HG Accessible Customer Service Policy

The Accessibility for Ontarians with Disabilities Act, 2005 (‘the AODA’) is a Provincial Act with the purpose of developing, implementing and mandating accessibility standards in order to achieve accessibility for persons with disabilities, with respect to goods, services, facilities, accommodation, employment, buildings, structures and premises. Under the AODA, Ontario Regulation 429/07, entitled “Accessibility Standards for Customer Service” (‘the Regulation’), came into force on January 1, 2008. The Regulation establishes accessibility standards specific to customer service for public sector organizations and other persons or organizations that provide goods and services to members of the public or third party parties. Effective January 1, 2012 all business with 1 or more employees must meet the requirements of the Regulation.

The objective of this policy is to identify what the equal treatment provisions of the Ontario Human Rights Code, through the AODA and the Regulation, require as a minimum legal standard in program design and service delivery to persons with disabilities and addresses the following:

• The provisions of goods and services to persons with disabilities
• The use of assistive devices by persons with disabilities
• The use of service animals by persons with disabilities
• The use of support persons by persons with disabilities
• Notice of temporary disruptions in service and facilities
• Training
• Customer feedback regarding the provision of goods and services to persons with disabilities
• Notice of availability and format of documents

HG strives at all time to provide services in a way that respects the dignity and independence of persons with disabilities. It applies to all members of the Dealership Community, including Team Members, customers, visitors and third party contractors.

In accordance with the Accessibility for Ontarians with Disabilities Ontario Regulation 429/07, Accessibility Standards for Customer Service, HG herein also referred to as ‘the Dealership’, is committed to providing a working and learning environment that is accessible and inclusive to all persons who work, purchase goods and services, provide third party services or visit the Dealership. It is the policy of the Dealership that is working and service environments will be free from discrimination and harassment as defined by the Ontario Human Rights Code.

The Provision of Goods and Services to Persons with Disabilities
The Dealership will strive to ensure that its policies, practices and procedures are consistent with the following core principles as outlined in the AODA.
Dignity – Goods and services are provided in a manner that is respectful to persons with a disability and does not diminish the person’s importance.
Independence – Accommodating a person’s disability means respecting their right to do for themselves and to choose the way they wish to receive goods and services.
Integration – Persons with disabilities can access all goods and services.  This may require alternative formats and flexible approaches.  It means inclusiveness and full participation.  This is a fundamental human right.
Equal Opportunity – Service is provided to persons with disabilities in a way that their opportunity to access goods and services is equal to that given to others.

5.1 Communication with Persons with Disabilities
When communicating with a person with a disability, the Dealership will do so in a manner that takes into account the person’s disability. The Dealership commits to provide training on customer service to all current and future employees. This training will, in particular, include how to interact and communicate with persons with various types of disabilities.

5.2 Notice of Planned or Unplanned Disruption in Services and Facilities

In the event of a service disruption at the Dealership affecting Team Members, customers, visitors and third party contractors, it is the responsibility of individual department areas (i.e. Sales and Showroom, Parts, Administration, Service) to take reasonable steps to report such disruption in a timely fashion through appropriate channels. Such channels include, but are not limited to, the HG / Dealership websites, physical postings (temporary signage) on or immediately adjacent to the affected area, and/or communication via email to affected individuals, departments or groups. In accordance with AODA, notice must be conspicuous and indicate any alternatives that exist to allow access to persons with disabilities during the disruption. The required information necessary for any communication of a temporary disruption may include:

• The time, date and location of the disruption
• Information about the reason for the disruption
• Anticipated duration of the disruption
• Descriptions of alternative facilities or services, if any
• Contact information for the responsible service area

5.3 Assistive Technology

Personal assistive technologies are permitted and unrestricted in all areas of the Dealership to which Team Members, Customers, visitors and third party contractors have access, except when subject to operator safety and Dealership integrity. The Dealership will train, on an ongoing basis, current and future Team Members in the use of various assistive devices and related policies. The Dealership will provide an updated list of various assistive technologies available to Team members and customers (see Appendix A).  it should be noted that the provision, use and safety of personal assistive devices is the responsibility of the person with a disability.

