Policy number: GC-4300-2013
Policy Title: Accessibility (AODA) Policy
Policy Owner: Chief, Equity & Inclusion Officer / Chief Human Resources Officer
Effective Date: December 2013
Last Revised: September 21, 2016
On this page:
- Purpose
- Application and Scope
- Definitions
- Principles
- Accountability and Compliance
- Rules
- Policy Revision Date
- Attachments
- Specific Links
1. Purpose
The purpose of this policy is to establish the College’s commitment and responsibility to comply with the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and its Integrated Accessibility Standards Regulation. It is intended to outline the guidelines for ensuring accessibility for individuals with disabilities in the College environment – students, employees and community. The College recognizes that individuals with disabilities should have the same opportunity of access to and benefit from goods, services, facilities, accommodation and employment as are provided to all Ontarians.
2. Application and Scope
This policy applies to all full-time and part-time students, employees and visitors to all campuses and areas of the College.
3. Definitions
“Employee” includes all employees of Mohawk College, including bargaining unit members, management and non-unionized employees.
“Student” is any person who is currently enrolled in a course or program at Mohawk College, or is a confirmed applicant.
“College Community” includes all students, employees, clients served by students, volunteers and visitors to the College.
“Disability” is determined by the Ontario Human Rights Code. It does not list all the conditions that may be considered a disability, or ‘handicap’ as it may be called. However, the Ontario Human Rights Commission follows certain guidelines to help determine whether a condition is considered a disability under 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.
“Accessible” is defined as any services or goods that are capable of being easily understood or appreciated; easy to get at; capable of being reached, or entered; obtainable.
“Essential requirements” of a course / program may include, but are not limited to, the knowledge and skills which must be acquired and / or demonstrated in order for a student to successfully meet the learning objectives of a course / program.
“Undue hardship” is defined by the Ontario Human Rights Code, as special or specified circumstances that partially or fully exempt a person / organization from performance of a legal obligation so as to avoid an unreasonable or disproportionate burden or obstacle. It is an obligation which is not in proportion to the reciprocal cost or benefit of the request. The OHRC prescribes three factors that are to be considered in assessing whether a requested accommodation would cause undue hardship. These are: cost; availability of outside sources of funding; and, health and safety requirements. There may be other factors that are relevant, including, but not limited to, the degree that an accommodation negatively impacts other students and employees. Concrete evidence is required to establish undue hardship.
4. Principles
Mohawk College acknowledges the right of all individuals, including those with disabilities, to an equal opportunity to experience success in their academic and/or employment endeavours with the College, as they apply to the provision of any and all services as indicated in the Ontario Human Rights Code.
The College recognizes that making successful learning and employment outcomes accessible to students and employees, respectively, is a shared responsibility and commitment on the part of the students and employees. This policy is articulated within the context of the shared values of Mohawk College that express a culture focused on students, employees and community.
Students and employees have a right to learn and work in an accessible, accountable and equitable environment. Failure to facilitate this may lead to legal actions or human rights challenges.
5. Accountability and Compliance
5.1 Accountability Framework
This policy has been approved by the Senior Leadership Team.
5.2 Compliance
The Mohawk Executive Group (MEG) oversees the accessibility mandate and is responsible for its overall implementation. The Chief Equity and Inclusion Officer and Chief Human Resources Officer are the leads responsible for developing and promoting the multi-year AODA Accessibility plan and developing and monitoring accessibility policies.
All members of the College community are responsible for fostering and championing an accessible environment.
5.3 Non-compliance Implications
The College’s failure to comply with applicable legislation may lead to legal action, including administrative penalties against the College depending on the severity of the impact of the contravention(s).
6. Rules
6.1 Compliance with Legislation
All College policies, procedures and practices regarding accessibility must comply with applicable federal and provincial legislation including, but not limited to, the Canadian Charter of Rights and Freedoms, the Ontario Human Rights Code, the Accessibility for Ontarians with Disabilities Act, and the Freedom of Information and Protection of Personal Privacy Act.
