Accessibility Standards for Customer Service

HR-01 Accessibility Standards for Customer Service
Department	People & Culture
Creation Date	January 7, 2010
Approval Date	December 7, 2022
Effective Date	January 7, 2010

Organizational Scope

This policy shall apply to every person who interacts with members of the public, students or other third parties on behalf of Michener. This including but not limited to employees, students, volunteers.

This policy aligns with Michener’s equity seeking polices and adheres to the Ontario Human Rights Code .

Purpose

The purpose of the Accessibility Standards for Customer Service Policy is to create standards governing the provision of goods and services within the Michener organization to persons with disabilities and improve accessibility, using reasonable efforts, in a way that preserves the dignity and independence of people with disabilities.

Policy

The guiding document for compliance requirements is set forth in the Accessibilities for Ontarians with Disabilities Act (AODA), Regulation 429/07. As such, this policy shall address the following:

1. Statement

Michener shall ensure that its policies, practices and procedures are consistent with the following principles;

• The goods or services will be provided in a manner that respects the dignity and independence of persons with disabilities with all intersecting identities.
• The provision of goods or services to persons with disabilities will be integrated unless an alternate measure is necessary, whether temporarily or on a permanent basis, to enable a person with a disability to obtain, use or benefit from the goods or services.
• Persons with disabilities will be given an equal opportunity to obtain, use, and benefit from the goods or services.
• Persons with disabilities may use assistive devices, support persons, and/or service animals in the access of goods and services.
• Michener employees when communicating with a person with a disability shall do so in a manner that takes into account the person’s disability.

2. Definitions

Assistive Devices

Any auxiliary aid such as communication aids, cognition aids, personal mobility aids and medical aids (i.e. canes, crutches, wheelchairs, or hearing aids).

Disabilities

The same as definition of disability found in the Ontario Human Rights Code.

Employees

Any person who deals with members of the public or other third parties on behalf of Michener, whether the person does so as an employee, agent, volunteer or otherwise.

Persons with Disabilities

Individuals who have a disability as defined under the Ontario Human Rights Code.

Service Animals

Any animal individually trained to do work or perform tasks for the benefit of a person with a disability.

Support Animals

Emotional support animals provide comfort and security. However, they do not have training for specific tasks to support a person with a disability under the AODA.

Students

For the purposes of this document, the term student applies to any individual who is registered to engage in studies at Michener, be it full-time, part-time, microcredentialing, international, and or in continuing education courses and programs.

Support Persons

Any person whether a paid professional, volunteer, family member or friend who accompanies a person with a disability in order to help with communications, personal care, medical needs or with access to goods or services.

People Leader

A Michener employee who has the delegated authority to recruit, conduct performance reviews and discipline; supervise, control, or assign the allocation and use of human,
capital, and financial resources; and act on behalf, and represent the interests of Michener management in the affairs of the organization.

Customer

Refers to employees, student, volunteers, faculty and other third-party on behalf of Michener.

3. Exception

This Accessibility Customer Service Standards Policy shall not apply during any period where Michener has declared a “State of Emergency” as defined under the Emergency Management Act .

4. Management Expectations

To implement this policy, management employees shall:

• Establish practices and procedures
• Evaluate practices and procedures
• Revise practices and procedures as required
• Hold accountable persons who engage in breaches of the policy

5. Review & Amendments

The Accessibility Coordinator shall be responsible for the review process and any subsequent amendments to this policy document.  Review and amendments shall take place on an ongoing basis, and at least every two years.

Customer Feedback

Feedback from our customers provides Michener with opportunities to learn and improve. Michener recognizes the right of our customers to make a complaint, compliment or make suggestions on ways to improve our services.

To assist Michener in ensuring that the delivery of goods and service to those with disabilities is provided in an effective and timely manner, the customer is invited to provide their feedback as follows:

In writing, in person, e-mail, or telephone, addressed to:

The Accessibility Committee Co-Chair(s)
People and Culture Department
222 St Patrick Street, Toronto ON M5T1V4
Phone: (416) 596-3101 Ext. 3426
E-mail: hr@michener.ca

The Accessibility Committee Co-Chair(s) will respond either in writing, in person, e-mail or telephone acknowledging receipt of feedback and will set out the action to be taken in response to any complaints.

