HR Accessibility Policy
This policy is intended to meet the requirements of the Integrated Accessibility Standards, Ontario Regulation 191/11 for the Employment Standard set forth under the Accessibility for Ontarians with Disabilities Act, 2005. This policy applies to the provision of accessible employment services for persons with disabilities.
All employment services provided by NAL INSURANCE INC. shall follow the principles of dignity, independence, integration and equal opportunity.
In accordance with the Integrated Accessibility Standards, Ontario Regulation 191/11, this policy addresses the following:
- A. General Requirements
- B. Recruitment, Assessment and Selection
- C. Accessible Formats and Communication Supports for Employees
- D. Workplace Emergency Response Information
- E. Documented Individual Accommodation Plans
- F. Performance Management and Career Development and Advancement
- G. Return to Work
- H. Redeployment
- I. Review
A. General Requirements
General requirements that apply across all of the five (5) standards (information and communication, employment, transportation, design of public spaces, and customer service) are outlined as follows.
Establishment of Accessibility Policies and Plans
NAL INSURANCE INC. will develop, implement and maintain policies governing how it will achieve accessibility through these requirements.
NAL INSURANCE INC. will provide training for its employees and volunteers regarding the IASR and the Ontario Human Rights Code as they pertain to individuals with disabilities. Training will also be provided to individuals who are responsible for developing NAL INSURANCE INC.’s corporate policies, and all other persons who provide services on behalf of NAL INSURANCE INC.
Training will be provided as soon as is reasonably practicable. Training will be provided on an ongoing basis to new employees and as changes to NAL INSURANCE INC.’s accessibility policies occur.
B. Recruitment, Assessment and Selection
NAL INSURANCE INC. will notify employees and the public about the availability of accommodations for job applicants who have disabilities. Applicants will be informed that these accommodations are available, upon request, for the interview process and for other candidate selection methods. Where an accommodation is requested, NAL INSURANCE INC. will consult with the applicant and provide or arrange for suitable accommodation.
Successful applicants will be made aware of NAL INSURANCE INC.’s policies and supports for accommodating people with disabilities.
C. Accessible Formats and Communication Supports for Employees
NAL INSURANCE INC. will ensure that employees are aware of our policies for employees with disabilities and any changes to these policies as they occur.
If an employee with a Disability requests it, NAL INSURANCE INC. will provide or arrange for the provision of accessible formats and communication supports for the following:
- Information needed in order to perform his/her job; and
- Information that is generally available to all employees in the workplace.
All employees at NAL INSURANCE INC. are given the corporate policies and the duty manual specific to their jobs on the first day. These policies and manuals are reviewed by management every year with employees. Should an employee require a different accessible format i.e. bigger font size, this will be made available to them.
NAL INSURANCE INC. will consult with the employee making the request to determine the best way to provide the accessible format or communication support.
D. Workplace Emergency Response Information
Where required, NAL INSURANCE INC. will create individual workplace emergency response information for employees with disabilities. This information will take into account the unique challenges created by the individual’s Disability and the physical nature of the workplace, and will be created in consultation with the employee.
This information will be reviewed when:
- The employee moves to a different physical location in the organization;
- The employee’s overall accommodation needs or plans are reviewed; and/or
- NAL INSURANCE INC. reviews general emergency response policies.
F. Performance Management and Career Development and Advancement
NAL INSURANCE INC. will consider the accessibility needs of employees with disabilities when implementing performance management processes, or when offering career development or advancement opportunities.
Individual accommodation plans will be consulted, as required.
G. Return to Work
NAL INSURANCE INC. will develop and implement return to work processes for employees who are absent from work due to a Disability and require Disability-related accommodations in order to return to work. The plan will be customised for each individual circumstance to ensure the employee returning to wok has their specific Disability adequately accommodated.
The accessibility needs of employees with disabilities will be taken into account in the event of redeployment.
Individual accommodation plans will be consulted, as required.
This policy will be reviewed regularly to ensure that it is reflective of NAL INSURANCE INC.’s current practices as well as legislative requirements.
Customer Service Accessibility Policy
This policy is intended to meet the requirements of the Customer Service Standards included in the Integrated Accessibility Standards under the Accessibility for Ontarians with Disabilities Act, 2005. It applies to the provision of goods and services to the public or other third parties, not to the goods themselves.
All services provided by NAL INSURANCE INC. shall follow the principles of dignity, independence, integration and equal opportunity.
Assistive Device – Is a technical aid, communication device or other instrument that is used to maintain or improve the functional abilities of people with disabilities. Personal assistive devices are typically devices that customers bring with them such as a wheelchair, walker or a personal oxygen tank that might assist in hearing, seeing, communicating, moving, breathing, remembering and/or reading.
Disability – The term disability as defined by the Accessibility for Ontarians with Disabilities Act, 2005, and the Ontario Human Rights Code, refers to:
- 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 on a wheelchair or other remedial appliance or device;
- A condition of mental impairment or a developmental disability;
- A learning disability, or 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.
Guide Dog – Is 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.
Service Animal – an animal is a service animal for a person with a Disability if:
- 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;
- A member of the College of Chiropractors of Ontario;
- A member of the College of Nurses of Ontario;
- A member of the College of Occupational Therapists of Ontario;
- A member of the College of Optometrists of Ontario;
- A member of the College of Physicians and Surgeons of Ontario;
- A member of the College of Physiotherapists of Ontario;
- A member of the College of Psychologists of Ontario; or
- A member of the College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario.
