Accessibility plan

Accessibility plan


Multi-year Accessibility Plan (updated December 2017)

Toronto Community Housing is committed to meeting the accessibility needs of people with disabilities in a timely manner. To meet this goal and to comply with the requirements under Ontario Regulation 191/11 (the "Integrated Accessibility Standards") of the Accessibility for Ontarians with Disabilities Act, 2005 (AODA), Toronto Community Housing has developed the following multi-year Accessibility Plan for Integrated Accessibility Standards ("Plan"). This plan will be reviewed at least once every five years, and is available in accessible format upon request.

This Plan covers the following areas:

  1. Statement of commitment; and
  2. An implementation chart to track compliance with the Integrated Accessibility Standards.

1. Organizational Statement of Commitment


Toronto Community Housing is committed to providing an inclusive environment to residents and employees with disabilities in accordance with the core principles of accommodation, dignity, independence, integration and equal opportunity outlined in the Accessibility for Ontarians with Disabilities Act, 2005, the Ontario Human Rights Code 1990 and the complimentary legislation of the Integrated Accessibility Standards Regulation (Ontario Reg. 191/11) (IASR), Accessibility Standards for Customer Service (Ontario Reg. 429/07), Employment Standards Act (2000), and the Ontario Building Code (Ontario Reg. 332/12). Toronto Community Housing recognizes the need to identify and remove barriers faced by people with disabilities, and will achieve greater accessibility by aligning with a culture that recognizes the dignity and worth of every individual.

2. Integrated Accessibility Standards: Implementation Tracking Chart​​


Tracking Requirements:

​AODA Requirements ​Implementation Status ​Comments
3. (1) Policy Requirements

Development of Accessibility Policies and Statement of Organizational Commitment

Deadline: January 1, 2014

CURRENT COMPLIANT

  • ​Accessible Customer Service Policy, Accessibility Policy and Accessible Built Environment Policy are available online and made available to the public and in an accessible format upon request.  



MOVING FORWARD:

  • These policies will be reviewed based on TCHC’s internal review process that are more frequent than legislative requirements. 

​4.(1)
Accessibility Plan

Deadline: January 1, 2014
CURRENT COMPLIANT
  • The 2014 Multiyear Accessibility Plan was posted on our website and in an accessible format in 2014. 

MOVING FORWARD
  • This enhanced Multiyear Accessibility Plan will be made available online by December 31, 2017 in an accessible format, and reviewed every 5 years. 

6. (1) Self-Serve Kiosks

​Deadline: January 1, 2014
CURRENT COMPLIANT
  • Majority of our pay and display visitor parking machines are installed in parking lots and are operated by Toronto Parking Authority.
  • Existing Kiosks are found in Operating Unit Offices, laundry rooms, and small parking facilities are currently compliant.
  • Vendors that manage facilities have to comply with accessibility standards. 
MOVING FORWARD

  • Reviewing internet payment machines in Q1 2018. Further actions are based on the review.

7.(1) Training
Training is provided on the requirements of the accessibility standards referred to in this Regulation and on the Ontario Human Rights Code as it pertains to persons with disabilities.

Deadline: January 1, 2014
IN PROGRESS
  • Online training on AODA and Human Rights Code were provided to all staff by the end of 2014.

  • In-person training completed with all staff in 2016 and 2017. 

  • All new employees received AODA and Human Rights Code training in general orientation. 
    • The Declaration of Compliance includes requirements of AODA legistation.
    • In-person tenant-led training for tenant representatives commenced in 2016 and 2017. Training for Tenant Leaders began in April 2017.
MOVING FORWARD
  • HR is developing a new learning management system in place in Q1 2018, and will ensure that all staff are trained on AODA.

  • Resident Services will continue training tenant representatives and tenant leaders in an e-module format in Q3 2018.

  • A new online module for Human Rights and Diversity Training will be developed in 2018. 


11.(1) Feedback Process


Establish a feedback process for receiving and responding to feedback about the manner in which TCH provides goods or services to people with disabilities, and make this process readily available to the public.

