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Accessibility Policy

Accessible Customer Service Standard Policy

Town Shoes Limited is committed to providing goods and services in a way that respects the dignity and independence of persons with disabilities. This will be achieved by identifying and removing barriers that impede a person's ability to access goods and services, ensuring everyone is provided with equal opportunities whenever they interact with TSL.

This policy is intended to outline the practices and procedures in place at TSL to meet the first accessibility standard, Accessibility Standards for Customer Service, Ontario Regulations 429/07, requiring all organizations in Ontario to make their customer service accessible as it applies to the provision of goods and services to persons with disabilities.

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:

  1. 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;
  2. A condition of mental impairment or a developmental disability;
  3. A learning disability, or dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
  4. A mental disorder; or
  5. 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:

  1. It is readily apparent that the animal is used by the person for reasons relating to his or her disability; or
  2. If the person provides a letter from a physical or nurse confirming that the person requires the animal for reasons relating to the disability.

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

  1. It is readily apparent to an average person that the dog functions as a service dog for a person with a medical disability;
  2. Or a person who requires the dog can provide on request a letter from a physical 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, TSL’s policies, practices and procedures will be achieved by addressing the following:

  1. The provision of good and services to persons with disabilities
    TSL will make every reasonable to effort to ensure that its policies, practices and procedures are consistent with the AODA principles of dignity, independence, integration and equal opportunity.
    TSL will communicate with persons with disabilities in ways that take into account their disability when providing goods and services.  TSL will also ensure that all persons with disabilities receive the same value and quality of customer service, by allowing them to do things in their own way, and at their own pace when accessing goods and services.  Alternative methods will also be used when possible to ensure that persons with disabilities have access to the same services, in the same place and in a similar manner.

  2. Assistive Devices
    Persons with disabilities may use their own personal assistive devices as required when accessing goods and services provided by TSL.  In cases where the assistive device is not permitted due to a safety concern or where accessibility might be an issue, other reasonable measures will be provided.

  3. Service Animals, Guide Dogs and Service Dogs
    Persons with disabilities may be accompanied by a service animal, guide dog or service dog and allowed access to premises that are open to the public or to other third parties at TSL while accessing our goods and services, unless otherwise excluded by law.

  4. Support Persons
    Persons with disabilities may be accompanied by a support person to assist with communication, mobility, personal care, medical needs or access to goods and services on TSL premises in areas that are open to the public or other third parties.  TSL will ensure that both persons are allowed to enter the premises together and that the person with the disability is not prevented from having access to the support person.  In situations where confidential information might be discussed in front of the support person, consent will be obtained from the person with a disability.

  5. Notice of Disruptions in Service
    Service disruptions may occur due to reasons that may or may not be within the control or knowledge of TSL.  In the event of any temporary disruptions to facilities or services that persons with disability rely on to access or use TSL'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.
    In the event that a notification is posted, it will include information about the goods and services that are disrupted or unavailable, the reason for the disruption, the anticipated duration and a description of alternative services or options, if available.
    Disruptions in service notifications will be posted in conspicuous places including at the point of disruption, at the main entrance of any one of our locations, front reception at our corporate head office and/or on the TSL website and any other method that may be reasonable under the circumstances.

  6. Feedback Process
    The public has the opportunity to provide feedback on the service provided by TSL.  Feedback may be given verbally, in person or telephone, in writing by letter or email, or by filling out an online feedback form.  Upon receipt of your feedback, TSL will respond within 10 business days, and will respond if possible, in the same format that the feedback was received.
    Feedback, as well as questions or concerns about this policy or its related procedures can be submitted to:

    Town Shoes Limited
    Attn: Customer Service
    44 Kodiak Crescent
    Downsview, Ontario
    M3J 3G5
    Tel: 1-888-874-6326
    Email: customerservice@townshoes.com

  7. Training
    Training will be provided to all associates, volunteers, interns, agents, contractors and third parties who deal with the public or other third parties and act on behalf of TSL, and those who are involved in the development and approval of customer service policies, practices and procedures.  This training will be provided as soon as practicable to new associates upon joining TSL, or to associates transferred to new roles with TSL requiring different training, and revised training will be provided in the event of changes to legislation, policy, practices and/or procedures.

    As reflected in Ontario Regulation 429/07, training will cover the following:

    1. A review of the purpose of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the Accessibility Standards for Customer Service, Ontario Regulations 429/07.
    2. Instructions on how to interact and communicate with persons with various types of disabilities.
    3. Instructions on how to interact with persons with disabilities who use an assistive device, or require the assistance of a guide dog, service dog or other service animal; or the use of a support person.
    4. Instructions on how to use equipment or devices that may help with the provision of goods or services to persons with disabilities.
    5. Instructions on what to do if a person with a particular type of disability is having difficulty accessing TSL's goods and services
    6. TSL's policies, procedures and practices pertaining to providing accessible customer service to persons with disabilities.