The Accessibility for Ontarians with Disabilities Act (AODA) Integrated Accessibility Standards Regulation includes 5 standards:
- General Accessibility for Persons with Disabilities;
- Information and Communication;
- Employment;
- Design of Public Spaces; and
- Customer Service.
6.2 Accommodations
Students and employees have a right to learn and work in an accessible and accountable environment. The College will make every effort to accommodate the particular needs of individuals with disabilities provided that:
6.2.1 The accommodation does not give rise to undue hardship, which would include:
- Altering the essential requirements of the program or course;
- Threatening the integrity of contracts of employment by significantly altering essential job requirements or responsibilities;
6.2.2 Where students or employees require accommodations, they fulfill their obligations by identifying their needs for accommodation, the reasons for them and the information necessary to assist the College in determining the nature of the accommodation required.
6.3 Academic and Employment Access
The College will monitor admissions policies and procedures to ensure that students with disabilities who are otherwise academically qualified are not excluded for reasons irrelevant to the essential requirements of the programs for which they are applying or in which they are enrolled.
The College will monitor employment postings to ensure that they reflect the essential requirements of the positions posted and do not contain any descriptors which directly or indirectly classify or indicate qualifications by prohibited grounds of discrimination under the Human Rights Code.
6.4 Physical and Technological Environments
The College will strive to ensure that its facilities are physically and technologically accessible, within the limits of physical and financial resources.
Mohawk College is responsible for providing accessible learning and working environments that include:
- The promotion of awareness of accessibility legislation and the elimination of biases or negative attitudes towards persons with disabilities,
- The provision of accommodations involving a collaborative process which recognizes the responsibilities of all of those involved:
- Accessible Learning Services (ALS) is responsible for coordinating and implementing provision of appropriate accommodations for students with disabilities.
- The Human Resources department is responsible for coordinating and implementing provision of accommodations for employees with disabilities in accordance with relevant legislation and/or collective agreement requirements.
6.5 Confidentiality
Mohawk College is concerned with protecting the privacy and confidentiality of individuals with disabilities. At the same time, Mohawk College needs sufficient information to reasonably evaluate and respond to a student/employee requests for accommodation. For this reason, students and employees are required to provide documentation noting the impact of their disability, their needs and restrictions. At times the accommodation process may require that a student disclose such information to employees and faculty, beyond Accessible Learning Services (ALS). All personal information disclosed to such employees or faculty shall be governed by the Mohawk College statement on Access to Information and Protection of Privacy.
6.6 Reporting
The College is responsible for completing and maintaining the multi-year accessibility plan that incorporates the AODA and IASR legislative requirements, achievements and future responsibilities, as well as a comprehensive annual Accessibility Compliance Report.
The services for students with disabilities are offered by Accessible Learning Services (ALS) and governed by Accessibility Fund for Students with Disabilities (AFSD), Ministry of Training, Colleges and Universities (MTCU) mandate; therefore ALS must meet comprehensive annual reporting requirements and specific obligations on service delivery to students.
Procedures governing the operation of ALS, as required under the MTCU mandate and for funding eligibility, are available online and in hard copy. Alternative formats available upon request.
7. Policy Revision Date
7.1 Revision Date
September 2019
7.2 Responsibility
The AODA Steering Committee, supported by the Accessibility Advisory Committee, is responsible for reviewing and making recommendations concerning implementation of this policy and /or associated procedures. Review will be accomplished in collaboration with the Chief Equity and Diversity Officer and Chief Human Resources Officer who are ultimately responsible for accessibility policies at the College.