 

Deadline: January 1, 2014



CURRENTLY COMPLIANT
  • Tenant complaint process is used to provide feedback. Feedback can be provided by phone to the Client care centre, or by email from our website, or in person at an Operating Unit Office or Property Management Office.
  • Feedback is also gathered at tenant consultations and meetings, where accessible formats and communications supports are available upon request.
  • Accessible feedback process and a system for receiving and responding to feedback.
    • Divisions also have independent feedback mechanisms. 

MOVING FORWARD:
  • TCH is updating the complaint process that will include further feedback mechanisms by the end of Q2 2018.

Availability of Documents (Section 8 and 9)


Notify the public in a conspicuous place on premises or on the website, that accessibility policy and feedback process is available, and provide documents in an accessible format upon request


​CURRENTLY COMPLIANT

Policies and feedback processes are posted online.


​See comments below. 

Accessibility Report (Section 11)

File accessibility report


CURRENTLY COMPLIANT
  • Reports filed.



Integrated Accessibility Standards Regulation (IASR)

General Requirements:

AODA Requirements ​Implementation Status ​Comments
Establishment of Accessibility Policies

Deadline: January 1, 2013

  • Develop, implement and maintain policies governing how the organization achieves accessibility through meeting requirements in the IASR
  • Include a statement of organizational commitment to meet accessibility needs of persons with disabilities
  • Document policies and make them available to the public, and provide them in an accessible format upon request

​​CURRENTLY COMPLIANT
  • Accessible Customer Service Policy, Accessibility Policy and Accessible Built Environment Policy are available online and made available to the public and in an accessible format upon request.

MOVING FORWARD:

  • These policies will be reviewed based on TCHC’s internal review process that frequent than legislative requirements.  

Accessibility Plans (IASR Section 4)

Implementation Date: January 1, 2013

  • Establish, implement and maintain a multi-year accessibility plan which addresses strategies to prevent/remove barriers
  • Post multi-year plan on website
  • Review and update plan every 5 years
  • Post annual status report of progress
  • Make documents available to the public and available in an accessible format upon request

CURRENTLY COMPLIANT
  • The Multiyear Accessibility Plan is posted on our website and in an accessible format. 

MOVING FORWARD:

  • This enhanced Multiyear Accessibility Plan will be made available online by December 31, 2017 in an accessible format, and reviewed every 5 years. 

Training (IASR Section 7)

Implementation Date: January 1, 2014

  • Ensure training is provided as soon as practicable on IASR requirements and HUMAN RIGHTS CODE as it pertains to people with disabilities to all employees, volunteers, policy developers, other third parties providing service on behalf of TCH
  • Update training when AODA Standards or policies change

CURRENTLY COMPLIANT

  • In-person training has been provided on IASR requirements and Human Rights Code to all staff in 2016 and 2017 and is being tracked.
  • In person tenant-led training for tenant representatives were provided in 2016 and 2017.
  • Third parties are required to conduct their own training and sign a form declaring compliance with requirements of AODA legislation

MOVING FORWARD:

  • A new learning management system in Q1 2018, will ensure that all staff are trained on AODA and any updates or changes to policy, will be reflected.
  • Training for tenant volunteers will continue in an e-module format in Q3 2018.  
  • A new online module for Human Rights and Diversity Training will be developed in 2018. 


Information and Communications Standards:

AODA Requirements​Implementation Status​Comments

Feedback (IASR Section 11)

Implementation Date: January 1, 2015

  • Ensure all feedback processes are accessible to people with disabilities, by providing or arranging for the provision of accessible formats and communication supports, upon request
  • Notify the public that accessible formats or communication supports are available


​​CURRENTLY COMPLIANT
  • Accessible formats and communications supports in person or by phone are available upon request at no charge.
  • Client Care Centre (tenant phone line) has TTY available for hearing impaired residents. It also has interpreting into 168 languages. 

MOVING FORWARD:

  • This will be reviewed in 2019 in line with the next AODA compliance report.  

