Accessible Customer Service Policy

6.35 Rev. 2 | June 30, 2013

A printable PDF of this policy is available for download here in regular, and large format.

Intent
This policy is intended to meet the requirements of Accessibility Standards for Customer Service, Ontario Regulation 429/07 under the Accessibility for Ontarians with Disabilities Act, 2005 and applies to the provision of goods and services to the public or other third parties, not to the goods themselves.

All goods and services provided by Glenn Davis Group Inc. shall follow the principles of dignity, independence, integration and equal opportunity.

Scope
This policy applies to the provision of goods and services at premises owned and operated by Glenn Davis Group Inc., incorporating agencies Bridgemark and Davis (hereinafter referred to as “the Company”).

This policy applies to employees, volunteers, agents and/or contractors who deal with the public or other third parties that act on behalf of the Company, including when the provision of goods and services occurs off Company premises such as delivery services, client premises or third party vendors (i.e., printers or photographers).

The section of this policy that addresses the use of guide dogs, service animals and service dogs only applies to the provision of goods and services that take place at premises owned and operated by the Company.

This policy shall also apply to all persons who participate in the development of Company policies, practices and procedures governing the provision of goods and services to members of the public or third parties.

Definitions (see Appendix)

General Principles
In accordance with the Accessibility Standards for Customer Service, Ontario Regulation 429/07, this policy addresses:

  1. The Provision of Goods and Services to Persons with Disabilities
  2. The Use of:
  3. Notice of Service Disruptions
  4. Customer Feedback
  5. Employee Training
  6. Notice of Availability and Format of Documents

A. The Provision of Goods and Services to Persons with Disabilities
Glenn Davis Group 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 services, in the same place and in a similar manner;
  • 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 our services;
  • taking into account individual needs when providing goods and services; and
  • communicating in a manner that takes into account the customer's disability.

B. The Use of Assistive Devices, Service Animals and Support Personnel
Persons with disabilities may use their own assistive devices, service animals and support personnel as required when accessing goods or services provided by the Company.

In cases where this 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 no elevators are 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.

If a customer with a disability is accompanied by a support person, consent will be obtained from the customer to include the support person prior to any conversation where confidential information might be discussed.

A customer with a disability that is accompanied by guide dog or service dog will be allowed access to public food service areas unless otherwise excluded by law. Other types of service animals are not permitted into food service areas due to the Health Protection and Promotion Act, Ontario Regulation 562 Section 60.

  • Exclusion Guidelines:
    If a guide dog, service animal or service dog is excluded by law (see applicable laws below), the Company will offer alternative methods to enable the person with a disability to access goods and services, when possible (for example, securing the animal in a safe location and offering the guidance of an employee).
  • Applicable Laws:
    Dog Owners' Liability Act, Ontario: If there is a conflict between a provision of this Act or of a regulation under this or any other Act relating to banned breeds (such as pitbulls) and a provision of a by-law passed by a municipality relating to these breeds, the provision that is more restrictive in relation to controls or bans on these breeds prevails.

Recognizing a Guide Dog, Service Dog and/or Service Animal, Care & Control
The customer that is accompanied by a guide dog, service dog and/or service animal is responsible for maintaining care and control of the animal at all times.

  • Health & Safety Concerns — Allergies
    If a health and safety concern presents itself in the form of a severe allergy to the animal, the Company will make all reasonable efforts to meet the needs of all individuals.

    In order that reasonable accommodations can be made for all parties, if you have a severe allergy to animals:
    • Employees should notify the HR Department and ensure the allergy is on file.
    • Customers should notify Reception and/or the person with whom they are meeting.

If there are any concerns, and if it is not readily apparent that the animal is being used by the customer for reasons relating to his or her disability, the Company may request verification from the customer:

  • a letter from a physician or nurse confirming that the person requires the animal for reasons related to the disability;
  • a valid identification card signed by the Attorney General of Canada;
  • a certificate of training from a recognized guide dog or service animal training school.

“No pet” policies do not apply to guide dogs, service animals and/or service dogs.

C. Notice of Service Disruptions
Temporary service disruptions may occur due to reasons that may or may not be within the Company’s control or knowledge (i.e., power outages and/or disruptions to elevator service). In these cases, 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.