8. Attachments
9. Specific Links
- CS-1317-2012 Harassment Policy
- GC-4301-1982 Human Rights Policy
- SS-3201-2013 Academic Accommodation for Students with Disabilities Policy
- Accessibility for Ontarians with Disabilities Act, 2005
- Accessibility Plan (2013-2015)
- Canadian Charter of Rights and Freedoms
- Freedom of Information and Protection of Personal of Personal Privacy Act
- Ministry of Community and Social Services: Customer Service Standards
- Ministry of Economic Development, Trade and Employment: Customer Service
- Ontario Human Rights Code
- Privacy and Confidentiality
- Web Content Accessibility Guidelines (WCAG) 2.0
Appendix A: Integrated Accessibility Standards
1. Introduction
Mohawk College is committed to the implementation of the Integrated Accessibility Standards Regulation 191/11 under the Accessibility for Ontarians with Disabilities Act 2005: Integrated Accessibility Standards. This Regulation establishes the standards for information and communications, employment and transportation for every organization that provides goods, services or facilities to the public. The College is obligated to have information and communication, employment and transportation policy, practices and procedures that are compliant with the Regulation.
- 1.1 The integrated accessibility standard regulation applies to the provision of information and communication, employment processes and transportation to members of the public, employees and students. This standard has a phased in approach and therefore parts of the standard will be added as deadlines for compliance are set and new regulations are implemented.
- 1.2 The information and communications standards do not apply to products and product labels, unconvertible information or communications, or information that the College does not control directly or indirectly through contractual relationship.
- 1.3 If Mohawk College determines that information or communications are unconvertible, the College shall provide the person requesting the information or communication with, an explanation as to why the information or communications are unconvertible; and a summary of the unconvertible information or communications. Information or communications are unconvertible if:
- It is not technically feasible to convert the information or communications; or
- The technology to convert the information or communication is not readily available.
2. Definitions
“Accessible” is defined as any services or goods that are capable of being easily understood or appreciated; easy to get at; capable of being reached, or entered; obtainable.
“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.
“Communication supports” may include, but are not limited to, captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communication.
“Communication” is the interaction between two or more persons or entities, or any combination of them, where information is provided, sent or received.
“Conversion ready” is an electronic or digital format that facilitates conversion into an accessible format.
“Disability” is determined by the Ontario Human Rights Code. It does not list all the conditions that may be considered a disability, or ‘handicap’ as it may be called. However, the Ontario Human Rights Commission follows certain guidelines to help determine whether a condition is considered a disability under 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.
“Educators” are employees who are involved in program or course design, delivery and instruction.
“Extranet website” is a controlled extension of the intranet, or internal network of an organization to outside users over the internet.
“Internet website” is a collection of related web pages, images, videos or other digital assets that are addressed relative to a common Uniform Resource Identifier (UDI) and is accessible to the public.
“Intranet website” is an organization’s internal website that is used to share privately and securely any part of the organization’s information or operational systems within the organization and includes extranet websites.
“Information” is data, facts and knowledge that exists in any format, including text, audio, digital or images, and that conveys meaning.
“Kiosk” is an interactive electronic terminal, including a point-of-sale device, intended for public use that allows users to access one or more services or products or both.
“Maintenance” means activities that are intended to keep existing public spaces and elements in existing public spaces in good working order or to restore the spaces or elements to their original condition, examples of which include painting and minor repairs.
“New internet website” is either a website with a new domain name or a website with an existing domain name undergoing a significant refresh.
“Off-street parking facilities” includes open area parking lots and structures intended for the temporary parking of vehicles by the public, whether or not the payment of a fee is charged and includes visitor parking spaces in parking facilities.
“Service 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;
- College of Chiropractors of Ontario;
- College of Nurses of Ontario;
- College of Occupational Therapists of Ontario;
- College of Optometrists of Ontario;
- College of Physicians and Surgeons of Ontario;
- College of Physiotherapists of Ontario;
- College of Psychologists of Ontario; or,
- College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario.
“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 or medical needs or with access to goods, services or facilities.
“Web Content Accessibility Guidelines (WCAG), 2.0” are dictated by the World Wide Web Consortium Recommendation, dated December 2008.
“Web page” is a non-embedded resource obtained from a single Uniform Resource Identifier (URI) using Hypertext Transfer Protocol (HTTP) and any other resources that are used in the rendering or intended to be rendered together with it by a user agent.