Service Dog – As reflected in Health Protection and Promotion Act, Ontario Regulation 562 a dog other than a Guide Dog for the blind is a service dog if:
- It is readily apparent to an average person that the dog functions as a service dog for a person with a medical Disability; or
- The person who requires the dog can provide on request a letter from a physician or nurse confirming that the person requires a service dog.
Support Person – a support person means, in relation to a person with a Disability, another person who accompanies him or her in order to help with communication, mobility, personal care, medical needs or access to goods and services.
In accordance with the Customer Service Standards, this policy addresses the following:
- A. The Provision of Goods and Services to Persons with Disabilities;
- B. The Use of Assistive Devices
- C. The Use of Guide Dogs, Service Animals and Service Dogs
- D. The Use of Support Persons
- E. Notice of Service Disruptions
- F. Customer Feedback
- G. Training
- H. Notice of Availability and Format of Required Documents
A. The Provision of Goods and Services to Persons with Disabilities
NAL INSURANCE INC. will 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;
- Allowing customers with disabilities to do things in their own ways, at their own pace when accessing services as long as this does not present 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;
- Taking into account individual needs when providing services; and
- Communicating in a manner that takes into account the customer’s Disability.
B. The Use of Assistive Devices
Customer’s Own Assistive Device(s)
Persons with disabilities may use their own Assistive Devices as required when accessing services provided by NAL INSURANCE INC.
In cases where the Assistive Device presents a safety concern or where accessibility might be an issue, other reasonable measures will be used to ensure the access of services. For example, where elevators are not present and where an individual requires Assistive Devices for the purposes of mobility, service and client meetings will be provided in a location that meets the needs of the customer.
C. Guide Dogs, Service Animals and Service Dogs
A customer with a Disability that is accompanied by Guide Dog, Service Animal or Service Dog will be allowed access to premises that are open to the public unless otherwise excluded by law. This includes meeting areas with NAL agents and NAL staff. “No pet” policies do not apply to Guide Dogs, Service Animals and/or Service Dogs.
Recognizing a Guide Dog, Service Dog and/or Service Animal:
If it is not readily apparent that the animal is being used by the customer for reasons relating to his or her Disability, NAL INSURANCE INC. may request verification from the customer.
Care and Control of the Animal:
The customer who is accompanied by a Guide Dog, Service Dog and/or Service Animal is responsible for maintaining care and control of the animal at all times.
If a health and safety concern presents itself for example in the form of a severe allergy to the animal, NAL INSURANCE INC. will make all reasonable efforts to meet the needs of all individuals.
D. The Use of Support Persons
If a customer with a Disability is accompanied by a Support Person, NAL INSURANCE INC. will ensure that both persons are allowed to enter the premises together or be on a phone call together and that the customer is not prevented from having access to the Support Person.
In situations where confidential information might be discussed, consent will be obtained from the customer and Support Person, prior to any conversation where confidential information might be discussed.
E. Notice of Disruptions in Service
Service disruptions may occur due to reasons that may or may not be within the control or knowledge of NAL INSURANCE INC. In the event of any temporary disruptions to facilities or services that customers with disabilities rely on to access or use NAL INSURANCE INC.’s services, reasonable efforts will be made to provide advance notice. In some circumstances such as in the situation of unplanned temporary disruptions, advance notice may not be possible.
In the event that a notification needs to be posted the following information will be included unless it is not readily available or known:
- Services that are disrupted or unavailable;
- Reason for the disruption;
- Anticipated duration; and
- A description of alternative services or options.
When disruptions occur NAL INSURANCE INC. will provide notice by:
- contacting customers with appointments;
- verbally notifying customers when they are making an appointment; or
- by any other method that may be reasonable under the circumstances.
F. Customer Feedback
NAL INSURANCE INC. shall provide customers with the opportunity to provide feedback on the service provided to customers with disabilities. Information about the feedback process will be readily available to all customers and notice of the process will be made available via the website. Feedback forms along with alternate methods of providing feedback such as verbally or written, will be available upon request.
Customers can submit feedback to:
361 Dufferin Ave. London, ON N6B 1Z5
Customers who wish to provide feedback can do so verbally or by completing an onsite customer feedback form to any NAL INSURANCE INC. employee.
Customers who provide formal feedback will receive acknowledgement of their feedback, along with any resulting actions based on concerns or complaints that were submitted.
Training will be provided to:
- Every person who is an employee of NAL INSURANCE INC.
- Every person who participates in developing the provider’s policies.
- Every other person who provides services on behalf of NAL INSURANCE INC.
Regardless of the format, training will cover the following:
- A review of the purpose of the Accessibility for Ontarians with Disabilities Act, 2005.
- A review of the requirements of the Customer Service Standards.
- Instructions on how to interact and communicate with people with various types of disabilities.
- Instructions on how to interact with people with disabilities who:
- use Assistive Devices;
- require the assistance of a Guide Dog, Service Dog or other Service Animal; or
- require the use of a Support Person
- Instructions on what to do if a person with a Disability is having difficulty accessing your services.
- NAL INSURANCE INC.’s policies, procedures and practices pertaining to providing accessible customer service to customers with disabilities.
NAL INSURANCE INC. will provide training as soon as practicable. Training will be provided to new employees, agents and/or contractors. Revised training will be provided in the event of changes to legislation, procedures, policies, and/or practices.
This policy and its related procedures will be reviewed as required in the event of legislative changes, or changes to company procedures.