CCTS Integrated Accessibility Policy

1. General Provisions

Commitment Statement 

The Commission for Complaints for Telecom-television Services (CCTS) is committed to being responsive to the diverse needs of the public and strives to provide all persons with an equal opportunity to obtain, use and benefit from our services while allowing each person to maintain their dignity and independence.  

Providing accessible customer service so that persons with disabilities can contact us easily and use the CCTS’ services is one of our Operating Principles and a key principle in our Performance Standards. 

 The CCTS will apply to each person the key principles of equality, integration, dignity and independence regardless of whether an individual is: 

  • Obtaining CCTS services through telephone or online platforms; 
  • Accessing information about the CCTS and its services; or 
  • Visiting or working in CCTS offices. 

This policy is intended to meet Integrated Accessibility Standards, Ontario Regulation 191/11 requirements set out in the Accessibility for Ontarians with Disabilities Act, 2005.  

This Integrated Accessibility Policy will be reviewed regularly to ensure that it is reflective of the CCTS’ current practices in accordance with legislative requirements. 

Feedback

The CCTS welcomes feedback from the public about the manner in which it provides services to persons with disabilities and whether the feedback process complies with the requirement to provide, or arrange for the provision of, accessible formats and communication supports upon request. 

The CCTS will consider all feedback on a case-by-case basis and, as circumstances allow, respond within a reasonable time.   

Persons with disabilities to whom the CCTS provides services can provide feedback by email, telephone including by Video Relay Service (VRS), teletypewriter (TTY), fax, physical mail, audio recording or, on request, in another accessible format or with communication supports, to: 

Email:                   communications@ccts-cprst.ca

Telephone:          1-888-221-1687

TTY:                      1-877-782-2384

Fax:                       1-877-782-2924

Mail:                     CCTS

                              P.O. Box 56067 Minto Place RO

                              Ottawa, ON

                              K1R 7Z1

Definitions 

In this Policy: 

“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. 

“Assistive device” means a technical aid, communication device or other instrument that is used to maintain or improve the functional abilities of persons with disabilities.  

“Career development and advancement” includes providing additional responsibility within an employee’s current position and the movement of an employee from one job to another in the CCTS that may be higher in pay, provide greater responsibility or be at a higher level in the CCTS or any combination of them and, for both additional responsibilities and employee movement, is usually based on merit or seniority, or a combination of them. 

“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. 

Disability” (as defined in the Accessibility for Ontarians with Disabilities Act, 2005) means: 

  • 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 a 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, SO 1997, c 16.  

“Individual Accommodation Plan” means a written document that identifies an employee’s disability-related limitations, work-related responsibilities that are affected by the limitations, a description of the accommodation to be provided, and the expected duration of the specified accommodation. 

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. 

“Performance Management” means activities related to assessing and improving employee performance, productivity and effectiveness with the goal of facilitating employee success.  

“Redeployment” means the reassignment of employees to other departments or jobs within the CCTS as an alternative to layoff, when a particular job or department has been eliminated by the CCTS.  

“Return to Work Plan” means a written document that supports the reintegration process for employees who have been absent from work because of disability or medical-related leave and who require accommodations when they return to work. 

Service animal” means: 

(a) any animal that is used by a person with a disability for reasons relating to his or her disability, or; 

(b) if it is not readily apparent that the animal satisfies (a), any animal for which a person with a disability provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to his or her disability. 

Support personmeans, in relation to a person with a disability, another person who accompanies him or her in order to help with communication, mobility, personal care or medical needs or with access to goods or services. 

Web Content Accessibility Guidelines” means the World Wide Web Consortium Recommendation, dated December 2008, entitled “Web Content Accessibility Guidelines (WCAG) 2.0.” 

Training

The CCTS will provide training on the Accessibility for Ontarians with Disabilities Act, 2005, the Integrated Accessibility Standards, Ontario Regulation 191/11 and the provisions of the Ontario Human Rights Code to: 

  • every employee or volunteer of the CCTS; 
  • every person who participates in the development of the CCTS’ policies; and 
  • every other person who provides services on behalf of the CCTS. 

The training must include a review of the purposes of the Accessibility for Ontarians with Disabilities Act, 2005 and instruction about: 

  • how to interact and communicate with persons with various types of disabilities; 
  • how to interact with persons with disabilities who use an assistive device or require the assistance of a guide dog or other service animal or the assistance of a support person; 
  • how to use equipment or devices available on the CCTS’ premises or otherwise provided by the CCTS that may help with the provision of services to a person with a disability; and 
  • what to do if a person with a particular type of disability is having difficulty accessing the CCTS’ services. 

The CCTS will maintain records of the training provided, including the dates on which the training is provided and the number of individuals to whom it is provided. 

Training is provided to all new employees and all individuals on an ongoing basis with respect to any changes to policies, practices and procedures governing the provision of services to persons with disabilities.  

2. Information and Communications Standard

Accessible formats and communications supports

The CCTS will create, provide and receive information and communications in ways that are accessible to persons with disabilities. 

Upon request, the CCTS will provide for free, in an accessible format or with an accessible communication support: 

  • all organizational information and communications available to the public, including this Policy; and 
  • access to any processes for receiving and responding to feedback. 

Upon request, the CCTS will consult with the requestor to determine the suitability of any accessible format or communication support provided. The information or support will be provided as soon as practicable.  

If the CCTS determines that it is not technically feasible to convert the requested information or communications to an accessible format or that the technology to convert the information or communications is not readily available, it will, upon request, explain to the requestor why the information or communications are not convertible to an accessible format and provide a summary of the information or communications.   

