Accessibility

The Printing House Ltd^™ (TPH^®) is committed to providing accessible customer service to people with disabilities and ensuring our goods and services are offered in a way that respects both their dignity and independence. People with disabilities will have the same opportunity to access TPH^®‘s goods and services with the same quality, timeline and in a similar way as other customers.

Providing Goods & Services to People with Disabilities

The Printing House Ltd^™ is committed to excellence in serving all customers including people with disabilities and we will carry out our functions and responsibilities in the following areas:

Communication

• We will communicate with persons with disabilities in ways that take into account their disability.
• We will train our employees who communicate with customers on how to interact and communicate with people with various types of disabilities.

Telephone Services

• We are committed to providing fully accessible telephone service.
• We will train our employees to communicate with customers over the telephone in clear and plain language and to speak clearly and slowly.
• We will offer to communicate with customers by email and/or relay services if telephone communication is not suitable to their communication needs or is not available.

Assistive Devices

• We are committed to serving people with disabilities who use assistive devices to obtain, use or benefit from our goods and services.
• We will ensure that our employees are trained and familiar with the various assistive devices that may be used by our customers with disabilities while accessing our goods and/or services.

Billing

• We are committed to providing accessible invoices to all of our customers. For this reason, invoices will be provided in the following formats upon request: hard copy, large print and/or email.
• We will answer any questions customers may have about the content of their invoice in person, by telephone or by email.

Use of service animals

The Printing House Ltd^™ is committed to welcoming people with disabilities who are accompanied by a service animal on the parts of our premises that are open to the public and other third parties. We will also ensure that our employees who deal with the public are appropriately trained in how to interact with people with disabilities who are accompanied by a service animal.

Use of support person

The Printing House Ltd^™ is committed to welcoming people with disabilities who are accompanied by a service person on the parts of our premises that are open to the public and other third parties. We will also ensure that our employees who deal with the public are appropriately trained in how to interact with people with disabilities who are accompanied by a service person.

Notice of temporary disruption

TPH^® will provide customers with notice in the event of a planned or unexpected disruption to the facilities or services usually used by people with disabilities to access our goods and services. The notice will include information about the reason for the disruption, the anticipated duration and a description of alternatives facilities or services if available. We may not be able to give adequate notice in case of an unexpected, emergency or temporary disruption.

In order to make information accessible, signs and printed notices will be clearly laid out and of sufficient size to be easily readable.

When appropriate, notices will be posted on the company’s website. Signs will be displayed prominently at public entrances, service counters and/or the reception area of TPH^® locations.

Training for TPH^® employees

The Printing House Ltd^™ will provide training to all employees, volunteers and others who deal with the public on our behalf and all those who are involved in the development and approval of customer service policies, practices and procedures. Training will be provided as part of an employee’s orientation program, and will occur no later than 14 days after hire. Employees will be trained on the policies, practices and procedures that affect the way goods and services are provided to people with disabilities. Training will occur on an ongoing basis when changes are made to these policies, practices and procedures.

Training will include the following topics:

• A review of the purposes of the customer service policy for providing goods and services to people with disabilities.
• How to interact and communicate with people with various types of disabilities.
• How to interact with persons with disabilities who use assistive devices or require the assistance of a service animal or a support person.
• What to do if a person with a disability is having difficulty in accessing TPH^®‘s goods and services.
• TPH^®‘s practices and procedures relating to the Customer Service Standard

Note: for Ontario Employees training will also include a review of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard.

Feedback Process

At TPH^®, we aim to exceed all of our customers’ expectations and this includes instances in which we’re serving customers with disabilities. Comments from the public on our services regarding how well those expectations are being met are welcome and appreciated.

Feedback regarding the way TPH^® provides goods and services to people with disabilities can be made in person, by telephone, mail, email or any other reasonable method. All feedback will be directed to and reviewed by the Office of the President. Customers can expect a response within two business days.

Modifications to this or other Policies

We are committed to developing customer service policies that respect and promote the dignity and independence of persons with disabilities. Therefore, no changes will be made to this policy before considering the impact on people with disabilities.

Any policy of The Printing House Ltd^™ that does not respect and promote the dignity and independence of persons with disabilities will be modified or removed.

