Accessibility for Ontarians with Disabilities Act, 2005
Integrated Accessibility Standards – Multi Year Plan
Part I – General Requirements
Requirement Outlined in the Act
| # | Section # from Act | Initiative | Requirement Outlined in the Act | First National's Actions | Status | Compliance Date |
|---|---|---|---|---|---|---|
| 1 | 3 | Establishment of Accessibility Policies | 3.(1) Every obligated organization shall develop, implement and maintain policies governing how the organization achieves or will achieve accessibility through meeting its requirements under the accessibility standards referred to in this Regulation. | Developed and implemented policy. | Completed | January 1, 2014 |
| 2 | 4 | Accessibility Plans | 4.(1) Large organizations shall, a) establish, implement, maintain and document a multi-year accessibility plan, which outlines the organization‘s strategy to prevent and remove barriers and meet its requirements under this Regulation; b) post the accessibility plan on their website, if any, and provide the plan in an accessible format upon request; and c) review and update the accessibility plan at least once every five years. | Completed an accessibility plan by determining barriers that exist at First National. HR reviewed the plan and policy in January 2016 and has committed to reviewing the plan minimally once every 5 years, the next review will occur on January 1st, 2019.
| Completed | January 1, 2014 |
| 3 | 7 | Training | 7.(1) Every obligated organization shall ensure that training is provided on the requirements of the accessibility standards referred to in this Regulation and on the Human Rights Code as it pertains to persons with disabilities to, (a) all employees, and volunteers; (b) all persons who participate in developing the organization‘s policies; and (c) all other persons who provide goods, services or facilities on behalf of the organization. | All existing employees completed training in December 2014 and new employees are required to complete training within 30 days of their start date. | Completed | January 1, 2015 |
Part II - Information and Communications Standards
Requirement Outlined in the Act
| # | Section # from Act | Initiative | Requirement Outlined in the Act | First National's Actions | Status | Compliance Date |
|---|---|---|---|---|---|---|
| 4 | 13 | Emergency Procedures, Plans or Public Safety Information | 13.(1) In addition to its obligations under section 12, if an obligated organization prepares emergency procedures, plans or public safety information and makes the information available to the public, the obligated organization shall provide the information in an accessible format or with appropriate communication supports, as soon as practicable, upon request. | First National does not make this information available to the public however we have established internal procedures for emergency related information. We have confirmed that our landlord is compliant with providing this information to the public. | Not applicable | January 1, 2012 |
| 5 | 14 | Accessible Websites & Web Content | 14.(2) Designated public sector organizations and large organizations shall make their internet websites 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, and shall do so in accordance with the schedule set out in this section. | First National has confirmed that our website meets the accessibility requirements (Level A) identified in this act.
First National will ensure any new vendors meet the requirements outlined in the WCAG 2.0. | Completed
Completed | January 1, 2014 All internet websites and web content must conform with WCAG 2.0 Level AA, other than, • success criteria 1.2.4 Captions (Live) • success criteria 1.2.5 Audio Descriptions (Pre-recorded). |
| 6 | 11 | Feedback | 11.(1) Every obligated organization that has processes for receiving and responding to feedback shall ensure that the processes are accessible to persons with disabilities by providing or arranging for accessible formats and communications supports, upon request. | The person making the accommodation request will be consulted prior to arranging any accessible formats and communications support and will meet the criteria as outlined in this section. | Completed | January 1, 2015 |
| 7 | 12 | Accessible Formats & Communication Supports | 12.(1) Except as otherwise provided, every obligated organization shall upon request provide or arrange for the provision of accessible formats and communication supports for persons with disabilities, a) in a timely manner that takes into account the person‘s accessibility needs due to disability; and b) at a cost that is no more than the regular cost charged to other persons. | The person marking the accommodation request will be consulted prior to arranging any accessible formats and communications support and First National will meet the criteria as outlined in this section. | Completed | January 1, 2016 |
| 12.(2) The obligated organization shall consult with the person making the request in determining the suitability of an accessible format or communication support. | The person making the accommodation request will be consulted prior to arranging any accessible formats and communications support and First National will meet the criteria as outlined in this section. | Completed | January 1, 2016 | |||
| 12.(3) Every obligated organization shall notify the public about the availability of accessible formats and communication supports. | The availability of accessible formats and communication supports is included in a variety of public places, including but not limited to the company's website, job postings, etc. | Completed | January 1, 2016 |
Part III - Employment Standard
Requirement Outlined in the Act| # | Section # from Act | Initiative | Requirement Outlined in the Act | First National's Actions | Status | Compliance Date |
|---|---|---|---|---|---|---|