Notifications will be made as necessary via e-mail, our website, via phone to affected individuals or posted in a public area near the disruptive service describing the service that is unavailable, the reason for the disruption, anticipated duration and description of alternative services or options.

Notification Options:
When disruptions occur the Company will provide notice by:

  • posting notices in conspicuous places including at the point of disruption, at the main entrance and the nearest accessible entrance to the service disruption and/or on the Company website;
  • contacting customers with appointments;
  • verbally notifying customers when they are making a reservation or appointment;
  • by any other method that may be reasonable under the circumstances.

D. Customer Feedback
The Company welcomes feedback on the service provided to customers with disabilities. Feedback can be submitted:

By e-mail In writing Verbally (in person or telephone)
Via our Company
website contact forms,
or to any Company employee.
VP HR, Glenn Davis Group
77 City Centre Drive
West Tower 2nd Floor
Mississauga, ON L5B 1M5
To any Glenn Davis Group employee

Customers who provide formal feedback will receive acknowledgement of their feedback, along with any resulting actions based on concerns or complaints that were submitted.

E. Employee Training
Training will be provided to all employees who deal with the public (including managers, contractors and/or other third parties that act on behalf of the Company such as drivers or vendors) and those who are involved in the development and approval of customer service policies, practices and procedures.

Training Provisions:
As reflected in Ontario Regulation 429/07, regardless of the format, training will cover the following:

  • A review of the purpose of the Accessibility for Ontarians with Disabilities Act, 2005.
  • A review of the requirements of the Accessibility Standards for Customer Service, Ontario Regulation 429/07.
  • Instructions on how to interact and communicate with people with various types of disabilities.
  • Instructions on how to interact with people with disabilities who:
    • use assistive devices;
    • require the assistance of a guide dog, service dog or other service animal; or
    • require the use of a support person.
  • Instructions on equipment or devices that are available at our premises or that may help people with disabilities.
  • Instructions on what to do if a person with a disability is having difficulty accessing our services.
  • Company policies, procedures and practices pertaining to providing accessible customer service to customers with disabilities.

Training Schedule/Record of Training
Existing employees have been trained as of January 1, 2012. New Employees will be trained as part of our Orientation and Training Schedule. Revised training will be provided in the event of changes to legislation, procedures and/or practices.

The Company will keep a record of training that includes dates training was provided and number of employees who attended the training.

F. Notice of Availability and Format of Documents
The Company shall notify customers and employees 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 on the Glenn Davis Group website (with links from agency sites) and on our Intranet.

Administration
If you have any questions or concerns about this policy or its related procedures please contact:

VP HR, Glenn Davis Group

905.270.2501
Mailing Address:

Glenn Davis Group
77 City Centre Drive
West Tower 2nd Floor
Mississauga, ON L5B 1M5

This policy and its related procedures will be reviewed as required in the event of legislative changes.

APPENDIX – Definitions
Assistive Device – is 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 customers 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.

Customer – client, supplier or guest visiting any Glenn Davis Group facility or meeting with any Glenn Davis Group employee.

Disability – the term disability as defined by the Accessibility for Ontarians with Disabilities Act, 2005 and the Ontario Human Rights Code, refers to:

  • 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 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.

Guide Dog – is a highly-trained working dog that has been trained at one of the facilities listed in Ontario Regulation 58 under the Blind Persons’ Rights Act, to provide mobility, safety and increased independence for people who are blind.

Service Animal – as reflected in Ontario Regulation 429/07, an animal is a service animal for a person with a disability if:

  • it is readily apparent that the animal is used by the person for reasons relating to his or her disability; or
  • if the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disability.

Service Dog – as reflected in Health Protection and Promotion Act, Ontario Regulation 562 a dog other than a guide dog for the blind is a service dog if:

  • it is readily apparent to an average person that the dog functions as a service dog for a person with a medical disability;
  • or the person who requires the dog can provide on request a letter from a physician or nurse confirming that the person requires a service dog.

Support Person – as reflected in Ontario Regulation 429/07, a support person means, in relation to a person with a disability, another person who accompanies him or her in order to help with communication, mobility, personal care, medical needs or access to goods and services.