The Accessibility for Ontarians with Disabilities Act, 2005 (“the AODA”) is a Provincial Act with the purpose of developing, implementing and mandating accessibility standards in order to achieve accessibility for persons with disabilities, with respect to goods, services, facilities, accommodation, employment, buildings, structures and premises.
AptPay is committed to providing a respectful, welcoming, accessible, and inclusive environment for all persons with disabilities in a way that is respectful of the dignity and independence of people with disabilities and in a manner which takes into account the person’s disability and embodies the principles of integration and equal opportunity.
AptPay is committed to, and will strive to ensure that, the Accessibility for Ontarians with Disabilities Act (AODA), 2005, its regulations, standards and all other relevant legislation concerning accessibility, are rigorously observed in a timely fashion.
Accessible Formats: include, but are not limited to accessible electronic formats, Braille, text transcripts, large print, recorded audio, and other formats accessible to persons with disabilities.
Assistive Device: 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 members and guests 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.
Barrier: as defined by the Ontarians with Disabilities Act, 2001, anything that prevents a person with a disability from fully participating in all aspects of society because of his/her disability.
Communication Supports: include but are not limited to sign language, plain language and other communication supports that facilitate effective communications.
Disability: a key feature of the AODA is its definition of “disability”. Under the AODA, the definition of “disability” is the same as the definition in the Ontario Human Rights Code .
A. INTEGRATED ACCESSIBILITY STANDARDS REGULATION POLICY
PURPOSE AND BACKGROUND
The Integrated Accessibility Standards Regulation (Regulation 191/11) (the “IASR”) under the AODA provides standards for private sector organizations to increase accessibility for persons with disabilities specifically in the areas of:
Information and Communications
In order to achieve our goals, AptPay has developed a multi-year Accessibility Plan which documents AptPay’s strategy and commitment to meet the applicable standards of the IASR.
The Accessibility Plan was developed in consultation with a cross-functional team at AptPay that helped to identify barriers that prevent a person with a disability from fully participating in aspects of society because of their disability (such as attitudinal, information or communication, technology, organizational and physical) within the stated goals of the IASR.
The Accessibility Plan will be reviewed and updated at least once every five years.
AptPay will ensure that timely training is provided to all necessary persons, that it aligns with the requirements of the accessibility standards referred to in the IASR, and AptPay will continue to provide training on the Human Rights Code as it pertains to persons with disabilities. Appropriate records of training are maintained.
Training, using the most appropriate methodologies, as appropriate, is provided to the following person(s):
all persons who work under a contractual agreement directly with AptPay
(2) INFORMATION AND COMMUNICATION STANDARDS
AptPay will ensure that its processes for receiving and responding to feedback are made available to persons with disabilities, whether members of the public, clients, customers or employees, in an appropriate, accessible format or communication support, upon their request, and that members of the public are notified of the availability of such an option. AptPay reviewed its current feedback processes to ensure they were accessible and in compliance with the IASR prior to January 1, 2015.
(b) Accessible Formats and Communication Supports (to be effective in full by June 29, 2020)
AptPay will, upon request and consultation, endeavor to provide information and communications under our control about our goods and services to people with disabilities using the appropriate accessible format or communication support wherever possible, in a timely manner and on par with the fee charged to others for the same information. AptPay will notify the public about the availability of accessible formats and communications supports. AptPay will review and determine its current offerings of accessible formats and communications supports and will engage in an ongoing process of identifying additional accessible formats and communications supports that may be offered by AptPay.
(c) Accessible Websites and Web Content
AptPay is pleased to confirm that all of its new websites and content, like the existing websites, will be in conformance with Web Content Accessibility Guidelines (WCAG) 2.0 Level A as of June 2020, as practicable.
AptPay will ensure all of its websites, content, and applications directly controlled by AptPay or through its contractual relationships, will be in conformity with WCAG 2.0 Level AA, as required by the IASR, by January 1, 2021, as practicable.
(d) Recruitment, Assessment or Selection Process
AptPay will ensure that job applicants are notified when they are individually selected to participate in the assessment or selection process and that accommodation for disabilities are made available upon request in relation to the materials or processes to be used. AptPay will consult with individuals who request accommodations and will provide for appropriate accommodations.
