The City of Toronto Corporate Accessibility Policy (hereafter referred to as the “Policy”) establishes a framework for compliance with the City’s commitment to accessibility, requirements of the Accessibility for Ontarians with Disabilities Act, 2005 (AODA), requirements of the Integrated Accessibility Standards Regulation (IASR) under the AODA, and additional City requirements.
The City of Toronto is committed to building an inclusive society that values the contributions of people with disabilities. It is committed to providing an accessible environment in which people with disabilities can access the City’s goods, services, and facilities, including all buildings, public spaces, information and communications, in a way that meets their individual needs. The City is committed to the identification, removal and prevention of accessibility barriers, including attitudinal, systemic, information, communications and technology, and built environment and physical barriers.
The AODA provides for the development, implementation and enforcement of accessibility standards in order to achieve accessibility for persons with disabilities in all aspects of society. The City must meet requirements in key areas including:
All City policies, procedures, bylaws, standards and guidelines must comply with the AODA, and provide for dignity, independence, integration and equal opportunity for people with disabilities. In all of the key areas listed above, the AODA requires the City to:
This Policy applies to all City employees, volunteers, and accountability offices.
Any individual or third party organization that provides goods, services, and facilities on behalf of the City is also required to demonstrate compliance with AODA.
The Employment Standards Requirements in Section 8 apply only to employees of the City.
City goods, services and facilities are to be available to people with disabilities in a manner that:
Accessibility is a shared responsibility and everyone has a part to play in making the City accessible to residents, visitors, and co-workers, as described in the following roles and responsibilities.
All employees and other persons acting on behalf of the City must:
In addition to the roles and responsibilities in Section 4.1 of this Policy, individuals with management and supervisory roles must:
In addition to roles and responsibilities in Sections 4.1 and 4.2 of this Policy, the City Manager, Deputy City Managers and Division Heads must:
The City Manager is responsible for promoting awareness of the Policy and for reporting compliance to the Province, in accordance with AODA reporting deadlines, with support from the Chief People Officer, People & Equity Division.
The AODA requires the council of every municipality with a population over 10,000 to have an Accessibility Advisory Committee, and that a majority of committee members must be persons with disabilities.
The Toronto Accessibility Advisory Committee is required under AODA. The mandate of the committee is to:
In addition to the Toronto Accessibility Advisory Committee, divisional and program advisory bodies, will also be consulted as appropriate.
The City will ensure the general requirements of the Integrated Accessibility Standards Regulation (IASR) under the AODA are met in order to achieve accessibility for persons with disabilities.
The AODA requires the City to maintain one or more policies governing how the organization will achieve the requirements of the IASR. The City must also make such documents available to the public, and in accessible formats upon request. This Policy is adopted in compliance with this obligation.
The AODA requires the City to establish, implement, maintain and make public a Multi-Year Accessibility Plan outlining the corporate strategy to identify, remove and prevent barriers and to meet the legislated requirements of the IASR. The plan must be developed in consultation with the Accessibility Advisory Committee and people with disabilities. It must be posted on the City’s website and made available in an accessible format or with appropriate communications supports as soon as possible upon request.
As required by the AODA, when acquiring or procuring goods, services, and facilities, the City must incorporate accessibility criteria and features, and will do so as early as possible in the procurement process. Where it is not practicable to do so, an explanation must be provided upon request, in accordance with City Accessible Procurement Guidelines.
Ensuring accessibility is incorporated into all procurement activities is the primary responsibility of the divisions who manage these activities and contracts. Any third parties that provide goods, services and facilities on the City’s behalf must ensure their staff has received appropriate training as required by the IASR.
The City requires any third-party that is contracted to provide a service on behalf of the City to sign a ‘Declaration of Compliance with Anti-Harassment/Discrimination Legislation and City Policy’ form confirming that they will uphold City policies and their obligations under provincial legislation, including the provision of accessibility training. Third parties may be required to provide records to show training has been done.
The AODA requires the City to incorporate accessibility features when designing, procuring or acquiring self-serve electronic kiosks (interactive electronic terminals).
