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Overview
The Accessibility for Ontarians with Disabilities Act, 2005 (the AODA) aims to develop, implement, and enforce accessibility standards to achieve accessibility 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). AODA/IASR enable the WSIB 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 Code (the Code). The Code protects people from discrimination and harassment due to Disability in the areas of: 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 the Board of Directors, WSIB Employees, business areas and Contingent Workers 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 respects their dignity and independence, considers the person’s disability, and embodies the principles of integration and equal opportunity.
Application and Scope
This Policy addresses accessibility needs of WSIB Employees, our Customers, and the public.
This Policy applies to Employees, the Board of Directors, and Contingent Workers that provide services on behalf of and to the WSIB to the extent included in the applicable contracts.
Policy Statement
WSIB is committed to establishing a barrier-free environment and meeting the requirements of the AODA and the organizational policies that address the human rights and privacy of WSIB Employees, our Customers, and the public.
In fulfilling its mandate, WSIB strives to ensure that all people have equitable and barrier-free access to WSIB premises, products, programs and services, and employment opportunities.
Language matters and shapes people’s perception of WSIB. Using incorrect terminology or outdated language can perpetuate existing barriers to disability inclusion and may be seen as Ableism. To guide communication and interaction with or about people with disabilities, this policy uses the term “person with a disability” or “people with disabilities.” This is known as ‘person first’ language. However, it is recognized that people across the disability community, including in the Autism, Deaf, and Blind communities, may prefer ‘identity first’ language, such as “Disabled person,” as they feel their disability inherently shapes their experiences and world view.
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. This includes implementing an inclusive design approach to designing communications, products, services and environments that consider the diverse needs and abilities of all users, including those with disabilities and other limitations. Inclusive design promotes diversity, equity, and inclusion by ensuring that everyone can fully participate and benefit from the designed experience by creating solutions that are accessible, usable, and accommodating to as many people as possible, regardless of their age, background or physical or cognitive abilities.
Definitions
For the purpose of this Policy:
Ableism Ableism is defined as discrimination or prejudice against persons with disabilities that manifest in various forms, such as exclusion, stereotypes or belief that people with disabilities are incapable or inferior. Ableism leads to marginalization and oppression of individuals with disabilities and can impact their access to resources, opportunities, and rights.
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 duty 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. Accommodation is provided on a case-by-case basis in a way that is responsive to the request and respects the dignity of the person.
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. A non-exhaustive list of examples includes: 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.
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.
Contingent Worker is a person who is contracted to perform a service on behalf of the WSIB on a temporary or per project basis and is not a WSIB Employee. A Contingent Worker includes the following: external consultant, independent contractor, managed service provider or temporary administrative support personnel.
Customer means the subset of the 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.
Disability, as defined by the AODA and the Ontario Human Rights Code, is:
- 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;
- 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; and
- 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 and non-visible disabilities, and disabilities whose effects 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 refer 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 refers to any animal that provides direct support to a person with a disability. In order to be classified as a service animal:
- 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
- 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 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
Accessible Client Service
- 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 Customers receive the same value and quality of services;
- allowing Customers 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 Customers with disabilities have access to the same services, in the same place and in a similar manner;
- considering individual needs when providing services; and
- communicating in a manner that takes into account the Customer’s disability.
- WSIB Employees are encouraged to be proactive in seeking solutions and removing barriers, as well as alerting all Customers to the range of available accommodations.
- It is best not to make assumptions. Wait until an individual describes their disability to you, or ask how you should refer to them, if possible. Disabilities can be complex, and our assumptions may be inaccurate.
- Guide Dogs and Service Animals
- 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.
- If it is not readily apparent that the animal is being used by the Customer for reasons related to their disability, WSIB may request verification from the Customer. It is the responsibility of the person with a disability to ensure that their service animal is under their control at all times.
- Use of Support Persons
- 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.
- 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.
- Use of Assistive Devices
- 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.
- 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.
- Notice of Temporary Disruptions
- 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.
