Accessibility

Providing Goods and Services to People with Disabilities

Our Mission

The mission of Carmens Group is to enrich the live of our guests. clients, and community by creating extraordinary experiences.

Our commitment

In fulfilling our mission, Carmens Group strives at all times to provide its goods and services in a way that respects the dignity and independence of people with disabilities. We are also committed to giving people with disabilities the same opportunity to access our goods and services and allowing them to benefit from the same services, in the same place and in a similar way as other customers.

Providing goods and services to people with disabilities

Carmens Group is committed to meeting its current and ongoing obligations under the Ontario Human Rights Code respecting non-discrimination.

Carmens Group understands that obligations under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and its accessibility standards do not substitute or limit its obligations under the Ontario Human Rights Code or obligations to people with disabilities under any other law.

Carmens Group is committed to complying with both the Ontario Human Rights Code and the AODA.

Our accessible customer service policies are consistent with the principles of independence, dignity, integration and equality of opportunity for people with disabilities.

Carmens Group is committed to excellence in serving all customers including people with disabilities and we will carry out our functions and responsibilities in the following areas:

Communication

We will communicate with people with disabilities in ways that take into account their disability.  This may include the following:

• Email
• Fax
• Telephone
• Verbal
• Written Letter

We will work with the person with a disability to determine what method of communication works for them.

We will train staff who communicate with customers on how to interact and communicate with people with various types of disabilities.

Telephone services

We are committed to providing fully accessible telephone service to our customers. We will train staff to communicate with customers over the telephone in clear and plain language and to speak clearly and slowly. We will offer to communicate with customers by email, fax or other available methods if telephone communication is not suitable to their communication needs or is not available.

Assistive devices

We are committed to serving people with disabilities who use assistive devices to obtain, use or benefit from our goods and services. In cases where the assistive device presents a significant and unavoidable health or safety concern or may not be permitted for other reasons, other measures will be used to ensure the person with a disability can access our goods, services or facilities. We will ensure that our staff are trained and familiar with various assistive devices that may be used by customers with disabilities while accessing our goods or services.

Billing

We are committed to providing accessible invoices to all of our customers. For this reason, invoices will be provided in the following formats upon request: hard copy, large print, e-mail. We will answer any questions customers may have about the content of the invoice in person, by telephone or email.

Use of service animals and support persons

We welcome people with disabilities and their service animals. Service animals are allowed on the parts of our premises that are open to the public.  When we cannot easily identify that an animal is a service animal, our staff may ask a person to provide documentation from a regulated health professional that confirms the person needs the service animal for reasons relating to their disability.  A service animal can be easily identified through visual indicators, such as when it wears a harness or a vest, or when it helps the person perform certain tasks.

If service animals are prohibited by another law, we will do the following to ensure people with disabilities can access our goods, services or facilities:

• explain why the animal is excluded
• discuss with the customer another way of providing goods, services or facilities

A regulated health professional is defined as a member of one of the following colleges:

• 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
• College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario

We are committed to welcoming people with disabilities who are accompanied by a support person. Any person with a disability who is accompanied by a support person will be allowed to enter Carmens Group’s premises with his or her support person. At no time will a person with a disability who is accompanied by a support person be prevented from having access to his or her support person while on our premises.

Full meal and/or room costs will be charged to the support person for admission to Carmens Group’s premises. Customers will be informed of this by a notice that will be posted in Carmens Group’s premises and contracts.

In certain cases, Carmens Group might require a person with a disability to be accompanied by a support person for the health or safety reasons of:

• the person with a disability
• others on the premises

Before making a decision, Carmens Group will:

• consult with the person with a disability to understand their needs
• consider health or safety reasons based on available evidence
• determine if there is no other reasonable way to protect the health or safety of the person or others on the premises

If Carmens Group determines that a support person is required, we will waive the admission fee or fare [if applicable] for the support person.

Notice of temporary disruption

Carmens Group will provide customers with notice in the event of a planned or unexpected disruption in the facilities or services usually used by people with disabilities. This notice will include information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if available.

The notice will be placed at all public entrances and service counters on our premises.

Training for staff

Carmens Group will provide training to all employees, volunteers and others who deal with the public or other third parties on their behalf, and all those who are involved in the development and approvals of customer service policies, practices and procedures.

Training will be provided as soon as is practicable after each person is assigned the applicable duties. Training will also occur on an ongoing basis as changes are made to the policies, procedures and practices dealing with the provision of goods and services to persons with disabilities and as may be required by applicable law.

Training will include the following:

• The purposes of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard
• How to interact and communicate with people with various types of disabilities
• How to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person
• What to do if a person with a disability is having difficulty in accessing Carmens Group’s goods and services
• Carmens Group’s policies, practices and procedures relating to the customer service standard.