| 8 | 27 | Workplace Emergency Response Information | 27.(1) Every employer shall provide individualized workplace emergency response information to employees who have a disability if the disability is such that the individualized information is necessary and the employer is aware of the need for accommodation due to the employee‘s disability. | First National sends quarterly email reminders to all of its employees to advise the HR team if they require assistance during a workplace emergency (this includes employees beginning a return to work plan). New employees are also
advised during the New Hire Orientation which occurs within one month of their start date. HR and the employee’s Manager will work with the employee that requires assistance and create a plan based on the type of accommodation required during a workplace emergency. Employees are required to complete the Individualized Employee Emergency Response Information Form. First National has documented internal procedures referred to as the Fire Safety Evacuation Procedures for each office. | Completed | January 1, 2012 |
| 9 | (2) If an employee who receives individualized workplace emergency response information requires assistance and with the employee‘s consent, the employer shall provide the workplace emergency response information to the person designated
by the employer to provide assistance to the employee. | First National’s Joint Health and Safety Committee, Health and Safety Coordinator, Management team and the HR team may have access to this information at any given time for the purpose of assisting the employee. Employees are advised of this in the consent section of the Individualized Employee Emergency Response Information Form. | Completed | January 1, 2012 | ||
| (3) Employers shall provide the information required under this section as soon as practicable after the employer becomes aware of the need for accommodation due to the employee‘s disability. | First National has committed to providing this information to the employee as soon as possible.
| Completed | January 1, 2012 | |||
| (4) Every employer shall review the individualized workplace emergency response information, (a) when the employee moves to a different location in the organization; (b) when the employee‘s overall accommodations needs or plans are reviewed; and (c) when the employer reviews its general emergency response policies. | First National is committed to reviewing the individualized workplace emergency response information as outlined in this section. First National has in place processes to identify when these situations occur. | Completed | January 1, 2012 | |||
| 10 | 22 | Recruitment - General | 22. Every employer shall notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment processes. | All recruitment processes make candidates and employees aware that accommodations are available as outlined in this section, i.e. through job postings. | Completed | January 1, 2016 |
| 11 | 23 | Recruitment, Assessment or Selection Process | 23.(1) During a recruitment process, an employer shall notify job applicants, when they are individually selected to participate in an assessment or selection process, that accommodations are available upon request in relation to the materials
or processes to be used. (2) If a selected applicant requests an accommodation, the employer shall consult with the applicant and provide or arrange for the provision of a suitable accommodation in a manner that takes into account the applicant‘s accessibility needs due to disability. | All recruitment processes make candidates and employees aware that accommodations are available as outlined in this section at the beginning of the interview process.
The person making the accommodation request will be consulted prior to arranging any accommodations and will take into account the person's accessibility needs. | Completed | January 1, 2016 |
| 12 | 24 | Notice to Successful Applicants | 24. Every employer shall, when making offers of employment, notify the successful applicant of its policies for accommodating employees with disabilities. | All recruitment processes make candidates and employees aware that accommodations are available as outlined in this section, i.e. at the offer stage. | Completed | January 1, 2016 |
| 13 | 25 | Informing Employees of Supports | 25.(1) Every employer shall inform its employees of its policies used to support its employees with disabilities, including, but not limited to, policies on the provision of job accommodations that take into account an employee‘s accessibility needs due to disability. | Employees are informed through training that job accommodations are available if and when needed due to disability. Employees will be provided with this information within the first week of their start date. Employees will be provided with updates 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. First National has in place a process for communicating such changes. | Completed | January 1, 2016 |
| 25. (2) Employers shall provide the information required under this section to new employees as soon as practicable after they begin their employment. | Completed | January 1, 2016 | ||||
| 25. 3) Employers shall provide updated information to its 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. | Completed | January 1, 2016 | ||||
| 14 | 26 | Accessible Formats & Communication Supports for Employees | 26.(1) In addition to its obligations under section 12, where an employee with a disability so requests it, every employer shall consult with the employee to provide or arrange for the provision of accessible formats and communication
supports for, (a) information that is needed in order to perform the employee‘s job; and (b) information that is generally available to employees in the workplace. | The person making the accommodation request will be consulted prior to arranging any accommodations as outlined in this section. | Completed | January 1, 2016 |
| 26.(2) The employer shall consult with the employee making the request in determining the suitability of an accessible format or communication support. | Completed | January 1, 2016 | ||||