- WSIB shall provide Customers with notice in the event of a planned disruption in the premises or services usually used by people with disabilities.
- In the event of an unexpected disruption, WSIB shall make reasonable efforts to contact Customers with disabilities that may be impacted by the disruption prior to their scheduled services.
- The notice shall include information about the reason for the disruption, its anticipated duration, and a description of alternative premises or services, if available.
- Notice(s) will be placed at visible place(s) on the premises (e.g., public entrances, service counters) and/or 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.
- Accessibility Feedback Process
- The ultimate goal of WSIB is to meet Customer expectations while serving people with disabilities. To receive and respond to customer feedback about the manner in which it provides goods, services or facilities to persons with disabilities, the WSIB will ensure that there is an accessible feedback process and that information about the feedback process is readily available to the public.
- The Accessibility Office shall ensure that the accessibility feedback process allows Customers to provide comments through its website, by telephone, mail, email, or in-person.
- 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 in accordance with the Enterprise Privacy Policy.
- When complaints or suggestions related to accessibility are received, Customers can expect the following:
- Upon receipt of the feedback, regardless of the format, Customers 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, or in-person with Employees working in the field shall be acknowledged in accordance with this Policy.
- The applicable WSIB business area must follow up with any required action within the timeframe noted.
- All feedback responses shall be made through the Customer’s selected communication channel or through the format requested by the Customer. 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 Customer wishes to remain anonymous or indicates that receipt of acknowledgement or a response is not required, the Customer’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 appropriate.
- Availability of Accessibility Documents
- All documents required by the AODA, shall be available upon request, subject to the Freedom of Information Policy. Any document(s) provided in an alternate format as part of the freedom of information process will not incur any additional charge other than what is defined in the Freedom of Information and Protection of Privacy Act (FIPPA).
- When providing these documents to a person with a disability, WSIB shall endeavour to provide the document, or the information contained in the document, in a format that takes the person’s disability into account. WSIB will consult with the person making the request in determining suitability of an accessible format or communication support.
- 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:
AODA Mandatory Training
- 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.
- Training shall be appropriate to the duties of all groups listed in Section 2.1 above and provided as soon as reasonably practical.
- 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.
- 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.
- 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.
- If accommodation is required for the training, the Accessibility Office will work with the business area to provide the accommodation.
- 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.
- WSIB shall ensure that the amount and format of training shall be in relation to the person’s level of interaction with WSIB Customers.
- 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);
- 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 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; and
- WSIB's policies, procedures and practices pertaining to providing accessible customer service to persons with disabilities.
- The WSIB shall ensure that training that supports the goals of AODA, using appropriate methodologies, is provided to the following person(s):
Information and Communication
- Digitally Inclusive Communications
- WSIB strives to provide digitally inclusive communications accessible to individuals of all abilities regardless of their access to technology or digital literacy. Information is provided in multiple formats and designed to be user friendly and easy to navigate with clear instructions and prompts for those who may be less familiar with technology. This addresses both the ease of access to information from a technical standpoint and the ease of understanding of the information.
- Alternate Formats Available Upon Request
- WSIB shall provide Customers with appropriate accessible formats and/or communication supports upon request. Such formats and/or supports shall be provided in a timely manner and to consider 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.
- WSIB shall notify the public about the availability of accessible formats and communication supports through its website and written communications when possible and shall engage in an ongoing process of identifying additional accessible formats and communication supports that may be offered by WSIB.
- 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 where possible.
- Website Accessibility
- 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 AA and increasing to level AAA..
- WSIB shall continue to work towards increasing the accessibility of its existing web content, website(s) and web-based applications per WCAG requirements.
- 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.
- Multi-Year Accessibility Plan and Annual Progress Reports
- 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 at least once every five years and then posted on WSIB’s external website.
- WSIB shall prepare an annual status report on the progress of measures taken to implement the Multi-Year Accessibility Plan.