The AODA requires that all employees, volunteers and persons who participate in developing City policies must receive training on the AODA, the Ontario Human Rights Code, and Accessible Customer Service. Training must take place as soon as possible and be appropriate to the person’s role. The City must keep a record of the training provided to employees and volunteers, including the dates on which accessibility training took place and the names of individuals trained.
Training must include:
The City will provide accessible information and communication by preventing and removing barriers, and providing accessible formats or communication supports to individuals that identify a barrier to accessibility. This section of the Policy addresses the City’s requirements of the IASR Information and Communications Standards under the AODA.
The AODA requires that all information and communications that the City produces, directly or indirectly through contractual relationships, must be made available in accessible formats upon request.
When an accessible format or communication support is requested, the City must consult with the person making the request to determine which format or support is required, and provide or make arrangements to provide the material in a reasonable amount of time and at no additional cost to the requestor.
The City’s Accessible Information, Communications, and Technology Guidelines provide technical guidance for achieving accessibility in a broad range of materials and technology environments.
IASR Information and Communication Standards do not apply to products and product labels, unconvertible information or communications, and information that the City does not control directly or indirectly through a contractual relationship.
If, in consultation with the People & Equity Division, the information or communication is determined to be unconvertible, the City must provide the person requesting the information or communication with:
This Policy will be maintained by the People & Equity Division and available on the City’s website.The Policy must be provided to individuals, upon request, in the appropriate format or with communication supports.
The AODA requires that the City’s internet website and web content, controlled directly by the City or through a contractual relationship that allows for modification of the product, must conform to World Wide Web Consortium (W3C) Web Content Accessibility Guidelines (WCAG) 2.0 at Level AA, in accordance with the timelines set out in the IASR and in the Accessible Information, Communications, and Technology Guidelines.
The City of Toronto’s Technology Services Division and the Strategic Communications Division, in consultation with People & Equity Division, are responsible for establishing and maintaining procedures, standards and guidelines to ensure all internet websites and web content is accessible.
City of Toronto divisions that manage their content on the City’s website are responsible for ensuring accessibility based on approved procedures, standards and guidelines, with support from the Technology Services Division and the Strategic Communications Division.
The AODA requires that City emergency procedures, plans or public safety information that is available to the public must be made available in an accessible format or with appropriate communication supports as soon as possible upon request.
The City must have a process in place for receiving and responding to feedback, including feedback on how services are delivered to people with disabilities. The City must make feedback processes accessible to persons with disabilities by providing or arranging for the provision of accessible formats and communication supports upon request.
Feedback will be collected by phone by dialing 3-1-1, or 416-392-CITY (2489), by TTY (Teletypewriter) 416-338-0889, by email at firstname.lastname@example.org, and in person at any of the City’s service locations.
The City will strive for excellence in serving all customers including people with disabilities and is committed to meeting obligations under the Ontario Human Rights Code and the AODA.
Persons with disabilities must not be charged more to access City programs or services.
The AODA requires the City to allow persons with disabilities to use their own assistive devices to obtain, use or benefit from the goods, services, and facilities offered by the City.
In circumstances where a person with a disability is unable to access the City’s services through the use of their own personal assistive device, the City must assess service delivery and potential service options to meet the needs of the individual, in accordance with the Ontario Human Rights Code and the City’s Accommodation Policy.
Where City owned assistive devices are available, the AODA requires that they must be kept in good working order and the public must be informed of their availability. Staff within the applicable division must be trained in the application and use of the devices.
Where a person with a disability accessing City goods, services, or facilities is accompanied by a support person, the AODA requires the City to ensure that both persons are permitted to enter the premises together and the person with a disability is not prevented from having access to the support person while on the premises.
The AODA requires that persons with disabilities accompanied by their service animal must be permitted to keep that animal with them in premises that members of the public are permitted to enter. Please see Section 13 for a definition of service animal.
In the event the animal is excluded by law, such as in a food preparation area, the City must ensure other measures are available to enable the person with a disability to obtain, use or benefit from City goods, services, and facilities. Staff will respectfully explain why the animal is excluded and determine what other arrangements can be made.