Applicable staff will be trained on policies, practices and procedures that affect the way goods and services are provided to people with disabilities. Staff will also be trained on an ongoing basis when changes are made to these policies, practices and procedures.

Feedback process

The ultimate goal of Carmens Group is to meet and surpass customer expectations while serving customers with disabilities. Comments on our services regarding how well those expectations are being met are welcome and appreciated.

Feedback regarding the way Carmens Group provides goods and services to people with disabilities can be made by e-mail, verbally, or feedback card. All feedback will be directed to the Accessibility Coordinator.  Customers can expect to hear back within 5 business days.

Complaints will be addressed according to complaint categories already established in our company’s complaint management procedures.

Carmens Group will make sure our feedback process is accessible to people with disabilities by providing or arranging for accessible formats and communication supports, on request.

Notice of availability of documents

Carmens Group will notify the public that documents related to accessible customer service, are available upon request by posting a notice on our company web page.

Carmens Group will provide this document in an accessible format or with communication support, on request. We will consult with the person making the request to determine the suitability of the format or communication support. We will provide the accessible format in a timely manner and, at no additional cost.

Modifications to this or other policies

We are committed to developing customer service policies that respect and promote the dignity and independence of people with disabilities. Therefore, no changes will be made to this policy before considering the impact on people with disabilities. Any policy of Carmens Group that does not respect and promote the dignity and independence of people with disabilities will be modified or removed.

Questions about this policy

This policy exists to achieve service excellence to customers with disabilities. If anyone has a question about the policy, or if the purpose of a policy is not understood, an explanation should be provided by, or referred to, Accessibility Coordinator of Carmens Group

Statement of Organizational Commitment

Carmens Group is committed to meeting the objectives and requirements outlined in the IASR under the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) and meeting the needs of people with disabilities, in a timely manner, through the implementation of the requirements of the AODA.

POLICY

PART 1: GENERAL

1.1 Multi-Year Accessibility Plan and Accessibility Reports

Carmens Group shall establish, implement, maintain and document a Multi-Year Accessibility. The Multi-Year Accessibility Plan will outline Carmen’s Group’s strategy to prevent and remove barriers and meet the requirements under the IASR.

The Multi-Year Accessibility Plan will be posted on the Company website and will be provided in an accessible format upon request.

The Multi-Year Accessibility Plan will be reviewed and updated at least once every 5 years.

Carmens Group shall file an accessibility report with the Province annually or at such other times as may be specified. Accessibility reports shall be made publicly available.

1.2 Training

Carmens Group will provide training to employees, volunteers and other staff members on the requirements of the accessibility standards in the IASR and on the Ontario Human Rights Code as it relates to persons with disabilities. Training will be provided as soon as practicable. Training will be provided in a way that best suits the duties of employees, volunteers and other staff members. The Company will maintain a record of the dates training is provided and the number of individuals to whom it was provided.

1.3 Self-Service Kiosks

Carmens Group will have regard to accessibility for persons with disabilities when designing, procuring or acquiring self-service kiosks.

PART 2: ACCESSIBLE INFORMATION AND COMMUNICATIONS STANDARDS

2.1 Accessible Emergency Information

Emergency procedures, plans or public safety information, that is publicly available, shall be provided in an accessible format or with appropriate communication supports, as soon as practicable upon request.

2.2 Feedback Process

Carmens Group has a process in place to receive and respond to customer feedback and will take steps to ensure those processes are accessible to persons with disabilities Carmens Group will provide or arrange for the provision of accessible formats and communication supports as soon as practicable upon request. Customers are notified regarding the availability of accessible formats and communication supports on our website.

2.3 Accessible Formats and Communication Supports

Carmens Group will upon request provide or arrange for the provision of accessible formats and communication supports for persons with disabilities at a cost that is no more than the regular cost charged to other persons and in a timely manner (as soon as practicable) that takes into account the person’s accessibility needs due to disability.

Carmens Group will consult with the person making the request in determining the suitability of an alternative format or communication support

Customers are notified on the Company website about the availability of accessible formats and communication supports.

Note that IASR does not apply to product and product labels, unconvertible information and communication, information that Carmens Group does not control directly or indirectly through a contractual relationship. In the event the Company determines it is not technically feasible to convert the information or communications or the technology to convert the information or communications is not readily available, the Company will provide the person that requires the information an explanation as to why the information or communications are unconvertible.

2.4 Accessible Websites and Web Content

The Company shall make its internet website and web content conform to World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, initially at Level A and increasing to Level AA. By January 1, 2021 all internet website and web content published after 2012 will conform to0 Level AA to the extent practicable other than criteria 1.2.4 (captions) and 1.2.5 (pre-recorded audio descriptions).

Note that WCAG2.0 requirements only apply to websites, web content and web based applications that an organization can control either directly or through a contractual relationship and where meeting the requirements are technically feasible, including considering the availability of commercial software or tools or both.

