Clients; and
incorporating accessibility criteria and features into the design of new online and offline service experiences.

8.12. Learning and Development Branch is responsible for:

ensuring the development of accessible learning products and knowledge content for WSIB Employees within Service Excellence and Operations; and
informing WSIB business areas of requirement.

8.13. Reception Employees and management are responsible for:

ensuring that reception areas and equipment in reception areas available to the public are accessible and reporting problems to appropriate areas for resolution;
reporting any reception area accessibility and/or equipment concerns to the identified management representative; and
formulating plans, in conjunction with their local management, Accessibility Office and Corporate Security, for delivering services if reception areas or WSIB buildings are not accessible for people with disabilities.

8.14. Corporate Security is responsible for:

participating in the safety planning for Clients with disabilities during emergency situation events; and
assisting in formulating security plans and posting signage when there is a disruption to the accessibility of services.

8.15. Emergency Management and Business Continuity Planning is responsible for:

ensuring emergency specific protocols are established and annually reviewed for WSIB Employees, and include procedures to account for Persons Requiring Assistance (PRA’s).

8.16. Strategic Procurement is responsible for:

ensuring that procurement activities and processes are fair and accessible to suppliers, in accordance with the Procurement Policy; and
verifying that applicable assessments are completed for procurement documents, including accessibility requirements where required, in accordance with the Procurement Policy.

8.17. Information Technology is responsible for:

incorporating accessible design and features in the development of new tools and systems or when a significant upgrade is being implemented.

8.18. All WSIB Employees are responsible for:

ensuring they understand the intent of this Policy;
complying with the provisions of this Policy; and
completing required training.

8.19. Employees with disabilities are responsible for:

participating in and cooperating with all parties to facilitate workplace accommodation;
informing their manager of the need for accommodation; and
informing the HWC of their need for accommodation in an emergency by completing the “Persons Requiring Assistance Form”.

Revision History

Policy version effective October 15, 2021 replaces July 15, 2018 version. Summary of changes: new definitions (Accessible Design, Accommodation, Public Spaces); clarified Accessibility Feedback Process and Roles and Responsibilities; and minor housekeeping updates.
Policy version July 15, 2018 replaced January 1, 2015 version.
Policy version effective January 1, 2015 replaced June 26, 2013 version.
Policy version effective June 26, 2013 – new policy.

Reviewers

July 7, 2021: Accessibility Office and Corporate Policy Branch completed drafting
July 22, 2021: Subject Matter Expert (SME) and Corporate Policy Advisory Table (CPAT) review completed
September 27, 2021: Chiefs review completed