Accessible Formats and Communications Supports (IASR Section 12)

Implementation Date: January 1, 2015

  • Provide or arrange for provision of accessible formats and communication supports, upon request
  • Notify the public that accessible formats and communication supports are available
  • Consult with the person making the request to determine the suitability of the accessible format or communication support


CURRENTLY COMPLIANT
  • TCH has a process to provide alternate formats via internally trained resources or third party vendor services.
  • All requests online are received by Strategic Communications and each requester is consulted with.
  • Posters developed by Strategic Communication include a statement to notify tenants about requesting accessible formats.  



MOVING FORWARD:

  • Resident Services will ensure posters to inform tenants that accessible formats are available, and accommodations are available upon request.  

Emergency Procedure, Plans or Public Safety Information (IASR Section 13)

Implementation Date:

  • Provide publicly available emergency procedures, plans, or safety information in accessible formats or with communications supports, upon request

CURRENTLY COMPLIANT

  • Risk Management provides accessible formats for TCH emergency plans and procedures
  • Fire Safety Plans are available in electronic formats. State of Good Repair projects have been identified and implemented to upgrade systems to include visual alarms.
  • Fire Wardens are trained on responsibilities and able to assist the public
  • Fire Safety Plan has an updated vulnerability list.  

MOVING FORWARD:

  • Scope the development of communication channels and application of emergency response plan in times of emergency incidents in Q1 2018.
  • The Vulnerability List is updated monthly by buildings and placed in fire boxes, ensuring first responders have access


Accessible Website and Web Content (IASR Section 14)

Implementation Date: January 1, 2014 and January 1, 2021

  • New websites published after January 1, 2014 must meet Web Content Accessibility Guidelines WCAG Level A
  • By 2021 all websites and content must meet WCAG Level AA.
  • Applies to websites and web content, including web-based applications that an organization controls directly or through a contractual relationship
  • Applies to all content published on a website after January 1, 2012 (i.e., when new website is launched the requirement applies retroactively to all content that was published after 2012, e.g. PDFs)

CURRENTLY COMPLIANT
  • TCH completed a Web Content Migration project and launched a new website, prior to the AODA deadline was in effect. The current website is accessible to WCAG Level AA, with a few exceptions
  • Web Standards for accessible web design practices are in place.

MOVING FORWARD:
  • RPATH recommended additional revisions to be made to the website, ITS commencing project in Q1 2018.  


Employment Standards:

AODA Requirements ​Implementation Status ​Comments

Recruitment General (IASR Section 22)

Implementation Date: January 1, 2014

  • Notify employees and public about availability of accommodation for applicants with disabilities during the recruitment process

CURRENTLY COMPLIANT

  • Internal and external job postings include a statement that TCH provides equitable treatment and accommodation to ensure barrier free employment.

MOVING FORWARD

  • This will be reviewed in 2019 in line with the next AODA compliance report.
Recruitment, assessment or selection process (IASR Section 23)

Implementation Date: January 1, 2014

  • Notify job applicants about availability of accommodation during the recruitment process, in relation to the materials or processes to be used
  • Consult with the applicant to determine suitable accommodation that takes into account accessibility needs due to a disability

CURRENTLY COMPLIANT
  • When inviting both internal and external candidates to attend an interview or participate in a test, they are advised that requests for accommodation are accepted throughout the hiring process.
  • TCH reviews all requests and determines appropriate accommodation on a case by case basis in consultation with the individual.

MOVING FORWARD
  • This will be reviewed in 2019 in line with the next AODA compliance report.

Notice to Successful Applicants (IASR Section 24)

Implementation Date: January 1, 2014

  • When making job offers, inform the successful applicant of policies for accommodating employees with disabilities

CURRENTLY COMPLIANT
  • All permanent and temporary employees, both union and non-union, external and internal, are notified verbally and/or in written job offers about policies and procedures for accommodating employees with disabilities.

MOVING FORWARD
  • This will be reviewed in 2019 in line with the next AODA compliance report.