      TSL will keep a record of training that indicates the date and training type provided, and the number of individuals to whom it was provided.

  8. Notice of Availability and Format of Documents

    TSL will post a sign in a conspicuous location on its premises, on its web site or by another reasonable method, informing the public that this policy and other documents related to the Accessibility Standard for Customer Service are available upon request and will be provided in formats that take into account the customer's disability

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

Multi-Year Accessibility Plan

Purpose

Under the Accessibility for Ontarians with Disabilities Act (AODA), 2005, all public and private sector organizations must meet the requirements of accessibility standards established by the regulation. This policy establishes the Integrated Accessibility Standards Regulation (IASR) in the areas of Employment, Information & Communications, and Public Spaces for TSL in accordance with Ontario Regulation 191/11, Ontario Regulation 413/12 and with the Ministry of Economic Development, Trade and Employment’s intent to “streamline, align and phase-in accessibility requirements and allow for progress on accessibility and reduce the regulatory burden for obligated organizations”. The IASR came into force on July 1, 2011.

Scope and Responsibilities

This plan has been drafted in accordance with the Regulation and addresses how TSL achieves accessibility through meeting the Regulation’s requirements. It provides the overall strategic direction that will be followed to provide accessibility supports to Ontarians with disabilities.The requirements of the Regulation include the following four items:

  1. Establishment, implementation, maintenance and documentation of a multi-year accessibility plan, which outlines the organization’s strategy to prevent and remove barriers and meet its requirements under the Regulation.
  2. Incorporation of accessibility criteria and features when procuring or acquiring goods, services, or facilities.
  3. Training.
  4. Other specific requirements under the Information & Communications, Employment, and Public Spaces standards.

Policy Statement and Organizational Commitment

TSL is committed to providing goods and services in a way that respects the dignity and independence of persons with disabilities. This will be achieved by identifying and removing barriers that impede a person’s ability to access goods and services, ensuring everyone is provided with equal opportunities whenever they interact with TSL.

Definitions

Below is a list of definitions in alphabetical order, which can be found throughout this document:

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

Accommodation means the special arrangement made or assistance provided so that persons with disabilities can participate in the experiences available to persons without disabilities. Accommodation will vary depending on the person’s unique needs.

Associates refers to TSL Associates (Ontario based).

Communications means the interaction between two or more persons or entities, or any combination of them, where information is provided, sent or received. Communication Supports may include, but are not limited to, captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications.

IAP means Individualized Accommodation Plan.

Information includes data, facts and knowledge that exists in any format, including text, audio, digital or images, which conveys meaning.

Internet Website means a collection of related web pages, images, videos or other digital assets that are addressed relative to a common Uniform Resource Identifier (URI) and is accessible to the public.

Maintenance of Public Spaces means activities that are intended to keep existing public spaces and elements in existing public spaces in good working order or to restore the spaces or elements to their original condition, examples of which include painting and minor repairs.

New Internet Website means either a website with a new domain name or a website with an existing domain name undergoing a significant refresh.

Redeployment means the reassignment of Associates to other departments or jobs within the organization.

Unconvertible means if it is not technically feasible to convert the information or communications. It also means if the technology to convert the information or communications is not readily available.

Web Content Accessibility Guidelines means the World Wide Web consortium recommendation, dated December 2008, entitled “Web Content Accessibility Guidelines” (WCAG) 2.0.
General Provisions

This section covers the general requirements of the Integrated Accessibility Standards
Regulation (IASR).

Multi-Year Accessibility Plan
This Multi-Year Accessibility Plan outlines a phased-in strategy to prevent and remove barriers and addresses the current and future requirements of the AODA. TSL will report annually on the progress and implementation of this plan, post the information on our website and will provide it in alternative formats upon request. This plan will be reviewed and updated at least once every five years.

Training
TSL will ensure training is provided on the requirements of the accessibility standards referred to in the Regulation and in the Human Rights Code as it pertains to persons with disabilities. This training will be provided to all Ontario based Associates initially, including volunteers, and third party contractors, who provide goods and services on TSL’s behalf, as well to those who develop the Organization’s policies.

If any changes are made to this policy or the requirements, additional training will be provided.
TSL will maintain a record of the dates when training is provided and the number of individuals who were trained.

Compliance Date: January 1, 2015
Completion Date: January 1, 2015

Information and Communications Standard

TSL will create, provide and receive information and communications in ways that are accessible to people with disabilities. If TSL determines it is not feasible to convert the information or communications or that the technology to convert the information or communications is not readily available, an explanation will be provided as to why the information or communications are unconvertible.

Accessible Emergency Information
TSL has implemented the following as it relates to accessible emergency information:

  1. Emergency procedures and public safety information prepared by TSL are available in accessible formats and with appropriate communication supports, upon request.
  2. Associates trained on emergency procedures are available to support those who require assistance during emergency situations.
  3. All Associates complete annual Emergency Preparedness Training.