Questions about this Policy

If anyone has a question about this policy or if the purpose of a policy is not understood, an explanation will be provided by the Manager at any TPH^® location or can be directed to the Office of the President.

TPH^® Integrated Accessibility Standards (IAS) Policy

The following policy has been established by The Printing House Ltd^™ (TPH^®) to govern the provision of services with Regulation 191/11, “Integrated Accessibility Standards” (“Regulation”) under the Accessibility for Ontarians with Disabilities Act, 2005.

These standards are developed to break down barriers and increase accessibility for persons with disabilities in the areas of information, communications and employment.

Commitment

TPH^® is committed to treating all people in a way that allows them to maintain their dignity and independence. We believe in integration and equal opportunity. We are committed to meeting the needs of persons with disabilities in a timely manner, and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the Accessibility for Ontarians with Disabilities Act. The Integrated Accessibility Standards Policy will be implemented in accordance with the time frames established by the Regulation.

Accessibility Plan

TPH^® will develop, maintain and document an Accessibility Plan outlining our strategy to prevent and remove barriers from our workplace and to improve opportunities for persons with disabilities.

The Accessibility Plan will be reviewed and updated at least once every five years, and will be posted on the The Printing House’s website. Upon request, TPH^® will provide a copy of the Accessibility Plan in an accessible format.

Training for TPH^® Employees and Volunteers

TPH^® will ensure that training is provided on the requirements of the accessibility standards referred to in the Regulation and continue to provide training on the Human Rights Code as it pertains to persons with disabilities, to: all employees and volunteers; all persons who participate in developing The Printing House’s policies; and, all other persons who provide goods, services or facilities on behalf of the The Printing House. The training will be appropriate to the duties of the employees, volunteers and other persons. Employees will be trained when changes are made to the accessibility policy. New employees will be trained during their orientation program, as soon as practicable. TPH^® will keep a record of the training it provides.

IAS Information and Communications Standards

Feedback

TPH^® will continue to ensure that its process for receiving and responding to feedback is accessible to persons with disabilities by providing, or arranging for the provision of, accessible formats and communications supports, upon request.

Commitment

Upon request, TPH^® will provide, or arrange for the provision of accessible formats and communication supports for persons with disabilities in a timely manner that takes into account the person’s accessibility needs due to disability. TPH^® will consult with the person making the request in determining the suitability of an accessible format or communication support. TPH^® will also notify the public about the availability of accessible formats and communication supports.

Accessible Websites & Web Content

TPH^® will ensure that our Internet websites, including web content, conform to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, at Level AA except where this is impracticable.

IAS Employment Standards

Recruitment

TPH^® will notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment process.

Recruitment, Assessment or Selection Process

TPH^® will notify job applicants, when they are individually selected to participate further in an assessment or selection process that accommodations are available upon request in relation to the materials or processes to be used. If a selected applicant requests an accommodation, TPH^® will consult with the applicant and provide, or arrange for the provision of, a suitable accommodation in a manner that takes into account the applicant’s accessibility needs due to disability.

Notice to Successful Applicants

When making offers of employment, TPH^® will notify the successful applicant of its policies for accommodating employees with disabilities.

Informing Employees of Supports

TPH^® will continue to inform its employees of its 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 practicable after commencing employment.

Accessible Formats & Communication Supports for Employees

Upon the request of an employee with a disability, TPH^® will consult with the employee to provide, or arrange for the provision of, accessible formats and communication supports for Information that is needed to perform his/her job, and information that is generally available to other employees. In determining the suitability of an accessible format or communication support, TPH^® will consult with the employee making the request.

Workplace Emergency Response Information

TPH^® will provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary, and if TPH^® is aware of the need for accommodation due to the employee’s disability. TPH^® will provide this information as soon as practicable after becoming aware of the need for accommodation.

Where the employee requires assistance, TPH^® will, with the consent of the employee, provide the workplace emergency response information to the person designated by TPH^® to provide assistance to the employee.

TPH^® will review the individualized workplace emergency response information when the employee moves to a different location in the organization, when the employee’s overall accommodations needs or plans are reviewed.