- The Accessibility Office shall ensure that the report is prepared in consultation with Employees with disabilities and posted on WSIB’s external website.
- Publicly Available Emergency Procedures and Safety Information
- WSIB prepares for emergency situations and has developed 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.
- WSIB works with our building landlords to provide publicly available emergency procedures and safety information related to the WSIB’s premises, to Customers, 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 Customer.
- Digitally Inclusive Communications
Privacy and Confidentiality
- Individuals must be accommodated in ways that respect their dignity and right to privacy. Information relating to specific requests for accommodation will be treated as confidential and will only be used for the purpose of assessing and implementing accommodation options and solutions. The collection, use and disclosure of personal employee information will be guided by the Employee Privacy Policy, and the collection, use and disclosure of non-employee information will be guided by the Enterprise Privacy Policy.
- Where a person with a disability, who is capable of consenting, is accompanied by a support person, verbal or written consent must be provided by the person with a disability to the disclosure of confidential information in the presence of their support person.
- Where the support person for the person with a disability is also their legal representative and/or substitute decision maker, then consent from the person with a disability to the disclosure of confidential information is not required.
Procurement
- When procuring or acquiring goods or services or facilities, WSIB shall incorporate accessible design, criteria and features, except where it is not practical 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.
- Where WSIB determines that it is not practical to incorporate accessible design, criteria and features when procuring or acquiring goods, services or facilities, WSIB shall provide a written explanation upon request.
Employment
- Notice and Provision of Accommodation in Recruitment and Selection
- WSIB shall notify its Employees and external applicants about the availability of accommodation for applicants with disabilities in its recruitment and selection process.
- WSIB shall make appropriate accommodation available, for applicants with disabilities, upon their request for accommodation.
- 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.
- 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.
- Accessible Formats and Communication Supports for Employees
- 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. To determine the suitability of an accessible format or communication support, WSIB shall consult with the Employee making the request.
- Accessible formats and communication supports for general workplace information shall also be provided to Employees with disabilities.
- WSIB shall ensure that a formalized process is in place for development of documented individual accommodation plans for Employees with disabilities.
- Individualized Workplace Emergency Response Information
- 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.
- The Healthy Workplace Centre (HWC) shall work with Employees who require individualized workplace emergency response information when required as part of individual accommodation plans. Individualized workplace emergency response information shall be shared with those designated to assist Persons Requiring Assistance (PRAs) in an emergency where necessary, with employee consent.
- 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 when:
- the Employee moves to a different location within the organization;
- when the Employee’s overall accommodation needs or plans are reviewed; and
- when WSIB reviews its emergency response protocols.
- Documented Individual Accommodation Plans
- 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.
- The written process for the development of documented individual accommodation plans for Employees with disabilities shall be developed by the HWC.
- 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; and/or
- How WSIB provides a plan in an accessible format.
- A documented individual accommodation plan must include:
- if requested, any information regarding accessible formats and communication supports provided (as described in Section 6.3 of this Policy);
- if required, individualized workplace emergency response information (as described in Section 6.4 of this Policy); and
- any other accommodation that is to be provided.
- 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.
- WSIB shall implement and maintain measures to maintain the privacy of its Employees with disabilities.
- Return to Work (RTW) Process and Accommodation Plans
- 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.
- The RTW process clearly defines and outlines steps WSIB shall take 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).
- Accommodation in Performance Management, Career Development and Advancement and Redeployment
- 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.
- 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.
- Where the WSIB redeploys Employees with disabilities, the WSIB shall take into account their accessibility needs, as well as individual accommodation plans.
- Notice and Provision of Accommodation in Recruitment and Selection
Design and Layout of WSIB Premises
- 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, WSIB will include accessibility requirements in the procurement, planning, design, and construction phases of new and renovated office spaces.
Accessibility Reporting
- 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.
- Notice of report availability shall be provided on the WSIB's website, through printed materials and posted within WSIB premises.
- 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.