Informing Employees of Supports (IASR Section 25)

Implementation Date: January 1, 2014

  • Inform employees of 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

CURRENTLY COMPLIANT
  • Accommodation and accessibility related policies are available to all employees on TCH's "inHouse" Intranet
  • Employees are notified in job offers about policies and procedures for accommodating employees with disabilities

MOVING FORWARD
  • This will be reviewed in 2019 in line with the next AODA compliance report.

Accessible Formats and Communication Supports for Employees (IASR Section 26)

Implementation Date: January 1, 2014

  • When requested, provide employees with accessible information and communication supports for information required to perform the job, and information generally available to employees in the workplace
  • Consult with the employee making the request to determine suitability of the format or communication support

CURRENTLY COMPLIANT
  • TCH provides accommodation, communication supports, and information in an accessible format, consistent with TCH's Accommodation Policy, TCH's Accessibility Policy, TCH's accommodation plan and return to work process, and TCH's obligations under the Human Rights Code

MOVING FORWARD
  • This will be reviewed in 2019 in line with the next AODA compliance report.

Workplace Emergency Response Information (IASR Section 27)

Implementation Date: January 1, 2012

  • Provide individualized workplace emergency response information to employees with disabilities if the disability is such that individualized information is necessary and the employer is aware of the need for accommodation.
  • With employee's consent, provide workplace emergency response information to the person(s) designated by the TCH to provide assistance
  • Provide the information required as soon as practicable after becoming aware of the need for accommodation
  • 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; and
    • when the employer reviews its general emergency response policies

CURRENTLY COMPLIANT
  • TCH provides this information consistent with TCH's Accommodation Policy and TCH's Accessibility Policy
  • TCH incorporates individualized workplace emergency response information into its accommodation plan and return work process

MOVING FORWARD
  • This will be reviewed in 2019 in line with the next AODA compliance report.

Documented Individual Accommodation Plans (IASR Section 28)

Implementation Date: January 1, 2014

Develop and have in place a written process for development of documented individual accommodation plans (IAP) for employees with disabilities that includes:

  1. How staff requesting accommodation can participate in the development process of their 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 assist the employer in determining if accommodation can be achieved and, if so, how accommodation can be achieved.
  4. The manner in which the employee can request the participation of a representative from their bargaining agent, where the employee is represented by a bargaining agent, or other 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.


  • If requested, include any information regarding accessible formats and communications supports provided
  • If required, include individualized workplace emergency response information
  • Identify any other accommodation that is to be provided.

CURRENTLY COMPLIANT
  • The process to develop individual accommodation plans is integrated as part of TCH's Accommodation Policy & Guidelines
  • TCH has a process in place for written accommodation and return to work plans, which reflects its obligations under the AODA, TCH's Accommodation Policy, and the Human Rights Code
  • TCH specifically incorporates individualized workplace emergency response information into its accommodation plan and return work processes
  • Accommodation and return to work plans are reviewed as necessary and at regular intervals.

MOVING FORWARD
  • This will be reviewed in 2019 in line with the next AODA compliance report.

Return to Work Process (IASR Section 29)

Implementation Date: January 1, 2014

  • Develop and have in place a return to work process for employees absent due to a disability who require disability-related accommodations in order to return to work
  • The process shall outline the steps the TCH will take to facilitate the return to work of employees who were absent due to a disability and shall use the Individual Accommodation Plan (IASR Section 28) as part of the process

CURRENTLY COMPLIANT
  • TCH has a process in place for written accommodation and return to work plans, which reflects its obligations under the AODA, TCH's Accommodation Policy, TCH's Disability and Absence Management Program, and the Human Rights Code
  • TCH has written policies and procedures regarding the accommodation Disability Management Program in place.
  • Accommodation and return to work plans are reviewed as necessary and at regular intervals.

MOVING FORWARD
  • This will be reviewed in 2019 in line with the next AODA compliance report.

Performance Management (IASR Section 30)


Implementation Date: January 1, 2014

  • Take accessibility needs and Individual Accommodation Plans into account in the performance management process

CURRENTLY COMPLIANT
  • Accessibility needs and individual accommodation plans are taken into account in performance management in compliance with Human Rights Code and the AODA.

