AODA Compliance | MindBeacon

Accessibility Policy

Commitment to an Inclusive and Accessible Work Environment

MindBeacon Health Inc. (together with its associates and affiliated entities, the "Company”) is committed to treating all people in a way that allows them to maintain their dignity and independence. We believe in integration and equal opportunity. We are committed to meeting the needs of persons with disabilities in a timely manner and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the Integrated Accessibility Regulation (the “ISAR”) of the Accessibility for Ontarians with Disabilities Act (“AODA”).

Inclusivity and accessibility are not only legislative requirements, they align with the Company’s core values. Preventing and removing barriers to the Company’s services and in our workplace makes sound business and economic sense. An accessible company allows the Company to provide services to our clients and retain diverse talent supporting our company’s competitive advantage.

Disability

A disability is defined as:

Any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness, including diabetes mellitus, 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;
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.

Accessibility Plan

The Company has developed and will continue to maintain a Multi-Year Accessibility Plan outlining the Company’s strategy to prevent and remove barriers from its workplace and to improve opportunities for persons with disabilities.

The Multi-Year Accessibility Plan will be reviewed and updated (where applicable) at least once every five years and posted on the Company’s website. Upon request, the Company will provide a copy of the Accessibility Plan in an accessible format.

Providing Services to People with Disabilities

The Company 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 the Company’s 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 services; and
Communicating in a manner that takes into account a customer’s disability.

Information and Communication Standards

The Company will communicate to customers with disabilities in ways that take into account their disability. We will train our staff on how to effectively interact and communicate with our diverse community and people with various types of disabilities.

Feedback

The Company has established a feedback process to ensure people with disabilities are able to provide us with feedback on our products/services. Feedback is always welcome and appreciated and can be submitted in the following formats: in person, by telephone, by mail, by email or by website e-submission.

The Company will continue to ensure that its customers’ feedback process is accessible to customers with disabilities by providing or arranging for the provision of accessible formats and communications supports upon request.

Accessible Formats and Communication Supports

Upon request, the Company will provide, or will arrange to provide information in an accessible format and with communication supports in a timely manner that takes into account a customer’s accessibility needs due to his/her disability.

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

The Company will also notify the public about the availability of accessible formats and communication supports. Notification will be given by posting the information on the Company’s websites or any other reasonable method.

Accessible Websites and Web Content

The Company will ensure that its websites, including web content, conform to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG 2.0) except where this is impracticable.

Telephone Services

The Company will train employees to communicate with customers over the telephone in plain language while speaking clearly and slowly. The Company will offer to communicate with customers by e-mail, fax or letter if telephone communication is not suitable to their communication needs or is unavailable.

Use of Assistive Devices

An assistive device is one or more devices used by a person with a disability to help him/her independently complete every day tasks. Accessibility devices include mobility aids (e.g., wheelchairs and walkers), portable communication devices, head-wands hearing aids and much more.

The Company welcomes the use of assistive devices by our customers to access our services. We will ensure our staff are trained on how to interact with individuals using various assistive devices and how our staff can provide alternative service methods.

Use of Service Animals and Support Persons

Service Animals

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

the person provides a letter from a Regulated Health Professional (including but not limited to physiologist, psychotherapist, chiropractor, nurse, physician, mental health therapist, etc.) confirming that the person requires the animal for reasons relating to the disability.

Customers with disabilities who are accompanied by a service animal are welcome at all Company properties when accessing our services unless the animal is otherwise excluded by law from the premises. If the animal is legally excluded from the premises, the Company will provide alternative measures to enable the person to obtain, use or benefit from its services.

The Company will ensure that all staff are properly trained on how to interact with customers with disabilities and who are accompanied by a service animal.

Support Persons

A support person is an individual who accompanies a person with disabilities to help meet his/her communication, mobility, personal care or medical needs or to assist the person with disabilities in accessing our services. A person with a disability who is accompanied by a support person will be allowed to enter the Company’s premises together with the support person and will not be prevented from having access to the support person while on the premises.

Notice of Disruptions to Service

The Company will provide customers with notice of a planned or unexpected disruption in services usually used by customers with disabilities. This notice will include the reason for the disruption, its anticipated duration, as well as describe alternative facilities or services that may be available. This notice will normally be posted on a website and may also be posted on the premises, where appropriate in the circumstances.

Employment Standards

Recruitment

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

Recruitment, Assessment or Selection Process

The Company will notify job applicants selected to participate in an assessment or selection process that accommodations are available upon request relating to the materials or processes to be used.

If a selected applicant requests accommodation, the Company will consult with the applicant and provide, or arrange for the provision of, suitable accommodation in a manner that takes into account the applicant's accessibility needs relating to his or her disability.

Notice to Successful Applicants

When making offers of employment, the Company will notify the successful applicant of its policies for accommodating employees with disabilities.

