AODA – Integrated Accessibility Standards Regulation (IASR) Information, Communications and Employment Policy

Intent

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 WildBrain shall follow the principles of dignity, independence, integration and equal opportunity.

Definitions

Accessible Formats – Include but are not limited to large print, recorded audio and electronic formats and other formats usable by persons with disabilities.

Communication Supports – Include but are not limited to captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications.

Performance Management – Activities related to assessing and improving employee performance, productivity and effectiveness with the goal of facilitating employee success. 

Redeployment – The reassignment of employees to other departments or jobs within the organization as an alternative to layoff, when a particular job or department has been eliminated by the organization. 

General Principles

In accordance with the Integrated Accessibility Standards, Ontario Regulation 191/11, this policy addresses the following:

  1. General Requirements
  2. Feedback Process
  3. Recruitment, Assessment and Selection
  4. Accessible Formats and Communication Supports
  5. Workplace Emergency Response Information
  6. Accessible Websites and Web Content
  7. Documented Individual Accommodation Plans
  8. Performance Management and Career Development and Advancement
  9. Return to Work
  10. Redeployment
  11. Exceptions

1. General Requirements

General requirements that apply across standards for information and communication, employment, and customer service) are outlined as follows. 

Establishment of Accessibility Policies and Plans

WildBrain will develop, implement and maintain policies governing how it will achieve accessibility through these requirements. These documents and plans will be made publicly available in an accessible format, upon request. 

Procuring or Acquiring Goods and Services, or Facilities

WildBrain will incorporate accessibility criteria and features when procuring or acquiring goods, services or facilities. The only exception is in cases where it is impracticable to do so. 

Training Requirements

WildBrain 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 WildBrain’s policies, and all other persons who provide goods, services or facilities on behalf of WildBrain.

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 WildBrain’s accessibility policies occur.

Records

WildBrain will maintain records on the training provided, when it was provided and the number of employees that were trained. 

2. Feedback Process

WildBrain will ensure that all feedback processes (both internal and external) are made accessible to clients/customers or employees, upon request. 

In accordance with the customer service standards, WildBrain will make known the availability of accessible feedback formats. 

3. Recruitment, Assessment and Selection

WildBrain will notify employees and the public about the availability of accommodation for job applicants who have disabilities. Applicants will be informed that these accommodations are available, upon request, during the interview process and for other candidate selection methods. Where an accommodation is requested, WildBrain will consult with the applicant and provide or arrange for suitable accommodation. 

Successful applicants will be made aware of WildBrain’s policies and supports for accommodating people with disabilities. 

4. Accessible Formats and Communication Supports

Unless deemed unconvertible or causes undue hardship, WildBrain will provide or arrange for the provision of accessible formats and communication supports for persons with disabilities, upon request. WildBrain will consider the person’s accessibility needs when customizing individual requests and shall consult with the individual making the request to ensure suitability. 

In addition, WildBrain will make the availability of accessible formats and communication supports publicly known. 

WildBrain 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, WildBrain will provide or arrange for the provision of accessible formats and communication supports for the following: 

  • Information needed in order to perform their job; and
  • Information that is generally available to all employees in the workplace.

WildBrain will consult with the employee making the request to determine the best way to provide the accessible format or communication support.  

5. Workplace Emergency Response Information

Where required, WildBrain 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
  • WildBrain reviews general emergency response policies.

6. Accessible Websites and Web Content

WildBrain will ensure that our website, and web content where applicable, conforms to the Web Content Accessibility Guidelines (WCAG) as outlined in the IASR, and will refer to the legislation for specific compliance deadlines and requirements.

7. Documented Individual Accommodation Plans

WildBrain must also develop and have in place written processes for documenting individual accommodation plans for employees with disabilities. The process for the development of these accommodation plans should include specific elements, including:

  • The ways in which the employee can participate in the development of the plan;
  • The means by which the employee is assessed on an individual basis;
  • The ways that an employer can request an evaluation by an outside medical expert, or other experts (at the employer’s expense) to determine if accommodation can be achieved, or how it can be achieved;
  • The ways that an employee can request the participation of a representative from the workplace for the creation of the accommodation plan;
  • The steps taken to protect the privacy of the employee’s personal information;
  • The frequency with which the individual accommodation plan should be reviewed or updated and how it should be done;
  • The way in which the reasons for the denial of an individual accommodation plan will be provided to the employee; and
  • The means of providing the accommodation plan in an accessible format, based on the employee’s accessibility needs.

The individual accommodation will also:

  • Include information regarding accessible formats and communication supports upon request;
  • Where needed, include individualized workplace emergency response information; and
  • Outline all other accommodation provided.

8. Performance Management and Career Development and Advancement

WildBrain 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.

9. Return to Work

WildBrain will develop and implement return to work processes for employees who are absent from work due to a disability and require disability-related accommodation(s) in order to return to work, up to the point of undue hardship. 

The return to work processes will outline the steps WildBrain will take to facilitate the employee’s return to work and shall use documented individual accommodation plans. 

10. Redeployment

The accessibility needs of employees with disabilities will be considered in the event of redeployment.  Individual accommodation plans will be consulted, as required.

11. Exceptions

The Information and Communications Standard does not apply to:

  • Products and product labels;
  • Unconvertible information or communications; or
  • Information that the organization does not control either directly or indirectly through a contractual relationship.

Unconvertible Information or Communications

If it is determined, in consultation with the requesting party, that information or communications are unconvertible, WildBrain will ensure that the individual who made the request is provided with an explanation and a summary of the information. 

WildBrain will classify information or communications as unconvertible where:

  • It is not technically practicable to convert; or
  • The technology required to make the conversion is not readily available.

Review and Update

This policy and its related procedures will be reviewed as required in the event of legislative changes, or changes to company procedures. WildBrain will review and update the Accessibility Policies and Plans at least once every five years.

Last updated: June 26, 2020