5.4 Service Animals

Persons with a disability who are accompanied by a service animal may access premises owned or operated by the Dealership, if the public has access to such premises and the animal is not otherwise excluded by law. If a service animal is excluded by law, the Dealership will ensure that alternate means are available within reasonable time and location to provide persons with a disability access to the Dealership’s services.

There may be rare circumstances where, for reasons of health and safety of another person, allowing a person with a disability to enter a premise accompanied by a service animal needs to be considered. Example of such situation includes but is not limited to a) where a person is allergic to animals and adversely affected if they are in close proximity to a service animal. If deemed necessary, a risk assessment will be conducted the Dealership’s Joint Health and Safety Committee (‘JHSC’). This assessment will identify a) the risks inherent with the service animal being in the area of concern; and b) alternate measures available to enable the person with a disability to access this service.

If it is not readily apparent that an animal is a service animal, the Dealership Management Staff may ask the person with the service animal to provide verification of the animal’s duty. It should be noted that the use and safety of the service animal is the responsibility of the person with a disability.

5.5 Support Persons

The dealership welcomes Team Members, customers and visitors who are accompanied by a support person, when the support person has been hired or chosen by the person with a disability to accompany them in order to assist in accessing goods or services and/or for the purposes of providing support with ability, personal assistance and/or communication. Persons with a disability who require a support person may access premises owned and/or operated by the university with their support person, provided the interaction between the person and their support person does not compromise the Dealership’s integrity.

Support persons are permitted to accompany person with a disability as they interact with the Dealership Team Members. Individuals who are accompanied by a support person are encouraged to inform relevant persons of their participation (e.g. Reception; Call Centre when booking appointments; Service Advisors;  etc.)

There may be rare circumstances where, for reasons of health and safety of another person, allowing a person with a disability to enter a premises accompanied by their support person needs to be considered.  Examples of such situations include potential fire code violations.  If deemed necessary, a risk assessment will be conduct by the JHSC. This assessment will identify: a) the risks inherent with the support person being in the area of concern; and b) alternate measures available to enable the person with a disability to access this service.

Support persons shall be permitted entry to all Dealership facilities and meeting areas that are open to the public.

5.6 Feedback

Feedback about the delivery of services to persons with disabilities is welcomed, as it may identify areas that require change and assist in continuous service improvement.  Such feedback may be by telephone, in person, in writing or by delivering an electronic text via email, or otherwise. The Dealership will make best efforts to provide a response in the same format in which the feedback was received. Where possible, feedback will be addressed immediately. Some feedback may, however, require more effort to address and may need to be reviewed before an action is taken. The Dealership will respond within 21 working days. Information about the feedback process will be posted at the Dealership.

Feedback may be provided directly to the Dealership concerned and/or to: 
The Humberview Group
1650 The Queensway
Toronto, ON
M8Z 1X1
HG People and Culture Department
Direct Line: 416-521-6745
Email: hgaccessibility@humberviewgroup.com or hgpeople@humberviewgroup.com

5.7 Training

The Dealership shall provide training on AODA customer service to all current employees and, in particular, to those providing services and who are involved in the development and approval of customer service policies, procedures and practices. New employees will be provided such training as part of their orientation, through the New Team Member Orientation program conducted monthly.

Such training shall include:

• A review of the purposes of the AODA and the requirements of the Accessibility Standards for Customer Service;
• 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 service animal or a support person;
• How to use the available equipment or devices that may assist with the provision of services to persons with disabilities;
• What to do if a person with a disability is having difficulty in accessing Dealership services;
• How to develop and review policies, procedures and practices relating to the provision of services to persons with disabilities.