Accessible websites and web content

The CCTS will ensure that its internet websites and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 AA, in accordance with the schedule set out in the Integrated Accessibility Standards, Ontario Regulation 191/11. 

Accessible customer service standard

Customer service

The CCTS will provide services to customers with disabilities in a manner that respects the dignity and independence of persons with disabilities.  The CCTS will integrate its provision of services to customers with disabilities with its provision of services to customers, unless an alternative measure is necessary, so that customers with disabilities have an equal opportunity to obtain, use or benefit from the CCTS’ services on a temporary or permanent basis. 

The CCTS will communicate with customers with disabilities in a manner that takes into account the  disability and, if unsure of the best manner of communication, will directly and respectfully ask the customer with a disability how to best communicate with them. 

Use of service animals and support persons

The CCTS’ premises are open to the public by invitation only.   

If a person with a disability who is invited to the CCTS’ premises is accompanied by a guide dog or other service animal, the CCTS will ensure that the person is permitted to enter the premises with the animal and to keep the animal with them, unless the animal is otherwise excluded by law from the premises. 

If a service animal is excluded by law from the CCTS’ premises, the CCTS will ensure that other measures are available to enable a person with a disability to obtain, use or benefit from the CCTS’ services or facilities. 

If a person with a disability who is invited to the CCTS’ premises is accompanied by a support person, the CCTS will ensure that both persons are permitted to enter the premises together and that the person with a disability is not prevented from having access to the support person while on the premises. 

The CCTS may require a person with a disability to be accompanied by a support person when on the CCTS’ premises, but only if, after consulting with the person with a disability and considering the available evidence, the CCTS determines that: 

  • a support person is necessary to protect the health or safety of the person with a disability or the health or safety of others on the premises; and 
  • there is no other reasonable way to protect the health or safety or the person with a disability and the health or safety of others on the premises.  

Notice of temporary disruptions

The CCTS will provide, as soon as practicable, notice to the public of any temporary disruption of a particular facility or service used by persons with disabilities to access the CCTS’ services.  The notice will identify the reason for the disruption, its anticipated duration and a description of alternative facilities or services, if any, that are available.   

The CCTS will prepare a document setting out the steps it will ensure are taken in connection with a temporary disruption and, on request, give a copy of the document to any person to whom it provides services. 

The CCTS will post the notice of the temporary disruption and the document setting out the steps it will take in connection with a temporary disruption on its website, or by such other method as is reasonable in the circumstances. 

Format of documents

The CCTS will, on request, provide or arrange to provide to a person with a disability any document, or the information contained in any document, referred to in this policy in an accessible format or with communication supports: 

  • in a timely manner that takes into account the person’s accessibility needs due to disability; and 
  • at a cost that is no more than the regular cost charged to other persons. 

The CCTS will consult with the person making the request in determining the suitability of an accessible format or communication support. 

4. Employment Standard

Recruitment, assessment and selection

The CCTS will notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment processes. 

During a recruitment process, the CCTS will 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. 

If a selected applicant requests an accommodation, the CCTS will 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 disability-related accessibility needs.  

The CCTS will, when making offers of employment, notify the successful applicant of its policies for accommodating employees with disabilities. 

Informing employees of supports

The CCTS will, as soon as practicable after an employee begins employment, inform its employees of its policies for supporting employees with disabilities.   

The CCTS will provide updated information to its employees whenever there is a change to existing disability-related accessibility and accommodation policies.   

Accessible formats and communications supports for employees

Upon request from an employee with a disability, the CCTS will consult with the employee to provide, or arrange to provide, accessible formats and communications supports for: 

  • providing information that is needed in order to perform the employee’s job; and 
  • providing information that is generally available to employees in the workplace. 

The CCTS will consult with the employee making the request to determine the suitability of an accessible format or communication support. 

Workplace emergency response information

The CCTS will provide individualized workplace emergency response information to employees with  disabilities, if the disability is such that the individualized information is necessary and the CCTS is aware of the employee’s need for disability-related accommodation, as soon as practicable after it becomes aware of the employee’s disability-related need for accommodation.  

If an employee who receives individualized workplace emergency response information requires assistance, and with the employee’s consent, the CCTS will provide the workplace emergency response information to the person it designates to provide assistance to the employee. 

The CCTS will review the individualized workplace emergency response information: 

  • when the employee moves to a different location in the CCTS; 
  • when the employee’s overall accommodation needs or plans are reviewed; and 
  • when the CCTS reviews general emergency response policies.  

Documented individual accommodation plans

The CCTS has a standard process for the development of documented individual accommodation plans for employees with disabilities. 

Return to work process

The CCTS has a standard 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. 

Performance management

The CCTS will take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when applying its performance management process in respect of employees with disabilities. 

Career development and advancement

The CCTS will take into account the accessibility needs of its employees with disabilities, as well as any individual accommodation plans, when providing career development and opportunities for advancement to its employees with disabilities. 

Redeployment

The CCTS will take into account the accessibility needs of its employees with disabilities, as well as individual accommodation plans, when redeploying employees with disabilities.  

Privacy and confidentiality

The CCTS recognizes and respects its employees’ right to privacy in respect of their personal medical information. At all times during the accommodation plan process or, if applicable, the return to work process, the CCTS will ensure the privacy, security and confidentiality of the employee’s personal and medical information and will disclose it only to designated staff who require it to carry out the individual accommodation process.