| 15 | 28 | Documented Individual Accommodation Plans | 28.(1) Employers, other than employers that are small organizations, shall develop and have in place a written process for the development of documented individual accommodation plans for employees with disabilities. | An individual accommodation plan template and process has been established for employees with disabilities. The process requires detailed information regarding the limitations and the accommodation required. The process for the development of documented individual accommodation plans includes the criteria as outlined in this section. | Completed | January 1, 2016 |
28.(2) The process for the development of documented individual accommodation plans shall include the following elements: 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 determine if and how accommodation can be achieved. 4. The manner in which the employee can request the participation of a representative from their bargaining agent, where the employee is represented by a bargaining agent, or other representative from the workplace, where the employee is not represented by a bargaining agent, in the development of the accommodation plan. 5. The steps taken to protect the privacy of the employee‘s personal. 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. | An individual accommodation plan template and process has been established for employees with disabilities. The process requires detailed information regarding the limitations and the accommodation required. The process for the development of documented individual accommodation plans includes the criteria as outlined in this section. | Completed | January 1, 2016 | |||
| 16 | 29 | Return to Work Process | 29.(1) Every employer, other than an employer that is a small organization, (a) shall develop and have in place a return to work process for its employees who have been absent from work due to a disability and require disability-related accommodations in order to return to work; and (b) shall document the process. | A return to work process exists through the company’s Short Term and Long Term Disability Plans. The return to work process includes the criteria outlined in this section. | Completed | January 1, 2016 |
| 29.(2) The return to work process shall, (a) outline the steps the employer will take to facilitate the return to work of employees who were absent because their disability required them to be away from work; and (b) use individual documented accommodation plans, as described in section 28, as part of the process. | ||||||
29.(3) The return to work process referenced in this section does not replace or override any other return to work process created by or under any other statute. | ||||||
| 17 | 30 | Performance Management | 30.(1) An employer that uses performance management in respect of its employees shall take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when using its performance management process in respect of employees with disabilities. | The company’s performance management processes takes into consideration the employee’s accessibility needs and individual accommodation plans when using performance management processes in respect of employees with disabilities. | Completed | January 1, 2016 |
| 18 | 31 | Career Development & Advancement | 31.(1) An employer that provides career development and advancement to its employees shall take into account the accessibility needs of its employees with disabilities as well as any individual accommodation plans, when providing career development and advancement to its employees with disabilities. | Any programs related to career development and advancement at First National take into account the accessibility needs of the employee with the disability as well as any individual accommodation plans when providing career development and advancement to its employees. | Completed | January 1, 2016 |
| 19 | 32 | Redeployment | 32.(1) An employer that uses redeployment shall take into account the accessibility needs of its employees with disabilities, as well as individual accommodation plans, when redeploying employees with disabilities. | Not applicable | Completed | January 1, 2016 |
Part IV - Transportation Standards
Requirement Outlined in the Act
| # | Section # from Act | Initiative | Requirement Outlined in the Act | First National's Actions | Status | Compliance Date |
|---|---|---|---|---|---|---|
| 20 | 33 - 80 | Transportation Standards | The Transportation Standard requires transportation service providers to make the features and equipment on routes and vehicles accessible to passengers with disabilities. First National is not involved in the transportation of people, and therefore, this standard is not applicable. | Not applicable | Not applicable | July 1, 2011 |
Part V - Design of Public Spaces Standards
Requirement Outlined in the Act
| # | Section # from Act | Initiative | Requirement Outlined in the Act | First National's Actions | Status | Compliance Date |
|---|---|---|---|---|---|---|
| 21 | 80.1 - 80.44 | Design of Public Spaces Standards | The Design of Public Spaces standards outlines the need for newly constructed or redeveloped public spaces to be accessible for people with disabilities. First National does not own the building in which we are a tenant of; therefore, this standard is not applicable. | Not applicable | Not applicable | January 1, 2016 |
Part VI - Customer Service Standards
Requirement Outlined in the Act
| # | Section # from Act | Initiative | Requirement Outlined in the Act | First National's Actions | Status | Compliance Date |
|---|---|---|---|---|---|---|
| 22 | 80.45 - 80.51 | Customer Service Standards | The Customer Service Standard sets out requirements for service providers to make their goods, services, and facilities accessible for customers or patrons with disabilities. | Please refer to First National’s AODA Customer Service Policy and Internal Procedures document. | Complete | January 1, 2010 |
File Name: Multi-Year Plan
Policy Implementation Date: December 2013
Last Revision Date: November 7, 2022
Last Review Date: September 9, 2022