Training

The Company will provide training for all employees that may be acting on the Company’s behalf in dealing with the public or any other third parties on how to effectively interact with people with disabilities. In addition, everyone who is involved with and/or influences the Company’s policies and standard operating practices and procedures will receive this training. Training will be updated in respect to any changes to the policies, practices, or procedures surrounding accessibility for people with disabilities. Training will be provided within the first week of employment.

Training will include:

Purposes of the Accessibility for Ontarians with Disabilities Act and requirements of the customer service standard;
How to interact and communicate with persons of disability in a manner that takes into account his or her disability;

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 equipment or devices available that may help with the provisions of services;
Review Company policies, practices, and procedures pertaining to providing accessible customer service to persons with disabilities; and
Workplace emergency response information.

Informing Employees of Supports

The Company will continue to inform its employees of its policies (and any updates to those policies) used to support employees with disabilities, including policies on the provision of job accommodations that take into account an employee accessibility needs due to disability. This information will be provided to new employees as soon as practicable after commencing employment.

Workplace Emergency Response

The Company will provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary, and if the Company is aware of the need for accommodation due to the employee’s disability. The Company will provide this information as soon as practicable after becoming aware of the need for accommodation.

Where an employee requires assistance, the Company will, with the consent of the employee, provide the workplace emergency response information to the person designated by the Company to provide assistance to the employee.

The Company will review the individualized workplace emergency response information when the employee moves to a different location in the organization, when the employee overall accommodations needs or plans are reviewed, or when the Company reviews its general emergency response policies.

Documented Individual Accommodation Plans

The Company will maintain a written process for the development of documented individual accommodation plans for employees with disabilities.

If requested, information regarding accessible formats and communications supports available will also be included in individual accommodation plans.

In addition, the plans will include individualized workplace emergency response information (where required) and will identify any other accommodation that is to be provided.

Return to Work Process

The Company will maintain a documented return to work process for its employees who have been absent from work due to a disability and who require disability-related accommodations to return to work.

The return to work process outlines the steps the Company will take to facilitate the return to work and will include documented individual accommodation plans as part of the process.

This return to work process will not replace or override any other return to work process created by or under any other statute (ie. the Workplace Safety Insurance Act, 1997).

Modifications to This or Other Policies

The Company is committed to developing customer service policies that respect and promote the dignity and independence of persons with disabilities. Therefore, no changes will be made to this policy before considering the impact on persons with disabilities. Any policy of the Company that does not respect and promote the dignity and independence of persons with disabilities will be modified or removed. This policy and its related procedures will be reviewed as required in the event of legislative changes.

Questions About This Policy

If anyone has a question about the policy or if the purpose of a policy is not understood, an explanation should be provided by, or referred to Human Resources

In Writing: MindBeacon Group, 181 University Avenue, Suite 1101, Toronto, Ontario M5H 3M7 By Email: hr@mindbeacon.com

Website: www.cbtassociates.com; www.mindbeacon.com; https://platform.mindbeacon.io

MindBeacon Group MULTI-YEAR ACCESSIBILITY PLAN

Accessibility Plan

The AODA seeks to provide a fully accessible Ontario by 2025. Consistent with this objective, there are many obligations placed on organizations, including The Company, to ensure their workplaces and services are fully accessible to the public and employees including persons with disabilities.

THE ISAR requires every employer with 50 or more employees to develop and post a Multi-Year Accessibility Plan. In accordance with the ISAR, the Company’s Multi-Year Accessibility Plan outlines the Company’s strategy to prevent and remove barriers to accessibility.

Barrier Assessment – Methodology

In accordance with the AODA and with the Company’s commitment to treating all people in a way that allows them to maintain their dignity and independence while creating an inclusive work environment for the Company’s people to develop to their full potential, our plan seeks to prevent and remove barriers to accessibility for persons with disabilities.

A “barrier” is anything that prevents a person with a disability from full participating in all aspects of society because of his or her disability. Typical barriers to accessibility encountered by persons with disabilities include Physical / Architectural, Attitudinal, Informational/Communication, Systemic, and Technological barriers.

Barrier Definitions:

Physical/Architectural: design elements of a building or a space that cause problems for persons with disabilities.
Attitudinal: our perceptions of, and how we interact with, persons with disabilities.
Informational/Communication: things/situations that make it difficult for a person with a disability to give, receive or understand information.
Systemic: organizational policies or practices that (often unwittingly) restrict the participation of persons with disabilities.
Technological: poor or inexistent technology system that can prevent people from accessing information. Common tools like computers, telephones and other aids can all present barriers if they are not set up or designed with accessibility in mind.