PART I – GENERAL ACCESSIBILITY
1. Accessible Plans
- Mohawk College has established and implemented a multi-year accessibility plan which is available on the Mohawk College website. The purpose of this document is to outline the College’s strategy to prevent and remove barriers. The plan is reviewed and updated every five years. An accessible version is provided on request.
- Mohawk College establishes reviews and updates the College accessibility plans in consultation with persons with disabilities and the College shall consult with an accessibility advisory committee on development and implementation of the Accessibility Plan.
- Mohawk College prepares an annual status report on the progress of measures taken to implement the strategy and posts the status report on the Mohawk College website. The report is provided in an accessible format upon request.
2. Procuring or Acquiring Goods, Services or Facilities
- Mohawk College incorporates accessibility criteria and features when procuring or acquiring goods, services or facilities, except where it is not practicable to do so.
- If Mohawk College determines that it is not practicable to incorporate accessibility criteria and features when procuring or acquiring goods, services or facilities, it shall provide, upon request to the Purchasing department, an explanation.
3. Self-Service Kiosks
Mohawk College incorporates accessibility features when designing, procuring or acquiring self-service kiosks. Options for assistance in accessibility will be provided at the kiosks.
4. Training
- Mohawk College provides training in respect of any changes to the policies on the requirements of the accessibility standards and on the Human Rights Code as it pertains to persons with disabilities to:
- All employees;
- All volunteers;
- All persons involved in developing customer service policies and procedures; and
- Every person who provides goods, services or facilities on behalf of the College.
- The training on the requirements of the Accessibility Standards and on the Human Rights Code is specific to the duties of the employees.
- Every person is trained as soon as practicable (during employees orientation);
- Mohawk College keeps a record of the training provided including the dates on which the training is provided and the number of individuals to whom it is provided.
PART II – INFORMATION AND COMMUNICATION STANDARDS
1. Accessible Formats and Communication Supports
- Mohawk College, upon request, provides or arranges 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 no more than the regular cost charged to other persons.
- Mohawk College consults with the person making the request in determining the suitability of an accessible format or communication support.
- Mohawk College notifies the public about the availability of accessible formats and communication supports via the Accessibility page on the website.
2. Emergency Procedures, Plans or Public Safety Information
- Mohawk College prepares emergency procedures, plans or public safety information and makes the information available to the public via the College public website, student portals, employee portals, signage and information kiosks throughout the College.
- If required to evacuate, Mohawk College ensures that individuals with disabilities are able to exit the College or exit particular facilities within the College safely. Mohawk College provides the information in an accessible format or with appropriate communication supports, as soon as practicable, upon request. Requests for accessible formats should be made through Security.
3. Accessible Websites and Web Content
Mohawk College makes their internet websites and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, initially at Level A and increasing to Level AA, to websites and web content, including web-based applications, that an organization controls directly or through a contractual relationship that allows for modification of the product; and all web content published on a website; and will do so in accordance with the following schedule:
- By January 1, 2014, new internet websites and web content on those sites must conform to WCAG 2.0 Level A.
- By January 1, 2021, all internet websites and web content must conform with WCAG 2.0 Level AA, other than:
- Success criteria 1.2.4 Captions (Live), and
- Success criteria 1.2.5 Audio Descriptions (Pre-recorded).
4. Educational and Training Resources and Materials, etc.
Mohawk College, if notification of need is given:
- Provides educational or training resources or materials in an accessible format that takes into account the accessibility needs due to a disability of the person with a disability to and to whom the material is to be provided by:
- Procuring through purchase or obtaining by other means an accessible or conversion ready electronic format of educational or training resources or materials, where available, or
- Arranging for the provision of a comparable resource in an accessible or conversion ready electronic format, if educational or training resources or materials cannot be procured, obtained by other means or converted into an accessible format.
- Provides student records and information on program requirements, availability and descriptions in an accessible format to persons with disabilities.
5. Training
- Mohawk College provides Educators with accessibility awareness training related to accessible program or course delivery and instruction.
- Mohawk College provides training on the requirements of the IASR and on the Ontario Human Rights Code as it pertains to people with disabilities.