MOVING FORWARD
  • This will be reviewed in 2019 in line with the next AODA compliance report.

Career Development and Advancement (IASR Section 31)


Implementation Date: January 1, 2014

  • Take accessibility needs and Individual Accommodation Plans into account when providing career development and advancement to employees with disabilities
  • ("Career development and enhancement" includes providing additional responsibilities in a current position and the movement of an employee from one job to another that may be higher pay, provide greater responsibility, or be at a higher level in the organization, and is usually based on merit or seniority)

CURRENTLY COMPLIANT
  • Accessibility needs and individual accommodation plans are taken into account in performance management in compliance with the Human Rights Code and the AODA.

MOVING FORWARD
  • This will be reviewed in 2019 in line with the next AODA compliance report.

Redeployment (IASR Section 32)

Implementation Date: January 1, 2014

  • Take accessibility needs and Individual Accommodation Plans into account when redeploying employees with disabilities

CURRENTLY COMPLIANT
  • Accessibility needs and individual accommodation plans are taken into account in performance management in compliance with the Human Rights Code and the AODA.

MOVING FORWARD
  • This will be reviewed in 2019 in line with the next AODA compliance report.


Design of Public Spaces Standards


AODA Requirements​Implementation Status​Comments

Design of Public Spaces Standards       

Implementation Date: January 1, 2016

  • TCH will meet the Accessibility Standards for the Design of Public Spaces when building or making major modifications to public spaces that are newly constructed or redeveloped by January 1, 2017.


CURRENTLY COMPLIANT

  • Approved by the Board of Directors in December 2015, TCHC's Build Standards have provided an effective framework for the implementation of accessible design principles in both new construction and renovation projects throughout the TCHC portfolio.
  • The Build Standards provide guidance for a wide range of applications including accessible unit modifications, common area renovations and exterior landscaping and grounds improvements. 
  • As many aspects of our standards exceed current building codes and municipal standards, Toronto Community Housing is proud to be industry leaders and innovators in accessibility.  

MOVING FORWARD

  • These standards are truly a living document.  They are constantly evolving, being added to and refined to reflect the needs of TCHC tenants. Their ongoing development is the result of continuing research, healthy debate and the applying of the many lessons learned from the tenants we serve and the projects we deliver.  Importantly, this document is born directly from the unique and successful collaboration between the tenant-led, volunteer-based RPATH committee and our dedicated TCHC staff.


Accessibility Plan


AODA Requirements​Implementation Status​Comments

Accessibility Plan (IASR, Subsection 80(44))      

Implementation Date: ongoing

  • Ensure that TCHC’s multi-year accessibility plan includes: (1) procedures for preventative and emergency maintenance of the accessible elements in public spaces as required under Part IV.1 of the AODA; and (2) procedures for dealing with temporary disruptions when accessible elements required under Part IV.1 are not in working order.

CURRENTLY COMPLIANT

Procedures for preventative and emergency maintenance of the accessible elements and for dealing with temporary disruptions when accessible elements are not in working order include:

  • conducting regular inspections for accessible and life safety equipment in all buildings throughout the year;

  • providing tenants 24/7 access to TCHC's Client Care Centre to have their needs addressed during planned and temporary service disruptions (dispatching staff for repair or direct tenant support);

  • notifying tenants during extended service disruptions and providing direct support, including providing all impacted individuals with reasonable alternative solutions where necessary; and

  • dispatching emergency maintenance services immediately when notified of a service disruption.

MOVING FORWARD

  • This will be reviewed in 2019 in line with the next AODA compliance report.


Compliance Reporting


AODA Requirements​Implementation Status​Comments

Reporting compliance in accordance with IASR Section 86.1 begins in 2013 and is required every two years thereafter (i.e., 2015, 2017, 2019, 2021, 2023, 2025)


CURRENTLY COMPLIANT

  • Reports filed in 2013, 2015. 

MOVING FORWARD

  • Report to be filed by 2017.