(e) Notice to Successful Applicants
When presenting offers of employment, AptPay will notify the successful applicant of its policies for accommodating employees with disabilities.
(f) Informing Employees of Supports
AptPay will ensure that employees are informed of all accessibility 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.
(g) Accessible Formats and Communication Supports for Employees
Upon request of an employee with a disability, AptPay will consult with the employee to provide, or arrange for accessible formats and communication supports for information that is needed to perform their job, and information that is available to other employees. In order to determine the suitability of an accessible format or communication support, AptPay will consult with the employee making the request. Accessible formats and communications supports regarding general workplace information will also be provided to employees with disabilities.
(h) Workplace Emergency Response Information
AptPay provides employees with disabilities individualized workplace emergency response information when the employee’s disability is such that the information is required and AptPay has been informed of the need to accommodate the employee’s disability.
(i) Documented Individual Accommodation Plans
AptPay currently accommodate the needs of its employees with disabilities as required under the Ontario Human Rights Code. AptPay will develop individualized accommodation plans for its employees with disabilities, as AptPay is made aware. The process by which AptPay will consult, develop, determine, document, review and routinely update the individualized accommodation plan will be formalized. AptPay will implement and maintain measures effective to maintain the privacy of its employees with disabilities.
(j) Return to Work Process
AptPay will maintain a documented return to work process for employees who have been absent from work due to a disability and who require disability-related accommodations and support in order to return to work. The return to work process will clearly define and outline the steps AptPay will take to facilitate the return to work and will include documented accommodation plans for each individual as part of the process. The above stated return to work process will not replace, hinder or override any other return to work process created by or under any other statute (i.e., the Workplace Safety Insurance Act, 1997).
(k) Performance Management, Career Development and Advancement and Redeployment
AptPay will continue to consider the accessibility needs of employees with disabilities as well as individual accommodation plans, when conducting performance management reviews, providing career development and advancement to employees and when redeploying employees.
B. ACCESSIBILITY STANDARDS FOR CUSTOMER SERVICE POLICY
PURPOSE AND BACKGROUND
Under the AODA, Ontario Regulation 429/07, entitled “Accessibility Standards for Customer Service” (the “Service Regulation”), came into effect on January 1, 2008. The Service Regulation establishes accessibility standards specific to customer service for private sector organizations that provide goods and services to members of the public or other third parties.
The objective of this policy is to identify what the equal treatment provisions of the Ontario Human Rights Code, through the AODA and the Service Regulation, require with respect to service delivery to persons with disabilities and addresses the following:
The Provision of Goods and Services to Persons with Disabilities;
The Use of Assistive Devices;
Notice of Service Disruptions;
Notice of Availability and Format of Required Documents.
STATEMENT OF COMMITMENT AND ACCOUNTABILITIES
AptPay is committed to providing a respectful, welcoming, accessible, and inclusive environment in the provision of goods and services for both customers/clients and employees alike. AptPay is committed to, and strives to ensure that, the AODA, the standards and all other relevant legislation concerning accessibility, are rigorously observed. AptPay ensures that all persons within its community are aware of their rights and responsibilities to foster an accessible and inclusive environment with and for persons with disabilities.
People with disabilities will be given an equal opportunity to obtain, use and benefit from AptPay’s products and services in a way that is respectful of the dignity and independence of people with disabilities and in a manner which takes into account the person’s disability.
All goods and services provided by AptPay shall follow the principles of dignity, independence, integration and equal opportunity.
AptPay is committed to becoming a barrier free environment and meeting the requirements of all existing legislation and its own policies and goals related to identifying, removing and preventing barriers to people with disabilities that might interfere with their ability to make full use of the services provided by AptPay.
This policy applies to the provision of goods and services at premises owned and/or operated by AptPay as well as any interactions with employees and customer/clients via telephone, email or written mail.
This policy applies to employees, volunteers, agents and/or contractors who deal with the public or other third parties that act on behalf of AptPay.
CUSTOMER SERVICE POLICY, PRACTICE AND PROCEDURE
(1) THE PROVISION OF GOODS AND SERVICES TO PERSONS WITH DISABILITIES
AptPay 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 goods and 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 goods and services; and
communicating in a manner that takes into account the customer’s disability.
AptPay employees and representatives will be encouraged to be pro-active in seeking solutions and removing barriers, as well as alerting all customers to the range of accommodations that are available.