5.8 Availability and Format of Documents (Alternative Formats)

All documents required by the Accessibility Standards for Customer Service, including the Dealership’s Accessible Customer Service Policy, notices of temporary disruptions, training records and written feedback process are available upon request, subject to the Freedom of Information and Protection of Privacy Act (‘FIPPA’). When providing these documents to a person with a disability, the Dealership will endeavor to provide the document, or the information contained in the document, in a format that takes the person’s disability into account.

Notice of the available of documents required by the Accessibility Standards for Customer Service will be posted on this website.

Accessible means obtainable, usable, readable, audible, visible, understandable, clear, able to be entered and exited, flexible, etc. To be accessible to all people, a variety of accessibility plans are necessary and under review. Ensuring inclusive practices will ensure that all goods and services can be accessed by a larger audience.

Alternative Formats refers to alternate ways to provide goods and services. This may be through forms of communication such as speech or writing, or methods such as in person or over the phone. Other examples are large print, electronic text (Word or html), Braille, sign language interpretation, communication devices, media caption, etc.

Assistive Devices are equipment that people with disabilities utilize to assist in their daily lives at home, work, school, etc.   Such devices could be a walker, scooter, can, magnification or specialized learning software, communication board, etc.

Assistive Technology is equipment or software such as screen reading, audio recording and voice recognition which people with disabilities use to obtain information and communicate with others.

Customer is the term used in the AODA Legislation to describe patrons, stakeholders or anyone in receipt of goods and services.  The primary recipients of a Dealership’s services are the Team Members, Customers, who use its facilities.

Dealership Premises are any buildings and/or lands owned, leased, operated, controlled or supervised by the Dealership.

Disability Under the AODA, the definition of ‘disability’ is the same as the definition in the Ontario Human Rights code:

(a)     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, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical coordination, 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;
(b)    A condition of mental impairment or a developmental disability;
(c)    A learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
(d)    A mental disorder;  or
(e)    An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

Team Member refers to any Dealership employee.
Service Animal  The Regulation defines a ‘service animal’ as an ‘animal for a person with disability.’ In this policy, a service animal is any animal used by a person with a disability for reasons relating to the disability or where the person provides a letter from a physician confirming that they require the animal for reasons relating to their disability; or where the person provides 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.

Support Person is someone who accompanies a person with a disability in order to assist them. Their assistance may include, but is not limited to, communication, mobility, personal care, medical needs or with access to goods or services.

This policy may be made available in alternative formats upon request.

Accessibility for Ontarians with Disabilities Act, 2005
ONTARIO REGULATION 191/11
INTEGRATED ACCESSIBILITY STANDARDS 

The Accessibility for Disabled Ontarians Act, 2005 requires all business to prepare and publish an accessibility plan to improve opportunities for persons with disabilities through the identification, removal, and prevention of barriers to their participation in the life of the province.  The Humberview Group (HG) is committed to ensuring that our dealerships are barrier-free – free of attitudinal, communication, physical, technological, and procedural barriers.  Our Accessibility Objective is to continue HG’s journey toward accessibility for all persons with disabilities by preventing, identifying, and facilitating the removal of barriers to equal access among such persons, including Customers, Team Members, Visitors, and members of the Dealership Community. 

Maintaining a Multi-Year Accessibility Plan outlines and identifies what the equal treatment provisions of the Ontario Human Rights Code, through the AODA and the Regulation, require as a minimum legal standard in program design and service delivery to persons with disabilities and address the strategy to prevent and remove barriers from the workplace, increase accessibility for persons with disabilities in areas of information, communication, and employment, and improve opportunities providing Dignity, Independence, Integration, and Equal Opportunity for all.  The Multi-Year Accessibility Plan will be reviewed annually and updated as required and every 5 years at a minimum.

The Multi-Year Plan is based on requirements for compliance in accordance with ONTARIO REGULATION 429/07, Ontario Regulation 191/11 Integrated Accessibility Standards, Ontario Human Rights Commission, Ministry for Seniors and Accessibility, best practice research from and with input from the HG dealership’s Joint Health and Safety Teams, Team members and HG Resources of CEO, COO, People & Culture, and the HG Leadership Team.