Roles and Responsibilities
- The President and CEO is accountable for:
- approving this Policy; and
- ensuring implementation of this Policy.
- The Chief Officer responsible for Accessibility is responsible for:
- providing a framework and methods to WSIB management to enable AODA compliance aligned with the WSIB’s overall risk management approach; and
- providing leadership to WSIB's Accessibility Office.
- The Vice President, Corporate 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.
- Senior Management is responsible for:
- ensuring adherence to 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.
- 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.
- WSIB Managers and Supervisors are responsible for:
- actively promoting and continuously improving awareness to facilitate understanding of this Policy through leadership, decisions and actions;
- demonstrating sensitivity to and respecting the privacy of personal information in relation to this Policy; and
- participating in and facilitating workplace accommodation, including the development of contingency plans.
- People Cluster 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, reviewed and updated as required;
- developing emergency response information for PRAs during emergency situations, in consultation with the PRA.
- ensuring the development of accessible learning products and knowledge content for WSIB Employees; and
- informing WSIB business areas of requirements in relation to this Policy;
- 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.
- 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.
- WSIB Internet, Intranet and SharePoint Content Owners are responsible for:
- ensuring internet, intranet and SharePoint content conforms to WSIB accessible design standards.
- 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.
- Customer and Channel Experience 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 Customers; and
- incorporating accessibility criteria and features into the design of new online and offline service experiences.
- 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 to people with disabilities.
- Corporate Security is responsible for:
- participating in the safety planning for persons with disabilities in advance of, in preparation for, and during emergency events;
- maintaining the name, contact information and expected location of a PRA, as provided to Corporate Security by the individual at time of entry to the building, and provide the current list of PRAs to emergency personnel in the event of an emergency evacuation; and
- assisting in formulating security plans and posting signage when there is a disruption to the accessibility of services.
- Emergency Management and Business Continuity is responsible for:
- ensuring emergency specific protocols are established and annually reviewed for WSIB Employees; and
- reviewing personnel and procedures to account for PRAs.
- Strategic Sourcing and Vendor Services 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.
- Information Technology is responsible for:
- incorporating accessible design and features in the development of new tools and systems or when a significant update or changes to the user interface are being implemented.
- All WSIB Employees and Contingent Workers that provide services on behalf and to the WSIB are responsible for:
- ensuring they understand the intent of this Policy;
- complying with the provisions of this Policy; and
- completing required training.
- 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
- Self-declaring through PeopleSoft HR, if they require assistance in the event of an emergency evacuation.
- The President and CEO is accountable for:
Related Documents
This Policy takes into account the following legislation and documents, as applicable:
- Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and Integrated Accessibility Standard Regulation (IASR)
- Blind Persons’ Rights Act
- Freedom of Information and Protection of Privacy Act, R.S.O,, 1990
- Ontarians with Disabilities Act, 2002
- Ontario Human Rights Code
- Web Content Accessibility Guidelines
- Workplace Safety and Insurance Act
This Policy takes into account the following WSIB corporate policies found on Policy Central, as applicable:
- Employee Privacy Policy
- Enterprise Privacy Policy
- Freedom of Information Policy
Revision History
- Policy version effective January 15, 2025 replaces October 15, 2021 version. Summary of changes: revised Policy Statement; new definitions (Ableism, Contingent Worker); updated definitions (Accommodation, Assistive Devices, and Service Animal); replace Client with Customer and service provider with Contingent Worker; clarify processes for temporary service disruptions, submitting accessibility feedback, and providing accessibility documents; specify confidentiality and privacy requirements including consents required to communicate with support persons and legal representatives; update roles and responsibilities to reflect organizational changes; housekeeping revisions including updating related documents, position titles, new WSIB logo.
- Policy version effective October 15, 2021 replaced July 15, 2018 version.
- 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
Approvals
Recommended for approval by:
Original signed by: Janine Dyck, Chief Employer Services Officer, December 23, 2024
Final approval:
Original signed by: Jeffery Lang, President and CEO, December 23, 2024