Accessibility

Accessible Customer Service Policy

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

Scope

a) This policy applies to the provision of goods and services at premises owned and
operated by RLB LLP.
b) This policy applies to employees, volunteers, agents and/or contractors who deal with
the public or other third parties that act on behalf of RLB LLP, including when the
provision of goods and services occurs off the premises of RLB LLP such as in: delivery
services, call centers, vendors, drivers, catering and third party marketing agencies.
c) 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 RLB LLP.
d) This policy shall also apply to all persons who participate in the development of the RLB
LLP’s policies, practices and procedures governing the provision of goods and services
to members of the public or third parties.

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.

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.

General Principles

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

A. The Provision of Goods and Services to Persons with Disabilities;
B. The Use of Assistive Devices
C. The Use of Guide Dogs, Service Animals and Service Dogs
D. The Use of Support Persons
E. Notice of Service Disruptions
F. Customer Feedback
G. Training
H. Notice of Availability and Format of Required Documents

A. The Provision of Goods and Services to Persons with Disabilities

RLB LLP 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 value and quality;
  • 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 the same services, in the same place and in a similar manner;
  • taking into account individual needs when providing goods and services; and
  • communicating in a manner that takes into account the customer’s disability.

B. Assistive Devices

Customer’s own assistive device(s):

Persons with disabilities may use their own assistive devices as required when accessing goods
or services provided by RLB LLP.

In cases where the assistive device 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, open flames and oxygen tanks cannot be near one another. Therefore, the
accommodation of a customer with an oxygen tank may involve ensuring the customer is in a
location that would be considered safe for both the customer and business. Or, where elevators
are not 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.

C. Guide Dogs, Service Animals and Service Dogs

A customer with a disability that is accompanied by guide dog, service animal or service dog will
be allowed access to premises that are open to the public unless otherwise excluded by law.
“No pet” policies do not apply to guide dogs, service animals and/or service dogs.

Food Service Areas:

A customer with a disability that is accompanied by guide dog or service dog will be allowed
access to food service areas that are open to the public 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)
RLB LLP 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:

Food Safety and Quality Act 2001, Ontario Regulation 31/05: Animals not intended for slaughter
or to be euthanized are not allowed in any area or room of a meat plant. It also makes an
exception for service dogs to allow them in those areas of a meat plant where food is served,
sold or offered for sale to customers and in those areas that do not contain animals or animal
parts and are not used for the receiving, processing, packaging, labelling, shipping, handling or
storing of animals or parts of animals.

The Health Protection and Promotion Act, Ontario Regulation 562 Section 60, normally does not
allow animals in places where food is manufactured, prepared, processed, handled, served,
displayed, stored, sold or offered for sale. It does allow guide dogs and service dogs to go into
places where food is served, sold or offered for sale. However, other types of service animals
are not included in this exception.

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:
If it is not readily apparent that the animal is being used by the customer for reasons relating to
his or her disability, RLB LLP may request verification from the customer.
Verification may include:

  • 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; or,
  • a certificate of training from a recognized guide dog or service animal training
    school.

Care and Control of the Animal:

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 time.

Allergies:

If a health and safety concern presents itself for example in the form of a severe allergy to the
animal, RLB LLP will make all reasonable efforts to meet the needs of all individuals.

D. Support Persons

If a customer with a disability is accompanied by a support person, RLB LLP will ensure that
both persons are allowed to enter the premises together and that the customer is not prevented
from having access to the support person.

There may be times where seating and availability prevent the customer and support person
from sitting beside each other. In these situations RLB LLP will make every reasonable attempt
to resolve the issue.

In situations where confidential information might be discussed, consent will be obtained from
the customer, prior to any conversation where confidential information might be discussed.

Admission Fees:

If payment is required by a support person for admission to the premises RLB LLP will ensure
that notice is given in advance by posting notice of admission fees for support persons where
RLB LLP fees are posted.

E. Notice of Disruptions in Service

Service disruptions may occur due to reasons that may or may not be within the control or
knowledge of RLB LLP. In the event of any temporary disruptions to facilities or services that
customer’s with disabilities rely on to access or use RLB LLP’s goods or services, 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 Include:

In the event that a notification needs to be posted the following information will be included
unless it is not readily available or known:

  • goods or services that are disrupted or unavailable
  • reason for the disruption
  • anticipated duration
  • a description of alternative services or options

Notifications Options:

When disruptions occur RLB LLP 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
    RLB LLP website;
  • contacting customers with appointments;
  • verbally notifying customers when they are making an appointment; or
  • by any other method that may be reasonable under the circumstances.

F. Feedback Process

RLB LLP shall provide customers with the opportunity to provide feedback on the service
provided to customers with disabilities. Information about the feedback process will be readily
available to all customers and notice of the process will be made available by the firm’s website
or contacting the general reception. Feedback forms along with alternate methods of providing
feedback such as verbally (in person or by telephone) or written (hand written, delivered,
website or email), will be available upon request. See Client with Disabilities Feedback Form.

Submitting Feedback:

Customers can submit feedback to:

  • Receptionist(s) or Human Resources
  • (519)822-9933
  •  15 Lewis Rd, Guelph ON N1H 1E9
  • reception@rlb.ca or hr@rlb.ca
  •  www.rlb.ca

Customers who wish to provide feedback by completing an onsite customer feedback form or
verbally can do so to any RLB LLP employee.

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

G. Training

Training will be provided to:

a) all employees, volunteers, agents and/or contractors who deal with the public or other
third parties that act on behalf of RLB LLP; for example: salespersons, drivers, vendors,
event operators, call centers and third party marketing agents; and,
b) 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 (including the handling of admission fees).
  • Instructions on how to use equipment or devices that are available at our premises or
    that we provide that may help people with disabilities.
  • Instructions on what to do if a person with a disability is having difficulty accessing your
    services.
  • RLB LLP’s policies, procedures and practices pertaining to providing accessible
    customer service to customers with disabilities.

Training Schedule:

RLB LLP will provide training as soon as practicable. Training will be provided to new
employees, volunteers, agents and/or contractor who deal with the public or act on our behalf
during orientation. Revised training will be provided in the event of changes to legislation,
procedures and/or practices.

Record of Training:

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

Notice of Availability and Format of Documents

RLB LLP shall notify customers 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 in a conspicuous place
owned and operated by RLB LLP, the RLB LLP’s website and/or any other reasonable method.

Administration

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

  • Crystal Dunlop, Human Resources Manager
  • 519-822-9933 x243
  • 197 Hanlon Creek Blvd, Guelph, ON N1C 0A1
  • Crystal.dunlop@rlb.ca
  • www.rlb.ca

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