Moving Toward Accessibility

Initiative (ISAR)	Action	Status	Required Legislative Compliance Date
Part I: - General Requirements
1.1 Establishment of Accessibility Policies	Policy completed and posted	Completed	January 1, 2014
1.3 Training	Company will provide training on the requirements of the IASR and on disability-related obligations under Ontario Human Rights legislation to employees, assignment employees, contractors, and any others who may be acting on CBT’s behalf in dealing with the public or any other third parties. Training will also be provided to all people who are involved in the development of Company’s policies. Company will maintain records of the dates when training is completed and the individuals who completed the training.	Completed/Ongoing	January 1, 2015
Part II: - Information and Communication Standards
2.1 Feedback	Company will ensure that customer service expectations are being met and that all customers regardless of any disability receive fair and equal treatment. All feedback will receive a receipt of feedback acknowledgement. Action will occur within 30 days of receipt.	Completed	January 1, 2015
2.2 Accessible Formats & Communication Supports	Company will provide appropriate information and communications in an accessible manner to people with disabilities upon request. Company will consult with the person to determine their accessibility needs. Company is committed to providing the alternate format in a timely manner.	Completed	January 1, 2016
2.3.1 Accessible Websites & Web Content	Company will ensure that internet websites and web content conform to the Web Content	Completed	January 1, 2014

Initiative (ISAR)	Action	Status	Required Legislative Compliance Date
	Accessibility Guidelines (WCAG) 2.0, Level AA
2.3.2 Accessible Websites & Web Content	Company will ensure that internet websites and web content conform to the WCAG 2.0 Level AA	Completed	January 1, 2021
Part III – Employment Standard
3.1 Recruitment, General	Company will notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment processes.	Completed	January 1, 2016
3.2 Recruitment, Assessment or Selection Process	Company will notify job applicants, when they are individually selected to participate further 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, Company 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 accessibility needs.	Completed	January 1, 2016
3.3 Notice to Successful Applicants	When making offers of employment, Company will notify the successful applicant of its policies for accommodating employees with disabilities.	Completed	January 1, 2016
3.4 Informing Employees of Supports	Company will inform all employees, both new and existing, of the accessible employment practices. This includes, but is not limited to, policies on providing job accommodations that take into account an individual employee’s accessibility needs due to disability. This will make all employees aware of how the organization will support them if they have a disability – or if they acquire a disability later in their careers.	Completed	January 1, 2016

Initiative (ISAR)

Action

Status

Required Legislative Compliance Date

3.5 Accessible Formats and Communication Supports for Employees

Upon request, whenever possible, Company will consult with the person to determine the best method of providing the information requested and take the necessary steps to provide accessible formats and communications for the following:

Information needed in order to perform their job; and
General information that is made available to all employees in the workplace.

Completed

January 1, 2016

3.6 Workplace Emergency Response Information

Company will provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary, and Company is aware of the need for accommodation due to the employee’s disability.
Company will provide this information as soon as practicable after becoming aware of the need for accommodation.
Where the employee requires assistance, Company will, with the consent of the employee, provide the workplace emergency response information to the person designated by Company to provide assistance to the employee.
Company will review the individualized workplace emergency response information when the employee moves to a different location in the organization, when the employee’s overall accommodations needs or plans are reviewed or when Company reviews its general emergency response policies.

Completed

January 1, 2012

Initiative (ISAR)

Action

Status

Required Legislative Compliance Date

3.7 Documented Individual Accommodation Plans

Company will take the following steps to develop and put in place a process for developing documented Individual Accommodation Plans (IAP) and processes for employees that have been absent due to a disability:
Develop an Individual Accommodation Plan (IAP) that includes the following:

The employee’s participation in the development of the IAP;
Assessment on an individual basis;
Identification of accommodations to be provided;
Timelines for the provision of accommodations;

Company may request an evaluation by outside medical or other expert, at our expense, to assist with determining accommodation and how to achieve accommodation;
Steps taken to protect the privacy of the employee’s personal information;
Frequency with which the IAP will be reviewed and updated and the manner in which it will be done;
If denied, the reasons for denial are to be provided to the employee;
A format that takes into account the employee’s disability needs;
If requested, any information regarding accessible formats and communication supports provided;
Identification of any other accommodation that is to be provided.

Completed

January 1, 2016

3.8 Return to Work

Company will develop a process that supports employees who have been absent due to a

disability and who require related

Completed

January 1, 2016

Initiative (ISAR)	Action	Status	Required Legislative Compliance Date
	accommodations when they return to work. The return to work process will: Be documented and outline the steps that will be taken to facilitate an employee’s return to work. Use documented individual accommodation plans. The return to work process will not replace or override any other return to work processes created under any other law.
3.9 Performance Management	Company will develop processes that take into account the accessibility needs of employees with disabilities and their individual accommodation plans. Completed will review an employee’s accommodation plan to understand the individual’s accommodation needs and determine if the plan needs adjusting to improve his or her performance on the job.	Completed	January 1, 2016
3.10 Career Development & Advancement	Company will adjust the accommodation supports or update an accommodation plan, with the employee’s participation, to meet the employee’s new role or responsibilities in the event the employee is promoted or redeployed.	Completed	January 1, 2016

In accordance with the AODA and with the Company’s objective of treating all people in a way that allows them to maintain their dignity and independence while creating an inclusive work environment for the Company’s employees to develop to their full potential, this Multi-Year Accessibility Plan will be made available to all employees and will be reviewed and updated at least once every five years and as required. It will also be provided in an accessible format upon request.