- Mohawk College keeps a record of the training provided, including the dates on which the training is provided and the number of individuals to whom it is provided.
PART III – EMPLOYMENT STANDARDS
1. Workplace Emergency Response Information
- Mohawk College provides 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. A Personal Emergency Plan (PEP) can be requested through the employee’s manager. See Emergency Preparedness and Response Procedure.
- If an employee who receives individualized workplace emergency response information requires assistance and with the employee’s consent, Mohawk College shall provide the workplace emergency response information to the person designated by the College to provide assistance to the employee. The emergency response plans are adjusted according to the personal emergency plan requirements.
- Mohawk College’s Security Office provides the information for the personal emergency plan as soon as practicable after the College becomes aware of the need for accommodation due to the employee’s disability.
- Where required, Personal Emergency Plans will be practiced and reviewed with stakeholders to ensure the safety of the employee is protected.
- The Personal Emergency Plan will be stored in the database in the Human Resources office. Mohawk College reviews the individualized workplace emergency response information (PEP) when:
- The employee moves to a different location in the organization;
- The employee’s overall accommodations needs or plans are reviewed; and
- The College reviews its general emergency response policies.
IV – DESIGN OF PUBLIC SPACES STANDARDS
1. Outdoor Public Use Eating Areas
Mohawk will ensure that where outdoor public use eating areas are constructed or redeveloped and maintained, the outdoor public use eating areas will meet the following requirements:
- A minimum of 20 per cent of the tables that are provided will be accessible to persons using mobility aids by having knee and toe clearance underneath the table and in no case shall there be less than one table in an outdoor public use eating area that meets this requirement.
- The ground surface leading to and under tables that are accessible to persons using mobility aids will be level, firm and stable.
- Tables that are accessible to persons using mobility aids will have clear ground space around them that allows for a forward approach to the tables.
2. Exterior Paths of Travel
- Mohawk will ensure that any exterior paths of travel that are constructed or redeveloped and maintained will meet all legislated technical requirements, including requirements for an exterior path of travel with a ramp, stairs, curb ramps and depressed curbs.
- Where new pedestrian signals are being installed or existing pedestrian signals are being replaced at a pedestrian crossover, they will be accessible pedestrian signals.
- When constructing new or redeveloping existing exterior paths, Mohawk shall consult on the design and placement of rest areas along the exterior path of travel and shall do so with the public and persons with disabilities.
3. Accessible Parking
3.1 Types of Accessible Parking Spaces
When constructing new or redeveloping off-street parking facilities, Mohawk will provide the following two types of parking spaces for the use of persons with disabilities:
- A. Type A, a wider parking space which has a minimum width of 3,400 mm and signage that identifies the space as “van accessible”.
- B. Type B, a standard parking space which has a minimum width of 2,400 mm.
3.2 Access Aisles
- The space between parking spaces that allows persons with disabilities to get in and out of their vehicles will be provided for all parking spaces for the use of persons with disabilities in off-street parking facilities.
- Access aisles may be shared by two parking spaces for the use of persons with disabilities in an off-street parking facility and will meet the following requirements:
- A. They will have a minimum width of 1,500 mm.
- B. They will extend the full length of the parking space.
- C. They will be marked with high tonal contrast diagonal lines, which discourages parking in them, where the surface is asphalt, concrete or some other hard surface.
3.3 Minimum Number and Type of Accessible Parking Spaces
- Off-street parking facilities will have a minimum number of parking spaces for the use of persons with disabilities, in accordance with the legislative requirements.
- If Mohawk is to provide more than one off-street parking facility at a site, Mohawk will calculate the number and type of parking spaces for the use of persons with disabilities according to the number and type of parking spaces required for each off-street parking facility.
- In determining the location of parking spaces for the use of persons with disabilities that will be provided where there is more than one off-street parking facility at a site, Mohawk may distribute them among the off-street parking facilities in a manner that provides substantially equivalent or greater accessibility in terms of distance from an accessible entrance or user convenience.