The Facilities Checklist is to be reviewed and audited as required at the quarterly JHSC meetings with General Manager, HG People and Culture, JHSC Team members with the assist and direction of HG H+S Director of Health and Safety.

1. Creation of Accessibility Policies

1.1. Accessibility Policy / Statement

Action: Reviewed annually
Status: 2012 – present HEA020 Policy/Statement

1.2. Accessibility Plan

Action: Multi-Year Plan 2019-2024
Status: Completed; review opportunities with Sr. Executive, JHSC teams, Team members throughout term

1.3. Accessibility Reporting

Action: File Accessibility Reports
Status: Completed ACR – 98989

1.4. Incorporate AODA Discussions

Action: JHSC Agendas
Status: Ongoing

Action: General Mgr. Meetings
Status: Ongoing

Action: Business Update
Status: Ongoing

2. Training

2.1. AODA Training

Action: Accessible Training provided in a way that best suits the duties of the Team member. New Hires - Training before commencing work.
Status: 2016 - present

2.2. AODA Customer Service Refresher

Action: Refresher Training will be assigned as required to Team members who deal with the public.  
Status: 2021 - present

2.3. All New Hires – AODA Training mandatory

Action: Dealership Tour/Virtual New Hire. Orientation including 20-minute video illustrating Accessibility in the workplace.
Status: Ongoing

2.4. PIPEDA 

Action: Expanding scope of instruction
Status: Completed 2019, continuing enhancements

2.5. Human Rights

Action: Understanding Human Rights Training (AODA Edition) as it pertains to persons with disabilities. Clear access to H+S equipment, First Aiders, training; risk analysis
Status: 2024 – provide additional training to ensure understanding of Human Rights and AODA

2.6. Workplace H+S Inspections

Action: Conducted monthly
Status: Ongoing

3. Accessible Websites + Web Content

Web content Accessibility Guidelines 2.1 (WCAG 2.1), which aim to explain and guide web developers in the creation of accessible sites.

Principles:  Providing Perceivable, Operable, Understandable + Robust information in parallel with WCAG Accessibility Guidelines

Action: Providing Web Content utilizing accessibility interface allowing persons with specific disabilities to adjust website’s UI (user interface) and design it to their personal needs.
Status: 2015 – 2022 eDealer and 2023 – Access360

4. Feedback

Process in place for accessible feedback

Action: Website Chat and Email Link located on Website
Status: Ongoing

Action: HG will continue to ensure process for receiving/responding to feedback is accessible to persons with disabilities by providing or making provisions of accessible formats and communications upon request
Status: HG will continue to consult with person making the request determining the suitability of accessible format

5. Accessible Formats + Communication

Action: HG to arrange provision of requested information in accessible formats with more accessible digital services; continue to review assistive technologies, and processes providing enhanced accessibility at the dealership.    Team members have the expertise to provide information in accessible formats
Status: Ongoing. Initiative: expand training to Team members by providing communication support.  Ensure Team members are aware and familiar with ACCESS360 to its fullest capacity to assist with a person’s accessibility needs due to disability  

6. Workplace Emergency Response Information

Action: Mapping Floorplans, Lot Maps; EER Team, Roles +Responsibilitie; Accommodation Plan
Status: 2016 - ongoing

7. Employment

7.1. Recruitment

Action: Compliance with applicable law, HG employment practices encourages people with disabilities to fully participate in practices for recruitment providing all Team members with accessibility training, + representation.  Workers have the support to join, work effectively, and have opportunities for learning and development
Status: Continuing best practices

7.2. Training

Action: Facilitating Safe Return to Work programs for Team members off due to disability
Status: HG is committed to the growth and development of all team members.

HG process in development to address return-to-work procedures for Team members absent from work due to a disability.

HG will review the Multi-Year Accessibility Plan in January 2025 and every 5 years thereafter. 

To obtain this document in an alternate format, please contact:

hgaccessibility@humberviewgroup.com

HG People and Culture
hgpeople@humberviewgroup.com
Direct Line: 416-521-6745