When serving two customers that have different needs, such as serving a customer that has a service animal and a customer that has an allergy to animals, staff will determine how to best meet the needs of both individuals and observe the rights of all individuals involved, according to the Ontario Human Rights Code and the City’s Accommodation Policy.
A person with a disability is responsible for the control of their service animal at all times. If the service animal is not kept under control, has bitten another person or animal, or is a menace to the safety of other persons or animals, the service animal may be required to leave the premises. If this occurs the person will be permitted to continue to access the City goods or services without the animal. In addition, City employees will, upon request, consider alternate accommodations for the person in such circumstances. The City may refuse to permit the service animal to accompany the person until steps have been taken to correct the situation, and the issue has been resolved.
The AODA requires the City to give notice of any temporary planned or unplanned service disruption of facilities, services or systems that are relied upon by people with disabilities to access City goods, services or facilities, such as elevators, lifts, or accessible washrooms. In the event of an unexpected disruption, notice must be provided as soon as possible.
Notice must include information about the reason for the disruption, its anticipated duration and a description of alternative facilities, services or systems that are available.
Notice must be given by posting the information in a prominent place on premises owned or operated by the provider, posted on the City’s website or social media, included on telephone recordings, or by other methods as is reasonable under the circumstances.
The City of Toronto will foster an inclusive workforce and provide equitable treatment and accommodation to ensure barrier-free employment. The requirements in this section apply only to employees of the City. Volunteers and other non-paid individuals are not captured under this section. This section addresses the City’s requirements of the IASR Employment Standards under the AODA.
The City must post information about the availability of accommodations for internal and external job applicants with disabilities in its recruitment process. Job applicants who are individually selected for an interview and/or testing must be notified that accommodations are available on request. The City must consult with an applicant who requests an accommodation and, in accordance with the Ontario Human Rights Code and the City’s Accommodation Policy, will provide or arrange for the provision of a suitable accommodation in a timely manner that takes into account the applicant’s accessibility needs due to disability. Successful applicants must be notified about the City’s policies for accommodating employees with disabilities as part of their offer of employment.
City employees must be made aware of the policies used to support employees with disabilities and accommodations available in accordance with the Ontario Human Rights Code and the City’s Accommodation Policy. The City provides this information to new employees through employment agreements and orientation materials, and must provide updated information to all employees whenever there is a change to existing policies on the provision of job accommodations that take into account an employee’s accessibility needs due to disability.
In accordance with the Ontario Human Rights Code and the City’s Accommodation Policy, upon an employee’s request, the City must consult with the employee to provide or arrange for the provision of accessible formats and communication supports for:
The City must consult with the employee making the request in determining the suitability of an accessible format or communications support. The City Accessible Information, Communications and Technology Guidelines provide technical guidance for achieving accessible information and communications.
The City will provide individualized emergency response information to employees who identify potential accessibility barriers when responding to emergency situations. If the employee requires assistance, the City must receive consent from the employee to provide the individualized emergency response information to the person(s) designated to provide assistance. The information must be reviewed when the employee moves to a different location, when the employee’s accommodation needs change, when overall accommodation plans are reviewed and when the City reviews its general emergency response plan.
The City’s Accommodation Policy describes the mandatory process for the development and maintenance of documented individual accommodation plans to support employees with disabilities. The process set out in the policy meets requirements of the AODA. If applicable, individual accommodation plans may include information regarding plans for accessible formats and communication supports, as well as individualized workplace emergency response information.
The City must have in place a documented return to work process for employees returning to work following an illness or injury where disability-related accommodations are required. This requirement is met through return to work processes supported by Occupational Health and Safety staff consistent with the collective agreements and return to work protocols.
The City will ensure employees with disabilities or individual accommodation plans are provided equitable access to career development, performance management and redeployment opportunities.
This section of the Policy addresses the City’s requirements of the IASR Transportation Standards under the AODA, which are applicable to the Toronto Island Ferry, design of bus stops and shelters, and licensing of vehicles-for-hire, which includes taxicabs and ride-sharing services.
