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Corporate Policy Accessible Formats & Communication Supports

Policy No: G00-23
Effective Date: April 20, 2016

Tab: General Government
Section: General
Subject: Accessible Formats & Communication Supports

A. Purpose

This policy outlines the Region of Peel's (the Region's) responsibilities under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) specifically section 12 of the Integrated Accessibility Standards (IASR), Regulation 191/11, which requires that upon request, the Region shall provide or arrange for the provisions of accessible formats and communication supports for persons with disabilities as it relates to information about regional goods, services or facilities.

This policy is intended to provide staff with assistance in responding to requests for:

  • documents in accessible formats, and/or
  • information provided through or with a communication support.

This policy is also intended to ensure that Region shall meet the information and communication needs of all staff with disabilities as required under the IASR Employment Standards.

B. Scope

This policy applies to all Regional staff, volunteers, consultants and contractors who produce information and communication materials on behalf of the Region.

This policy shall be interpreted consistent with the:

In addition, this policy shall be interpreted consistent with the following policies and by-law:

C. Definitions

Accessible/Alternate Format - a medium and/or methodology that allows access to information in a manner other than how the format was originally delivered. These may include, but are not limited to, large print, recorded audio and electronic formats, and Braille.

Alternatives to standard print are often referred to as “accessible formats” and methods to assist with communication are referred to as “communication supports”.

Assistive Devices - technical aids, communication devices, or medical aids modified or customized for use in increasing, maintaining or improving the functional ability of a person with a disability. These may include, but are not limited to, wheelchairs, walkers, white canes, note taking devices, portable magnifiers, recording machines, assistive listening devices and personal oxygen tanks. A person with a disability may bring their own assistive devices or the devices may be available on the premises.

Barriers - obstacles that impede people with disabilities from fully participating in all aspects of society because of their disability. Barriers include attitude, technology, architectural/structural, information and communication, and systemic.

Communication Supports - tools to facilitate effective communications with persons with disabilities. These may include, but are not limited to, captions, text within images, plain language and sign language.

Disability - as defined in the Human Rights Code:

  • 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 coordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device;
  • a condition of mental impairment or a developmental disability;
  • a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
  • a mental disorder; or
  • an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997

Municipal Goods, Services or Facilities -goods, services or facilities provided by the Region or a third party service provider.

Third PartyService Provider - an individual, an agency or an organization that is responsible for delivering goods or services on behalf of the Region. These may include, but are not limited to, contractors and vendors.

D. Policy

  1. Staff shall utilize this policy to ensure that the Region meets the Information and Communication Supports needs of its staff and customers who use alternate methods to access information. Region must ensure that such accessibility is considered for its customers as well as staff when acquiring goods and delivering Regional programs and services.
  2. Staff shall consider accessibility of publications, presentations, tools, videos and documents produced during their design and development stages. All efforts must be made to develop publications, presentations, tools, videos or documents in such a way that it reduces barriers in the original source of publications, presentations, tools, videos and documents to provide an inclusive user experience.

  3. Processing Requests:

    Requests for an accessible format or communication support can be received by staff in person, by writing, by phone/TTY such as the call center or by electronic formats such as emails or service requests. Upon receipt of a request, staff will complete the Online Request Form.  A copy of the request is also forwarded to the Accessibility Planning Program for record keeping purposes.  

  4. Timeframe: 
     
    1. The timeframe to convert publications, presentations, tools, videos and documents into an accessible format or arranging for various Communication Supports, can vary depending on the type of the format requested. When staff receives a request, the size, complexity, quality of source publications, presentations, tools, videos or documentation, and the number of documents required conversion must be considered in determining the time frame to complete the conversion. Requests shall be completed in a timely manner.
       
    2. If a request is being made to access materials, which are part of public consultation and has a fixed timeframe for public to provide comments, staff must consider these times constrains, when processing requests. 
       
  5. Cost of Conversion: 
     
    1. When a member of the public requests a Regional document in an accessible format or information with a communication support, the department of origin is responsible for the cost of conversion, materials and distribution of information.
       
    2. Once the appropriate format or support is determined with the requestor, staff shall provide or arrange for the provision of the accessible formats and/or communication support for persons with disabilities.
       
    3. If a staff member determines that information is unconvertible, they shall, in consultation with their manager, provide the person requesting the information or communication with: 

      i. a written explanation as to why the information or communications are unconvertible; and,
      ii. a summary of the unconvertible information or communication. 
       
    4. When needed, the Accessibility Planning Program will assist program staff to help determine if information can be converted. 
       
  6. Monitoring/Contraventions: 

    Supervisors and managers shall monitor current practices to ensure compliance. Failure to comply with the AODA regulations may result in provincial administrative penalties and all efforts must be made to avoid such penalties.

E. Responsibilities 

  1. Program Areas: 

    When a member of the public requests a document in an accessible format or information with a communication support, the department or division of the original publications, presentations, tools, videos and documents is responsible for arranging for the accommodation and the costs associated with the accommodation, at no additional cost to the requester. 
     
  2. Accessibility Planning Program:

    a) Keeping a non-identifying log of information about requests received; 

    b) Monitoring compliance with this procedure on an annual basis; 

    c) Maintained a list of resources available to create accessible publications, presentations, tools, videos and documents. 
     
  3. Directors: 

    a) Creating and maintaining regional goods, services or facilities free from discrimination toward persons with disabilities; 

    b) Budgeting for the costs associated with accessible formats and Communication Supports of materials originating from their departments; 

    c) Monitoring situations where requests for accessible formats and Communication Supports have been made. 
     
  4. Managers and Supervisors: 

    a) Creating and maintaining regional goods, services or facilities free from discrimination toward persons with disabilities by making alternative formats available when requested;

    b) Ensuring staff are aware of this policy;

    c) Tracking costs associated with requests;

    d) Ensuring staff are providing residents and Regional staff with the requested accessible format and communication support. 
     
  5. Communications Staff: 

    a) Ensuring their client groups are aware of the Region of Peel obligations under the AODA and guide them to produce all outward facing and internal information releases, posted electronically or via printed hard copies, such as media releases, flyers, promotional and educational brochures etc. with accessibility built into the original source documents. 

    b) Ensuring that following best practices are considered by client groups when assisting clients with their communication requests:

    i. Use of clear and consistent language;
    ii. Provide sufficient color contrast for text and images;
    iii. Create consistent and clean layouts for printed content;
    iv. Ensure electronic information is created accessible within the source document: 
     
    • Alt tags are available on each photo
    • Consistent and clean layouts for content and navigation through all web pages
    • Mobile website should provide options of Readable PDF, HTML and/or TEXT with clear, concise language
    • Large print format by using the A- or A+ function located on each page of the Region of Peel website

APPROVAL SOURCE: CAO Directive 16-02
ORIGINAL DATE: April 20, 2016
LAST REVIEW DATE: April 20, 2016
Last Update: April 20, 2016
Effective Update: April 20, 2016
RESPONSIBILITY.: Corporate Services Department/Clerk's Division