- For the purposes of subsection (4.3.3), the following factors may be considered in determining user convenience:
- A. Protection from the weather
- B. Security
- C. Lighting
- D. Comparative maintenance
3.4 Signage
Mohawk will ensure that parking spaces for the use of persons with disabilities are distinctly indicated by erecting an accessible permit parking sign in accordance with section 11 of Regulation 581 of the Revised Regulations of Ontario, 1990 (Accessible Parking for Persons with Disabilities) made under the Highway Traffic Act.
5. Obtaining Services
5.1 Service Counters
- When constructing new service counters, for services obtained in buildings or out-of-doors, which includes replacing existing service counters, the following requirements will be met:
- There will be at a minimum one service counter that accommodates a mobility aid for each type of service provided and the accessible service counter must be clearly identified with signage, where there are multiple queuing lines and service counters.
- Each service counter will accommodate a mobility aid, where a single queuing line serves a single or multiple counters.
- The service counter that accommodates mobility aids will meet the following requirements:
- The countertop height will be such that it is usable by a person seated in a mobility aid.
- There will be sufficient knee clearance for a person seated in a mobility aid, where a forward approach to the counter is required.
- The floor space in front of the counter will be sufficiently clear so as to accommodate a mobility aid.
5.2 Fixed Queuing Guides
When constructing new fixed queuing guides, the following requirements will be met:
- The fixed queuing guides will provide sufficient width to allow for the passage of mobility aids and mobility assistive devices.
- The fixed queuing guides will have sufficiently clear floor area to permit mobility aids to turn where queuing lines change direction.
- The fixed queuing guides will be cane detectable.
5.3 Waiting Areas
- When constructing a new waiting area or redeveloping an existing waiting area, where the seating is fixed to the floor, a minimum of three per cent of the new seating will be accessible, but in no case will there be less than one accessible seating space.
- For the purposes of this section, accessible seating is a space in the seating area where an individual using a mobility aid can wait.
6. Maintenance of Accessible Elements
In addition to the accessibility plan requirements set out, Mohawk College will ensure that the multi-year accessibility plans include the following:
- A. Procedures for preventative and emergency maintenance of the accessible elements in public spaces as required under this Part.
- B. Procedures for dealing with temporary disruptions when accessible elements required under this Part are not in working order.
V – CUSTOMER SERVICE STANDARDS
Mohawk College is committed to equal access to goods and services, providing exceptional and accessible customer service for its customers, and is obligated to facilitate the implementation of the Accessibility for Ontarians with Disabilities Act 2005 (AODA) and Ontario Regulation 191/11 Integrated Accessibility Standards. To ensure these outcomes, operational policies and procedures for the College are developed under the guidelines of dignity, independence, integration and equality of opportunity, in compliance with AODA.
1. Purpose
- The purpose of this standard is to establish accessibility standards for customer service. This applies to all employees (administrative, faculty, support staff), volunteers, and contractors of Mohawk College.
- Mohawk College recognizes that people with disabilities achieve accessibility to the provisions of goods and services by the College, consistent with the following principles:
- The goods or services must be provided in a way that respects the dignity and independence of people with disabilities.
- The provision of goods or services to people with disabilities must be integrated unless an alternate measure is necessary, whether temporary or on a permanent basis, to enable a person with a disability to obtain or benefit from the goods or services.
- People with disabilities must be given an opportunity equal to that given to others to obtain, use and benefit from goods or services.
2. Roles and Responsibilities
2.1 Guide Dogs, Service Animals
If a person with a disability is accompanied by a guide dog or other service animal, the College will permit the person to enter the premises with the animal and keep it with them, unless is otherwise excluded by law from the premises. If the service animal is excluded by law from the premises, the College will look to other available measures to enable the person with a disability to obtain, use or benefit from the College’s goods and services.