6. Service Animals & Support Persons

• Michener employees shall use reasonable efforts to allow persons with disabilities to use their own assistive devices to access goods and/or services.
• Michener employees shall allow persons with disabilities to be accompanied by their guide dog or service animal unless the animal is excluded by law.
• Where an animal is excluded by law from the premises, the reason why the animal is excluded shall be explained to the persons with disabilities, and other reasonable arrangements to provide goods and services shall be explored with the assistance of
  that individual.
• When a service animal is unruly or disruptive (jumping on people, biting, or other harmful behaviour) an employee may ask the person responsible / handler to remove the animal from the area or refuse access to goods or services. In this event, other reasonable arrangements to provide goods or services shall be explored with the assistance of the person with disability.
• Persons with disabilities may be accompanied by their support person while accessing goods and/or services.
• Persons with disabilities may not be accompanied by animals other than service working animals.
• See Appendix I

7. Admission Fees – Advanced Notice

In the event that admission fees are charged, advance notice concerning what admission, if any, would be charged to a support person shall be posted in a conspicuous place.

8. Planned Service Disruptions – Notice

• It is possible that from time to time there will be disruptions in service (e.g. an entrance way that is under repair, renovations that limit access to an area, or technology that is temporarily unavailable).
• In the event that a disruption in service is planned, and expected, it is important to provide reasonable notice.
• People with disabilities may often go to a lot of trouble to access services, such as booking transit or arranging a ride. In order to minimize inconvenience, provide as much advance notice as possible.
• Notice will be provided on the website, over the phone, or in writing.

9. Unexpected Disruption of Service – Notice

• In the event of an unexpected disruption in service, notice may be provided in a variety of ways, and will be done as quickly as possible.
• In the event of an unplanned service disruption, alternative methods of service may be considered and those impacted by service interruption shall be informed of any alternative methods.

10. Training Requirements

• Every person who participates in the development of the policy, practices and procedures under Ontario Regulation 429/07 – Accessibility Standards for Customer Service must be trained appropriately in relation to this Policy.
• Every person who deals with the public on behalf of Michener, including 3rd parties i.e. employees, agents, volunteers, management, must complete training in relation to this Policy.
• Current employees, agents, volunteers, management, etc. shall receive training on a regular basis.
• New employees, agents, volunteers, management, etc. shall receive training as soon as “practicable”, after being assigned.
• Ongoing training on changes to policies, procedures, and new equipment shall be provided.
• The method and amount of training shall be geared to the trainee’s role in terms of accessibility.
• Training records shall be kept, including the dates when the training is provided, number of individuals to whom the training was provided.

11. Acceptable Terms For Use When Talking About Disabilities

Words can influence and reinforce the public’s perception of people with disabilities. They can create either a positive view of people with disabilities or an indifferent, negative depiction. Some may not even identify as having a disability, so sensitivity and willingness to listen to the respective individual’s need is key.

Here are some general tips that can help make your communication and interactions with or about people with all types of disabilities more successful.

• Remember to put people first. It is proper to say person with a disability.
• If you don’t know someone or if you are not familiar with the disability, it’s better to wait until the individual describes their situation to you, rather than to make your own assumptions. Many types of disabilities have similar characteristics and your
  assumptions may be wrong. Disabilities are not always visible or easy to distinguish.
• Use disability or disabled, not handicap or handicapped.
• Recognize that many colloquial terms are demeaning and disrespectful.

12. Best Practices & Procedures

Accessible Customer Service follows four basic principles:

• Dignity
• Independence
• Integration
• Equal Opportunity

What can I do to help people with disabilities access our services?

• Ask how you can help
• Offer a variety of methods of communication
• Understand the nature and scope of the service you offer

Providing Customer Service for Persons with Disabilities

Physical

Physical disabilities include a range of functional limitations from minor difficulties in moving or coordinating one part of the body, through muscle weakness, tremors, and paralysis. Physical disabilities can be congenital such as Muscular Dystrophy; or acquired, such as tendonitis. A physical disability may affect an individual’s ability to:

• Perform manual tasks such as holding a pen, turning a key or grip a door knob
• Move around independently
• Control the speed or coordination of movements
• Reach, pull or manipulate objects
• Have strength or endurance

Best practices and procedures for Customer Service (Physical)

There are many types and degrees of physical disabilities, and not all require a wheelchair. It may be difficult to identify a person with a physical disability.