PART 3: ACCESSIBLE EMPLOYMENT STANDARDS

The Accessible Employment Standards apply to all paid employees. Carmens Group will inform employees of the policies and changes in policies used to support employees with disabilities throughout the employment life cycle.

3.1 Recruitment, Assessment, Selection

Carmens Group will specify that accommodation is available for applicants with disabilities in its recruitment processes on the website and on job postings.

Carmens Group will inform internal and external job applicants when they are individually selected to participate in an assessment or selection process, that accommodations are available upon request to participate in the recruitment process.

If a selected applicant requests an accommodation, the Company will consult with the applicant and provide or arrange for the provision of a suitable accommodation, having regard for the applicant’s accessibility needs.

When making an offer of employment, Carmens Group will notify the successful applicant of the policies for accommodating workers with disabilities at the time of the offer and as soon as practicable after the new employee begins work (specifically, during orientation).

3.2 Informing Employees of Supports

Carmens Group informs employees of policies used to support employees with disabilities including policies on the provision of job accommodation that take into an account the employee’s accessibility needs.

The information will be provided to new employees as soon as practicable after they begin their employment.

Updated information will be provided to employees whenever there is a change to existing policies on the provision of job accommodations.

3.3 Accessible Formats and Communication Supports for Employees

When requested by an employee, Carmens Group will consult with the employee to provide or arrange for the provision of accessible formats and communication supports for information that is needed in order to perform the employee’s job and also for information generally available to employees in the workplace. Carmens Group will consult with the employee making the request in determining the suitability of an accessible format or communication support.

3.4 Individualized Workplace Emergency Response Information

Carmens Group will provide individualized workplace emergency response information to employees who have a disability if the disability is such that individualized information is necessary and Carmens Group is aware of the need for accommodation due to the disability.

If an employee who receives individualized workplace emergency response information requires assistance and with the employee’s consent, Carmens Group will provide the workplace emergency response information to the person designated by Carmens Group to provide assistance to the employee.

Individualized workplace emergency response information will be reviewed when an employee moves to a different location within the organization, when the employee’s overall accommodation needs or plans are reviewed and when Carmens Group reviews its general emergency response policies.

3.5 Documented individual accommodation plans

Carmens Group has a written process for the development of an Individual Accommodation Plan (IAP) for employees with disabilities. In accordance with the IASR, the process includes:

1. the manner in which an employee requesting accommodating can participate in the development of the individual 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 workplace representative 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.

Individual accommodation plans shall: if requested, include any information regarding accessible formats and communications supports provided; if required, include individualized workplace emergency response information; and identify any other accommodation that is to be provided.

3.6 Return to work

Carmens Group has a written return to work process for employees who have been absent from work due to a disability and require disability-related accommodation to return to work. The return to work process:

1. outlines the steps the Company will take to facilitate the return to work of employees who were absent because their disability required them to be away from work; and
2. uses documented IAPs as described above.

3.7 Performance Management, Career Development, Advancement & Redeployment

Carmens Group shall take into account the accessibility needs of employees with disabilities and IAPs in its performance management processes, when providing career development and advancement opportunities and when considering redeployment of employees with disabilities.

PART 4: DESIGN OF PUBLIC SPACES STANDARDS

The Accessibility Standards for the Built Environment focus on removing barriers in two areas:

1. public spaces, and
2. buildings

Enhancements to accessibility in buildings will happen at a later date through Ontario’s Building Code, which governs new construction and renovations in buildings.

4.1 Public Spaces

Carmens Group shall incorporate accessibility into public spaces that are newly constructed or redeveloped where practicable on and after January 1, 2017.

Public spaces include exterior paths of travel, parking, service counters, queuing lines, waiting areas, maintain accessible parts of public spaces, recreation trails and beach access routes, outdoor public eating areas, outdoor play spaces.

For questions or clarifications, please contact

Email: peopleteam@carmensgroup.com
Phone: 905-381-9817
Fax: 905-574-1480
Write:
Erin Simon
1 King Street West, Suite 1200
Hamilton, ON L8P 1A4

APPENDIX

Related Documents

Ontarians with Disabilities Act, 2001

Accessibility for Ontarians with Disabilities, 2005

Ontario Regulation 191/11 – Integrated Accessibility Standards

Ontario Regulation 429-07 – Accessibility Standards for Customer Service

Accessible Customer Service Policy

Ontario Human Rights Code

DEFINITIONS

Disability, as defined by the AODA and the Ontario Human Rights Code, is:

any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device, a condition of mental impairment or a developmental disability, a learning disability, or 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.

Statement of Organizational Commitment

Carmens Group is committed to meeting the objectives and requirements outlined in the IASR under the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) and meeting the needs of people with disabilities, in a timely manner, through the implementation of the requirements of the AODA.

PART 1: General

PART 2: Information & Communication Standards

PART 3: Employment Standards

PART 4: Design of Public Spaces