The Toronto Transit Commission (TTC) manages conventional and specialized transportation services, and maintains their own policies and plans. Visit the TTC’s Accessibility website page for details (In accordance with City of Toronto Municipal Code Chapter 192, Public Service, agencies including the TTC are part of the broader public service with authority to manage their own affairs).
The City will operate the Toronto Island Ferry in compliance with AODA and as required by the IASR Transportation Standards.
The AODA requires the City’s Accessibility Advisory Committee, the public, and persons with disabilities to be consulted when developing design criteria for the construction, renovation, or replacement of bus stops and shelters.
The AODA requires the City to consult with the Accessibility Advisory Committee, the public, and persons with disabilities on the appropriate proportion of on-demand accessible taxicabs, and report on the progress and steps taken toward meeting the need in its Multi-Year Accessibility Plan, and progress status reports.
Owners and operators of vehicles-for-hire licensed by the City of Toronto are prohibited from charging an additional fee for persons with disabilities, or a higher fare than for persons without disabilities for the same trip. At no time will a fee be charged for the storage of mobility aids or mobility assistive devices.
In addition to meeting AODA requirements, vehicles-for-hire must adhere to the City bylaw Chapter 546, which includes that:
The City will ensure accessibility at all its facilities and public spaces by designing with accessibility in mind.
The Ontario Building Code, which has a section on Barrier-Free Design, and the AODA, IASR Design of Public Spaces Standards are both standards to which the City must adhere. These standards establish the minimum threshold for accessibility in the built environment.
The City maintains the Toronto Accessibility Design Guidelines (TADG). The TADG acts as a mandatory guiding standard of excellence in accessibility for newly constructed buildings, renovated City facilities and public spaces. Updated periodically to address changing legislation and industry best practices, the TADG aims to meet or exceed the Ontario Building Code (OBC) Barrier-Free Requirements, and the AODA Design of Public Spaces Standards.
In addition to technical design requirements for making public spaces accessible, the AODA also establishes requirements for service environments, maintenance of accessible elements and for the consultation of people with disabilities on accessibility of public spaces.
When constructing or replacing service counters, fixed queuing guides and waiting areas, the AODA requires the City to make them accessible to people with disabilities.
The AODA requires the City to develop and implement procedures for preventative and emergency maintenance and temporary disruptions of accessible elements in public spaces.
The AODA requires the City to provide opportunity for public consultation on the development or re-development of public spaces, including:
The City must submit completed compliance reports to the Province every two years, in accordance with the schedule set out in the AODA.
Failure to comply with this Policy may result in disciplinary action, up to and including dismissal. The City’s failure to comply with AODA may result in significant fines and reputational damage.
A concept integral to human rights that refers to the absence of barriers that prevent individuals and/or groups from fully participating in all social, economic, political and cultural aspects of society. The term is often linked to people with disabilities and their rights to access, and also refers to design characteristics of products, devices, information, services, facilities or public spaces that enable independent use, or support when required, and access by people with a variety of disabilities.
Refers to products, devices, information, services, facilities or public spaces that provide for independent, equitable and dignified access for people with disabilities, including but not limited to those with visual, auditory, sensory, cognitive and mobility related disabilities. The concept of accessible design ensures both “direct access” (i.e. unassisted) and “indirect access,” referring to compatibility with a person’s assistive technology.
Refers to formats that are usable by persons with disabilities including but not limited to: large print, recorded audio and electronic formats, and Braille.
In the context of Human Rights, accommodation means preventing and removing barriers caused by attitudinal, systemic, physical, information or communications, and technology barriers that unfairly exclude individuals or groups protected by Ontario’s Human Rights Code from having equal access to full benefits available to others. Principles of accommodation include dignity, individualization and inclusion or integration. For more information refer to Ontario’s Human Rights Code and the City’s Accommodation Policy.
Refers to technical aids, communication devices, or medical aids modified or customized for use to increase, maintain or improve the functional ability of a person with a disability including but not limited to wheelchairs, walkers, white canes, note taking devices, portable magnifiers, recording machines, assistive listening devices, personal oxygen tanks and devices for grasping. Assistive devices may accompany the customer or already be on the premises for the purpose of assisting persons with disabilities in carrying out activities or in accessing the services provided by the City.