• Speak normally and directly to your customer. Don’t speak to someone who is with them
• People with physical disabilities often have their own way of doing things. Ask before you help
• Wheelchairs and other mobility devices are part of a person’s personal space, don’t touch, move or lean on them
• Provide your customer information about accessible features of the immediate environment (automatic doors, accessible washrooms, etc.)
• Keep ramps and corridors free of clutter
• If a counter to too high or wide, step around it to provide service
• Provide seating for those who cannot stand in line
• Be Patient. Customers will identify their needs to you

Hearing

Hearing loss can cause problems in distinguishing certain frequencies, sounds or words. A person who is deaf, may be unable to:

• Use a public telephone
• Understand speech in noisy environments
• Pronounce words clearly enough to be understood by strangers

Best practices and procedures for Customer Service (Hearing)

• Hearing loss has a wide variety of degrees and some people may require assistive devices when communicating.
• Attract the customer’s attention before speaking. The best way is a gentle touch on the shoulder or gently waving your hand
• Always ask how you can help. Don’t shout. Speak clearly.
• Be clear and precise when giving directions, and repeat or rephrase if necessary. Make sure you have been understood.
• Face the person and keep your hands and other objects away from your face and mouth.
• Deaf people may use a sign language interpreter to communicate- always direct your attention to the Deaf person –not the interpreter.
• Any personal (e.g. financial) matters should be discussed in a private room to avoid other people overhearing.
• If the person uses a hearing aid, try to speak in an area with few competing sounds.
• If necessary, write notes back and forth to share information.
• Don’t touch service animals – they are working and have to pay attention at all times.

Deaf – Blindness

Deaf – Blindness is a combination of hearing and vision loss. The result for a person who is deaf-blind has significant difficulty accessing information and performing daily activities. Deaf-blindness interferes with communication, learning, orientation and mobility. People who are deaf-blind communicate using various sign language systems, Braille, telephone devices, communication boards and any combination thereof.

Many people who are deaf-blind use the services of an intervener who relays information, facilitates auditory and visual information and acts as a sighted guide.

Best practices and procedures for Customer Service (Deaf – Blindness)

Most people who are deaf-blind will be accompanied by an intervener, a professional who helps with communicating. Interveners are trained in special sign language that involves touching the hands of the client in a two-hand, manual alphabet or finger spelling, and may guide and interpret for their client.

• Do not assume what a person can or cannot do. Some people who are deaf-blind have some sight or hearing, while others have neither.
• A customer who is deaf-blind is likely to explain to you how to communicate with them or give you an assistance card or a note explaining how to communicate with them.
• Do not touch or address the service animals – they are working and have to pay attention at all times.
• Never touch a person who is deaf-blind suddenly or without permission unless it’s an emergency.
• Understand that communication can take some time- be patient.
• Direct your attention to your customer, not the Intervener.

Vision

Vision loss or blindness reduces one’s ability to see clearly and can occur on varying levels. Very few people are totally blind; many have limited vision such as tunnel vision, where a person has a loss of peripheral or side vision, or a lack of central vision, which means they cannot see straight ahead. Some can see the outline of objects while others can see the direction of light.

Vision loss may result in:

• Difficulty reading or seeing faces
• Difficulty manoeuvring in unfamiliar places
• Inability to differentiate colours or distances
• A narrow field of vision
• The need for bright light, or contrast
• Night blindness

Best practices and procedures for Customer Service (Vision)

Vision loss may restrict your customers’ abilities to read signs, locate landmarks or see hazards. In some cases, it may be difficult to tell if a person has a vision disability, while others may use a guide dog and/or white cane.

• Verbally identify yourself before making physical contact.
• If the person uses a service animal- do not touch or approach the animal- it is working.
• Verbally describe the setting, form, location as necessary.
• Offer your arm to guide the person. Do not grab or pull.
• Never touch your customer without asking permission, unless it is an emergency.
• Don’t leave your customer in the middle of a room. Show them to a chair, or guide them to a comfortable location.
• Don’t walk away without saying good-bye.

Intellectual

Intellectual disabilities affect a person’s ability to think and reason. It may be caused by genetic factors such as Downs Syndrome, exposure to environmental toxins, such as Fetal Alcohol Syndrome, brain trauma or psychiatric disorders.

A person with an intellectual disability or developmental delay may have difficulty with:

• Understanding spoken and written information
• Conceptual information
• Perception of sensory information
• Memory

Best practices and procedures for Customer Service (Intellectual)

People with intellectual or developmental disabilities may have difficulty doing many things that most of us take for granted. These disabilities can mildly or profoundly limit one’s ability to learn. You may not be able to know that someone has this disability unless you are told, or you notice the way people act, ask questions or use body language.