Compliance Date: January 1, 2012
Completion Date: Ongoing

Website Accessibility
TSL shall take the following steps to make its internet website and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 initially at Level A and increasing to Level AA:

  1. Ensure that any web content developed internally or externally meets the Information and Communication Standard and that content developers/vendors have the necessary expertise to develop such content.
  2. Ensure that by January 1, 2021 all internet website and web content backdated to 2012 conforms with WCAG 2.0 Level AA.

Compliance Date: New Content (WCAG 2.0 Level A) – January 1, 2014
All Content (WCAG 2.0 Level AA) - January 1, 2021
Completion Date: New content January 1, 2014. All content in progress.

Employment Standard

TSL is committed to fair and accessible employment practices. The Employment Standard builds upon the existing requirements under the Ontario Human Rights Code in relation to how accessibility throughout the entire employment cycle is provided.

Recruitment
TSL shall notify Associates and the public about our accommodation policies and the availability of accommodations for applicants with disabilities throughout the selection process. If a selected applicant requests accommodation, TSL shall consult with the applicant and provide or arrange for the provision of a suitable accommodation that takes into account the applicant’s disability.

Required Legislative Compliance Date: January 1, 2016
Completion Date: In progress

Associate Notification
TSL will review and, as necessary, modify existing orientation and on-boarding processes to ensure new Associates are provided information about TSL’s accessibility policies as soon as practicable after employment commences, including a description of same in new hire information. In addition, TSL will develop and integrate procedures for documenting changes to accessibility policies.

Required Legislative Compliance Date: January 1, 2016
Completion Date: In progress

Accessible Formats and Communication Supports
Upon request, TSL will consult with an Associate, who has a disability, to provide or arrange for the provision of accessible formats and communication supports as outlined below:

  1. Information that is needed in order to perform the Associate’s job.
  2. Information that is generally available to Associates in the workplace.

Required Legislative Compliance Date: January 1, 2016
Completion Date: In progress

Individual Accommodation Plan (IAP) and Return to Work
TSL will take the necessary steps to develop and implement a process for documenting and updating, as required, Individual Accommodation Plans and Return to Work Plans. In addition, TSL will continue to develop and provide appropriate training to Managers and Associates responsible for supporting both the Individualized Accommodation Plan and Return to Work Plan processes on a continuous basis.

Required Legislative Compliance Date: January 1, 2016
Completion Date: In progress

Performance Management, Career Development, and Redeployment

TSL will ensure the following steps:

  1. Review internal policies and procedures to ensure they are in compliance with the IASR, in particular as it relates to performance management, career development and redeployment processes to ensure the accessibility needs and individual accommodation plans of Associates with disabilities are taken into account.
  2. Develop and provide appropriate training to Managers and other Associates responsible for supporting or impacting performance management, career development, and redeployment processes, and a training schedule for same that will ensure compliance with the processes on a continuous basis.

Required Legislative Compliance Date: January 1, 2016
Completion Date: In progress

Workplace Emergency Response Information
TSL shall provide / review individualized workplace emergency response information for
Associates who have a disability:

  1. If the disability is such that the individualized information is necessary and the employer is aware of the need for accommodation due to the Associate’s disability.
  2. If the Associate who receives individual workplace emergency response information requires assistance and with the Associate’s consent, TSL shall provide the workplace emergency information to the person designated by TSL to provide assistance to the Associate.
  3. As soon as practicable after becoming aware of the need for accommodation due to the Associate’s disability.
  4. When the Associate moves to a different location in the Organization; when overall accommodation needs or plans are reviewed; and when the employer reviews its general emergency response policies.

Required Legislative Compliance Date: January 1, 2012
Completion Date: January 1, 2012

Public Spaces

TSL shall incorporate accessibility into public spaces on its premises that are newly constructed or redeveloped on and after January 1, 2017 as follows:

  1. Ensure existing requirements stated under the Design of Public Spaces are adhered to.
  2. Provide maintenance and restoration of public spaces by ensuring procedures are in place for preventative and emergency maintenance of accessible elements in public spaces and that procedures are in place for dealing with temporary disruptions when accessible elements required under this section are not in working order.

Required Legislative Compliance Date: January 1, 2017
Completion Date: In Progress

Contact

TSL welcomes feedback about this plan or how it provides goods or services to persons with disabilities. Members of the public may communicate in the manner deemed most convenient to them, including in person, by telephone, in writing, via Teletypewriter (TTY), or by email or other electronic format.

Feedback or request for documents available in alternative formats can be made through our
Customer Service department:

Town Shoes Limited
Attn: Customer Service
44 Kodiak Crescent
Downsview, Ontario
M3J 3G5
Tel: 1-888-874-6326
Email: customerservice@townshoes.com