Defined by the AODA as anything that prevents a person with a disability from fully participating in all aspects of society because of his or her disability, including a physical barrier, an architectural barrier, an information or communications barrier, an attitudinal barrier, a technological barrier, a policy or a practice.
Defined by the AODA as the provision of additional responsibility within an employee’s current position or movement from one job to another within the organization that may be higher in pay, provide greater responsibility, or be at a higher level in the organization.
Means the City of Toronto.
Refers to interaction between two or more persons or entities, or any combination of them, where information is provided, sent or received.
Includes, but is not limited to, captioning, alternative and augmentative communications supports, plain language, sign language and other supports that facilitate effective communications.
An electronic or digital format that facilitates conversion into an accessible format such as Braille, large print, audio cassettes CDs DVDs, etc.
“Disability” is defined, per Section 2 of the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11 and the Ontario Human Rights Code, R.S.O. 1990, c. H.19, as follows:
(a) 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,
(b) a condition of mental impairment or a developmental disability,
(c) a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,
(d) a mental disorder, or
(e) an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.
All aspects of the City as an employer and service provider, including: delivery of goods, services, and programs, all information and communication including verbal, print, audio, video, websites, web applications and web content, and other digital technologies including kiosks, and all buildings, facilities, public spaces, and the public realm.
Includes but is not limited to data, facts and knowledge that exists in any format, including text, audio, digital, or images that convey meaning.
Refers to 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.
Refers to either a website with a new domain name or a website with an existing domain name undergoing a significant refresh.
Defined by the AODA as a program that defines and assesses employee performance, productivity and effectiveness, with the goal of facilitating employee success.
Capable of being done or put into practice; capable of being used. Factors relevant to determining if accessibility is practicable may include:
Defined in City bylaw Chapter 546, Licensing of Vehicles-for-hire as any person who, in any manner, accepts, facilitates or brokers requests for or advertises or offers transportation in a private vehicle-for-hire to passengers for trips and who is or is required to be licensed by the City. PTC vehicles includes ride-sharing services that are booked with web-based booking applications. PTC vehicles do not include taxicabs or limousines licensed by the City.
Refers to outdoor recreational trails, beach access routes, boardwalks, ramps, outdoor public use eating areas, outdoor play spaces, outdoor paths of travel, accessible parking and service counters.
Assigning an employee to another job or department within the organization as an alternative to layoff, when a particular job or department within the organization has been downsized or eliminated.
Defined by Section 80.45 (4) of the AODA Customer Service Standards (O.Reg 165/16) as follows:
an 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 professional confirming that the person requires the animal for reasons relating to the disability:
- A member of the College of Audiologists and SpeechLanguage Pathologists of Ontario
- A member of the College of Chiropractors of Ontario
- A member of the College of Nurses of Ontario
- A member of the College of Occupational Therapists of Ontario
- A member of the College of Optometrists of Ontario
- A member of the College of Physicians and Surgeons of Ontario
- A member of the College of Physiotherapists of Ontario
- A member of the College of Psychologists of Ontario
- A member of the College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario.
An individual who accompanies a person with a disability to help with communication, mobility, personal care or medical needs or with access to goods or services.
As defined by City bylaw Chapter 546, Licensing of Vehicles-for-hire, a taxicab includes any vehicle with up to seven passengers plus the driver providing transportation to passengers at a public or private taxicab stand, in response to street hails from passengers, or in response to requests for service received through a taxicab broker, as well as any vehicle providing transportation to passengers that displays any sign or marking identifying, or likely to be perceived by a member of the public as identifying, the vehicle to be a taxicab.
Information or communications are unconvertible if it is not technically feasible to convert the information and communication, or the technology to convert the information and communication is not readily available.
Include owners, operators and drivers of taxicabs, and private transportation companies (PTC) and their drivers, as defined in City of Toronto Municipal Code Chapter 546, Licensing of Vehicles-for-hire.
June 26, 2018