As much as possible, treat your customers with an intellectual or developmental disability like anyone else. They may understand more than you think, and they will appreciate you are treating them with respect.

• Do not assume what a person can or cannot do
• Use clear, simple language
• Be prepared to explain and provide examples regarding information
• Remember that the person is an adult and unless you are informed otherwise, can make their own decisions
• Be patient and verify your understanding
• If you can’t understand what is being said, don’t pretend. Just ask again
• Provide one piece of information at a time
• Speak directly to your customer, not to their companion or attendant

Speech

Speech disabilities involve the partial or total loss of the ability to speak.

Typical disabilities include problems with:

• Pronunciation
• Pitch and loudness
• Hoarseness or breathiness
• Stuttering or slurring

Best practices and procedures for Customer Service (Speech)

Some people have problems communicating. It could be the result of cerebral palsy, hearing loss, or another condition that makes it difficult to pronounce words, causes slurring or stuttering, or not being able to express oneself or understand written or spoken language.

Some people who have severe difficulties may use communication boards or other assistive devices.

• Where possible, communicate in a quiet environment
• Give the person your full attention. Don’t interrupt or finish their sentences.
• Ask them to repeat as necessary, or to write their message.
• If you are able, ask questions that can be answered ‘yes’ or ‘no’
• Verify your understanding
• Patience, respect and willingness to find a way to communicate are your best tools

Learning

Learning disabilities include a range of disorders that affect verbal and non-verbal information acquisition, retention, understanding and processing. People with a learning disability may have average or above average intelligence, but take in and process information and express knowledge in different ways.

Learning disabilities may result in difficulties with:

• Reading
• Problem solving
• Time management
• Way finding
• Processing information.

Best practices and procedures for Customer Service (Learning)

• Learning disabilities are generally invisible and ability to function varies greatly.
• Respond to any requests for verbal information, assistance in filling in forms, etc. with courtesy.
• Allow extra time to complete tasks if necessary.
• Alternative format of materials.
• May need to be provided written instruction or summary notes of meetings.

Mental Health

Mental Health disabilities include a range of disorders;

• Anxiety
• Mood
• Behavioural
• ADHD

People with mental health disabilities may seem edgy or irritated, act aggressively, be perceived as pushy or abrupt, be unable to make a decision, start laughing or get angry for no apparent reason.

Best practices and procedures for Customer Service (Mental Health)

• Treat each person as an individual. Ask what would make them the most comfortable and respect they/their needs to the maximum extent possible.
• Try to reduce stress and anxiety in situations.
• Stay calm and courteous, even if the customer exhibits unusual behaviour, focus on the service they need and how you can help.

Olfactory

Olfactory/Scent disabilities can involve the inability to sense smells or a hypersensitivity to odours and smells. A person with a smelling disability may have allergies to certain odours, scents or chemicals or may be unable to identify dangerous gases, smoke, fumes and spoiled food.

Touch

Touch/ Tactile disabilities can affect a person’s ability to sense texture, temperature, vibration or pressure. Touch sensations may be reduced or heightened resulting in a hypersensitivity to touch, temperature, or the opposite, numbness and the inability to feel touch sensations.

Taste

Taste disabilities can limit the experience of the four primary taste sensations; sweet, bitter, salty and sour. A person with a taste disability may be unable to identify spoiled food or noxious substances.

Other

Other disabilities may result from a range of other conditions, accidents, illnesses and diseases including ALS, asthma, diabetes, cancer, HIV/AIDs, environmental sensitivities, seizure disorders, heart disease, stroke and joint replacement. Disabilities are not always visible or easy to distinguish.

It is important to always use all efforts and best judgement to preserve the dignity and independence of an individual.

13. Non-Compliance/Consequences

Failure to comply with this policy may result in disciplinary action up to and including termination.

Note: This policy is applied in conjunction with the Accommodation policies in Human Resources and the Student Success Network.

Associated Documentation

• Michener shall, upon request, supply a copy of the policies, practices and procedures required under the Ontario Regulation 429/07 – Accessibility Standards for Customer Service to any person.
•  To review the Accessibility for Ontarians with Disabilities Act, Ontario Regulation 429/07 in its entirety, please visit: Ontario Regulation 429/07

Revision History