Documented Individual Accommodation Plans

TPH^® will maintain a written process for the development of documented individual accommodation plans for employees with disabilities.

If requested, information regarding accessible formats and communications supports provided will also be included in individual accommodation plans.

In addition, the plans will include individualized workplace emergency response information (where required), and will identify any other accommodation that is to be provided.

Return to Work Process

TPH^® maintains a documented return to work process for its employees who have been absent from work due to a disability and who require disability-related accommodations in order to return to work.

The return to work process outlines the steps TPH^® will take to facilitate the return to work and will include documented individual accommodation plans as part of the process.

This return to work process will not replace or override any other return to work process created by or under any other statute (ie., the Workplace Safety Insurance Act, 1997).

Career Development, Performance Management and Redeployment

TPH^® will take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when conducting performance management, providing career development and advancement to employees, or when redeploying employees.

Questions About This Policy

This policy has been developed to break down barriers and increase accessibility for persons with disabilities in the areas of information and communications and employment. If anyone has a question about the IAS policies, or if the purpose of a policy is not understood, an explanation will be provided by the Office of the President. Questions can be directed to president@tph.ca.

Section 3:  Establishment of Accessibility Policies

(1) Every obligated organization shall develop, implement and maintain policies governing how the organization achieves or will achieve accessibility through meeting its requirements under the accessibility standards referred to in its Regulation.

Actions:

• Attended policy workshop (March 26, 2013)
• Developed draft policy.
• Draft policy for IAS standards and submit for approval.
• Policy for IAS standards approved.

Status:

• Completed

Compliance Date:

• January 1, 2014

Section 4: Accessibility Plans

(1) Large organizations shall,

• Establish, implement, maintain and document a multi-year accessibility plan which outlines the organization’s strategy to prevent and remove barriers and meets its requirements under this regulation:
• Post the accessibility plan on their website, if any, and provide the plan in an accessible format upon request;
• Review and update the accessibility plan at least once every 5 years

Actions:

• Attended multi-year accessibility workshop (March 26, 2013)
• Create and implement plan template to track actions and progress
• Source and engage consultants to review plan and provide feedback on plan (Completed December 16, 2013)
• Identify barriers to accessibility
• Engage IT Department for review of WCAG 2.0 requirements (Completed June 9^th 2013)
• Plan to be reviewed on an ongoing basis until all requirements have been met.

Status:

• Completed

Compliance Date:

• January 1, 2014

Section 7: Training

(1) every obligated organization shall ensure that training is provided on the requirements of the accessibility standards referred to in this Regulation and on the Human Rights Code as it pertains to personas with disabilities to,

• All employees & volunteers
• All persons who participate in developing the organizations policies and
• All other persons who provide goods, services or facilities on behalf of the organization

Actions:

• Assess and source training vendors and programs
• Assess the level of training required for all employees and volunteers
• Develop a training plan (March 31, 2014)
• Roll out training and ensure ongoing training is provided.

Status:

• Ongoing

Compliance Date:

• January 1, 2015

Section 11: Feedback

(1) Every obligated organization that has processes for receiving and responding to feedback shall ensure that the processes are accessible to persons’ with disabilities by providing or arranging for accessible formats and communications supports, upon request.

Actions:

• Identify and review all feedback processes in place (formal, informal, internal & external)
• Consider the formats that may be requested and how TPH will respond.

Status:

• Ongoing

Compliance Date:

• January 1, 2015
  

Section 12: Accessible Formats & Communication Supports (AF&CS)

(1) Except as otherwise provided, every obligated organization shall upon request provide or arrange for the provision of accessible formats and communication supports for persons with disabilities

• in a timely manner that takes into account the person’s accessibility needs due to disability and
• at a cost that is not more than the regular cost charged to other persons

(2) The obligated organization shall consult with the person making the request in determining the suitability of an accessible format or communication support

(3) Every obligated organization shall notify the public about the availability of accessible formats and communication supports.