The term “persons with disabilities” will be the norm, and if a specific condition must be referenced, the condition will be referenced last (e.g., person with low vision). The following are some general tips that may help make communication and interaction with or about people with all types of disabilities more successful:
Remember to put people first. It is proper to say person with a disability, rather than disabled person or the disabled.
It is best to wait until an individual describes his or her situation to you, rather than to make your own assumptions. Many types of disabilities have similar characteristics and assumptions may be wrong.
When AptPay bills for services, it should demonstrate a commitment to providing accessible invoices to all of our customers. This means that invoices should be provided in alternate formats upon request (e.g., hard copy, large print, email) and that staff is prepared to answer questions customers may have about the content of the invoice.
(2) ASSISTIVE DEVICES
Persons with disabilities may use their own assistive devices as required when accessing goods or services provided by AptPay. 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 goods and services. For example, where elevators are not present and where an individual requires assistive devices for the purposes of mobility, service will be provided in a location that meets the needs of the customer.
Every employee who interacts with customers/clients or other third parties will be trained on how to assist with various assistive devices, should their assistance be required.
Employees will be prepared to respond to requests of water for the service animal and to show the owner an outdoor area where the animal can be taken to relieve itself.
(3) SUPPORT PERSONS
If a customer/client with a disability is accompanied by a support person, AptPay will ensure that both persons are allowed to enter the premises together and that the customer/client is not prevented from having access to the support person. All customer/client confidentiality requirements and practices will also apply to support persons.
Training will be provided to all employees who deal with the public; revised training will be provided in the event of changes to legislation or AptPay’s policy, practice and procedure. AptPay will keep a record of training that includes the dates training was provided, the number of employees and names of employees trained.
The training will include information on the purposes of the AODA, requirements of this Service Regulation, how to communicate and interact with people with disabilities, how to interact with service animal or support person, how to utilize assisted devices that are available at our premises, what to do if a person has difficulty accessing AptPay services or facilities, and our policies, procedures and practices pertaining to providing accessible customer service to people with disabilities.
(5) NOTICE OF DISRUPTIONS IN SERVICE
Service disruptions may occur due to reasons that may or may not be within the control or knowledge of AptPay. In the event of any temporary disruptions to facilities or services that customers with disabilities rely on to access or use, 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.
Any service disruption will take top priority and AptPay employees will check to ensure no one is trapped or stuck because of the disruption.
The notice should include statement of regret and include date.
(6) FEEDBACK PROCESS
AptPay shall provide customers/clients with the opportunity to provide feedback on the service provided to persons with disabilities. Information about the feedback process will be readily available to all customers/clients and notice of the process will be made available at location reception. Feedback forms along with alternate methods of providing feedback such as verbally (in person or by telephone) or written (hand written or email) will be available upon request.
Customers/clients will be informed about the feedback process and how action will be taken if a complaint is received. AptPay will acknowledge verbal/written/telephone feedback within two business days, and within fifteen business days of the receipt of a mailed/e-mailed complaint. In some cases, it may not be possible or appropriate to acknowledge feedback, for example, if the customer wishes to remain anonymous, or indicates that he/she does not want to receive an acknowledgment. Customers can submit feedback to: firstname.lastname@example.org or contact us at 1 866 770 2194.
(7) AVAILABILITY AND FORMAT OF DOCUMENTS (ALTERNATIVE FORMATS)
All documents required by the Accessibility Standards for Customer Service, including AptPay’s Accessibility Policy, notices of temporary disruptions, training records, and written feedback process are available upon request, subject to the Freedom of Information and Protection of Privacy Act (“FIPPA”). When providing these documents to a person with a disability, AptPay will endeavor to provide the document, or the information contained in the document, in a format that takes the person’s disability into account. Notice of the availability of documents required by the Accessibility Standards for Customer Service will be posted on AptPay’s website at: www.AptPay.com.
AptPay shall notify customers that the documents related to the Accessibility Standard for Customer Service are available upon request and in a format that takes into account the customer’s disability. Notification will be given by posting the information in a conspicuous place owned and operated by AptPay, the website and/or any other reasonable method. In the event that a notification needs to be posted, the following information will be included unless it is not readily available or known:
goods or services that are disrupted or unavailable
reason for the disruption
a description of alternative services or options