2.2 Support Persons
If a person with a disability is accompanied by a support person, the College will ensure that both persons are permitted to enter the premises together, and that the person with a disability is not prevented from having access to the support person while on the premises. The College may require a person with a disability to be accompanied by a support person when on the College premises, but only if, after consulting with the person with a disability and considering the available evidence, the provider determines that:
- a support person is necessary to protect the health and safety of the person with a disability or the health and safety of others on the premises; and
- There is no other reasonable way to protect the health and safety of the person with a disability and the health and safety of others on the premises.
Where fees for programs, goods and services are advertised or promoted by the college, it will provide advance notice of the amount payable, if any, in respect of the support person. If the College requires a person with a disability to be accompanied by a support person when on the premises, the College shall waive payment of the amount, if any, payable in respect of the support person’s admission to the premises or in connection with the support person’s presence on the premises.
2.3 Disruption of Services
Mohawk College recognizes that persons with disabilities often make special arrangements in order to access our services (for example, they may book accessible transit, or arrange for transportation.) The College will provide notice of service disruptions when any facility, technology, or service that a person with a disability usually uses to access our goods and services is temporarily unavailable, or is expected to be temporarily unavailable in the near future.
Temporary disruptions in the services and facilities may occur due to reasons that may or may not be within the control or knowledge of the College. The College will provide prior notice of planned disruptions. In the case of unplanned service disruptions, the College will make reasonable effort to provide timely notice, recognizing that in some circumstances, such as in the situation of unplanned temporary disruptions, advanced notice will not be possible. Refer to the Notification of Service Disruption Procedure.
2.4 Assistive Devices
If a person with a disability requires assistive devices to access programs, goods or services at the College, they are allowed to use such devices. When available, the College will provide assistive technology in order to allow people with disabilities to access College programs, goods and services while on the premises conducting college business.
2.5 Feedback Process
The College will provide a mechanism which allows the public to provide feedback on the manner in which the College provides programs, goods, services and facilities to people with disabilities. The feedback process will permit the person to provide feedback in person, by telephone, in writing, or by an electronic means (i.e. email, social media, etc.). The feedback process will detail the Colleges process for receiving and responding to feedback including timelines and contact information and will be made available on the College website.
The College will ensure that the feedback process is accessible to persons with disabilities by providing, or arranging for the provision of, accessible formats and communication supports, on request.
2.6 Training
The College will provide Accessible Customer Service Training to all employees (including administrators, faculty and support staff), volunteers, all those involved in developing customer service policies and procedures, and every person who provides goods, services or facilities on behalf of the College. The College will keep records of the training provided, including dates training is provided and number of persons trained. The training will be delivered in a variety of formats and will be provided on an ongoing basis for employees in order to stay current with changes in policies, practices and procedures. The training will include the following:
- The purpose of the AODA and the requirements of the customer service standard.
- How to interact and communicate with persons with various types of disability.
- How to interact with persons with disabilities who use assistive devices or require the assistance of a guide dog or other service animal or the assistance of a support person.
- How to use equipment or devices available on the College premises or provided by the college that may help with the provision of goods, services or facilities to a person with a disability;
- What to do if a person with a disability is having difficulty accessing the College’s programs, goods, services or facilities.
- How to provide goods and services in a manner that respects the dignity and independence of persons with disabilities.
- The process to provide feedback to the College about the provision of services to persons with disabilities in any department or school and how the College responds to the feedback and takes action on any complaint.
2.7 Notice of Availability of Documents
This document and other policies and practices related to the provision of goods and services for people with disabilities will be advertised to ensure the public of their existence. These documents will be made available on request and in a format that takes into consideration, the person’s disability.
3. Non-Compliance Implications
Consequences of non-compliance with this standard include financial, human rights and legal implications. The Accessibility Standards for Customer Service, Ontario Regulation 429/07 includes a fine for a person who is non-compliant of up to $50,000 a day and for a corporation of up to $100,000 each day that they continue to be non-compliant.
4. Related Procedures
Each College department / school will be responsible for ensuring that their individual policies and procedures reflect this institutional policy and commitment, and the obligation of the College to the Accessibility Standards for Customer Service (O. Reg. 429/07).