Actions:

• Consider what these requests may be and who may be likely to receive them.
• Plan what additional tools and training may be needed.
• Ensure Managers know how to obtain, implement and use AF & CS.
• Ensure there is a process for timely responses to AF&CS requests
• Communicate to staff & Management there is no charge for AF&CS.
• Develop a protocol for dealing with situations where an amenable solution is not able to be found.
• Include AF&CS request information is available online and in-branch
• Review marketing and advertising materials for opportunities and include the message

Status:

• Ongoing

Compliance Date:

• January 1, 2016

Section 14: Accessible Websites & Web Content

(1) Designated large organizations shall make their internet websites and web content conform to WCAG 2.0 , initially at a Level A and increasing to Level AA and shall do so in accordance with the schedule set out in this section.

Actions:

• Review WCAG Compliance Guidelines and conduct (Gap Analysis – Complete Oct. 3, 2013)
• Inform programmers on WCAG 2.0 A requirements
• Pursue WCAG 2.0 AA compliance

Status:

• Ongoing

Compliance Date:

• January 1, 2014
• New internet sites & web content WCAG 2.0 A January 1, 2021
• All websites & web content conform to WCAG 2.0 AA

Section 22: Recruitment General

(1) Every employer shall notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment processes

Actions:

• Identify steps in current recruitment process that require this messaging.
• Develop an approved message for communicating the availability of accommodations for applicants with disabilities.

Status:

• Ongoing

Compliance Date:

• January 1, 2016

Section 23: Recruitment Assessment or Selection Process

(1) During a recruitment process, an employer shall notify job applicants, when they are individually selected to participate in an assessment or selection process, that accommodations are available upon request in relation to the material or processes to be used.

(2) If a selected applicant requests an accommodation, the employer shall consult with the applicant and provide or arrange for the provision of a suitable accommodation in a manner that takes into account the applicant’s accessibility needs due to disability.

Actions:

• Assess the type of accommodation requests that may be made during the recruitment process, create a plan to deal with each type of request.
• Designate an accommodation contact for the Managers to work with on requests and train Managers on appropriate responses to accommodation requests and supports.
• Create a resource guide identifying personal and technical supports.
• Create routines for acquiring supports as needed.
• Identify the likely barriers for applicants (interview locations, testing formats, time frames, telephone/video interviews)

Status:

• Ongoing

Compliance Date:

• January 1, 2016

Section 24: Notice to Successful Applicants

(1) Every employer shall, when making offers of employment, notify the successful applicant of its policies for accommodating employees with disabilities.

Actions:

• Review how offers of employment are made.
• Consider options for communicating policy at time of offer.

Status:

• Ongoing

Compliance Date:

• January 1, 2016

Section 25: Informing Employees of Supports

(1) Every employer shall inform its employees of its policies used to support it employees with disabilities, including, but not limited to, policies on the provision of job accommodations that take into account an employee’s accessibility needs due to disability.

(2) Employers shall provide the information required under this section to new employees as soon as is practicable after they begin their employment

(3) Employers shall provide updated information to its employees whenever there is a change to existing policies on the provision of job accommodations that take into account an employee’s accessibility needs due to disability.

Actions:

• Review & update policies as necessary including website and handbook.
• Management will be updated on policy changes through regular management meetings
• Ensure policies are covered in Orientation process and be consistent in timing for Employee Handbook distribution.

Status:

• Ongoing

Compliance Date:

• January 1, 2016

Section 26: Accessible Formats & Communication Supports for Employees

(1) In addition to its obligations under section 12, where an employee with a disability so requests it, every employer shall consult with the employee to provide or arrange for the provision of accessible formats and communication supports for:

• information that is needed in order to perform the employee’s job; and
• information that is generally available to employees in the workplace

(2) The employer shall consult with the employee making the request in determining the suitability of an accessible format or communication support.

Actions:

• Review and assess job descriptions, standard operating procedures, and other documents and manuals that employees need in order to perform their job.
• Identify most commonly requested accessible formats and ensure these documents are able to be made available or are available.
• Develop a process for employee consultation to determine what supports & formats can be offered.
• Create protocol for compromise where an amenable solution is not found.

Status:

• Ongoing

Compliance Date:

• January 1, 2016

Section 27: Workplace Emergency Response

(1) Every employer shall provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary and the employer is aware of the need for accommodation due to the employee’s disability.

(2) If an employee who received individualized workplace emergency response information requires assistance and with the employee’s consent, the employer shall provide the workplace emergency response information to the person designated by the employer to provide the employee assistance

(3) Employers shall provide the information required under this section as soon as is practicable after the employer becomes aware of the need for accommodation due to the employee’s disability.

(4) Every employer shall review the individualized workplace emergency response information:

• when the employee moves to a different location in the organization,
• when the employee’s overall accommodations needs or plans are reviewed
• when the employer reviews it general emergency response policies

Actions:

• Individualized emergency response information has been collected for Employees who self-identified as required assistance during emergencies.
• Employees who have self-identified are consulted on appropriate persons for workplace emergency assistance.
• Individualized workplace emergency response plans are completed within 30 days of the employee making the request.
• Ensure Managers are aware of the circumstances under which individualized workplace emergency response plans are required.

Status:

• Ongoing

Compliance Date:

• January 1, 2012

Section 28: Documented Individual Accommodation Plans

(1) Employers shall develop and have in place a written process for the development of documented individual accommodation plans for employees with disabilities.

(2) The process for the development of documented individual accommodation plans shall include the following elements:

1. The manner in which an employee requesting accommodation can participate in the development of the individual accommodation plan.
2. The means by which the employee is assessed on an individual basis.
3. The manner in which the employer can request an evaluation by an outside medical or other expert at the employer’s expense, to determine if and how the accommodation can be achieved
4. The manner in which the employee can request the participation of a representative from the workplace where the employee is not represented by a bargaining agent, in the development of the accommodation plan.
5. The steps taken to protect the privacy of the employee’s personal information.
6. The frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done.
7. If an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee.
8. The means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs due to disability.

Actions:

• Determine who will be involved in this process.
• Review the return to work accommodation process as a potential model.
• Implement updated process for documenting and managing individual accommodation plans.
• Develop areas of internal expertise and/or utilize external expertise in order to carry out the assessment process.
• Create a process to ensure individual accommodation plans will be reviewed and updated annually at a minimum.
• Create protocol for compromise and explanation where an accommodation plan is denied or an amenable solution is not found.

Status:

• Ongoing

Compliance Date:

• January 1, 2016

Section 29: Return to Work Process

(1) Every employer shall:

• develop and have in place a return to work process for its employees who have been absent from work due to a disability and require disability-related accommodations in order to return to work; and
• shall document the process.

(2) The return to work process shall:

• outline the steps the employer will take to facilitate the return to work of employees who were absent because of disability required them to be away from work, and
• use individual documented accommodation plans, as described in section 28, as part of the process.

(3) The return to work process referenced in this section does not replace or override any other return to work process created by or under any other statute.

Actions:

• Review current return to work process and conduct a gap analysis and recommendations.
• Update policy and procedure based on review.

Status:

• Ongoing

Compliance Date:

• January 1, 2016

Section 30: Performance Management

(1) An employer that uses performance management in respect of its employees shall take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when using its performance management process in respect of employees with disabilities.

Actions:

• Job performance is fully understood by all employees
• Undertake review of processes for all manner of performance management.
• Ensure Managers know how to obtain AF&CS related to the performance management process.
• Consider format changes and requests that may be made to accommodate individual accommodation plans and update processes as required.

Status:

• Ongoing

Compliance Date:

• January 1, 2016

Section 31: Career Development & Advancement

(1) An employer that provides career development and advancement to its employees shall take into account the accessibility needs of its employees with disabilities as well as any individual accommodation plans, when providing career development and advancement to its employees with disabilities.

Actions:

• Career development and advancement processes to consider the accessibility needs of employees with disabilities including individual accommodation plans.

Status:

• Ongoing

Compliance Date:

• January 1, 2016

Section 32: Redeployment

(1) An employer that uses redeployment shall take into account the accessibility needs of its employees with disabilities, as well as individual accommodation plans, when redeploying employees with disabilities.

Actions:

• Transfer process to consider accessibility for employees with disabilities including individual accommodation plan.
• Termination process to consider accessibility for employees with disabilities including individual accommodation plans.

Status:

• Ongoing

Compliance Date:

• January 1, 2016