STATEMENT OF ORGANIZATIONAL COMMITMENT:

Mary Berglund Community Health Centre Hub (MBCHCH) is committed to ensuring equal access and participation for people with disabilities.  We believe in integration and we are committed to meeting the needs of people with disabilities in a timely manner.  We will do so by removing and preventing barriers to accessibility and meeting our accessibility requirements under the Accessibility for Ontarians with Disabilities Act and Ontario’s accessibility laws.

MBCHCH is committed to meeting its current and ongoing obligations under the Ontario Human Rights Code respecting non-discrimination.

MBCHCH understands that obligations under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and its accessibility standards do not substitute or limit its obligations under the Ontario Human Rights Code or obligations to people with disabilities under any other law.

POLICY:

This policy is intended to meet the requirements of the Accessibility Standards for Customer Service, Ontario Regulation 429/07 under the Accessibility for Ontarians with Disabilities Act, 2005, and applies to the provision of goods and services to the public or other third parties, not to the goods themselves.

All programs and services provided by MBCHCH shall follow the principles of dignity, independence, integration and equal opportunity.

Scope

This policy applies to the provision of goods and services at premises leased, owned and operated by MBCHCH.

This policy applies to employees, volunteers, agents and/or contractors who deal with the public or other third parties that act on behalf of MBCHCH, including when the provision of goods and services occurs off the premises of MBCHCH.

This policy shall also apply to all persons who participate in the development of MBCHCH policies, practices and procedures governing the provision of goods and services to members of the public or third parties.

General Principles

MBCHCH 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 people with disabilities receive the same value and quality;
• allowing people with disabilities to do things in their own ways, and at their own pace, when accessing goods and services (as long as this does not present a safety risk);
• using alternative methods when possible to ensure that people with disabilities have access to the same services, in the same place and in a similar manner;
• taking into account individual needs when providing goods and services; and communicating in a manner that takes into account a person’s disability.

Assistive Devices

Persons with disabilities may use their own assistive devices as required when accessing services provided by MBCHCH.  In cases where the assistive device presents a safety concern or where accessibility might be an issue, other reasonable measures will be used to ensure the access of goods and services.

Guide Dogs, Service Animals and Service Dogs

A person with a disability that is accompanied by a guide dog, service animal or service dog will be allowed access to premises that are open to the public unless otherwise excluded by law.  “No pet” policies do not apply to guide dogs, service animals and/or service dogs.

A person with a disability that is accompanied by a guide dog or a service dog will be allowed access to food service areas that are open to the public unless otherwise excluded by law.  Other types of service animals are not permitted into food service areas due to the Heath Protection and Promotion Act, Ontario Regulation 562 Section 60.

If a guide dog, a service animal or a service dog is excluded by law (see applicable laws below), MBCHCH will offer alternative methods to enable the person with a disability to access goods and services, when possible (for example, securing the animal in a safe location and offering the guidance of an employee).

Support Persons

If a person with a disability is accompanied by a support person, MBCHCH will ensure that both persons are allowed to enter the premises together and that such a person is not prevented from having access to their support person.

In situations where confidential information might be discussed, consent will be obtained from the person with a disability prior to any conversation where confidential information might be discussed.

Notice of Disruptions in Service

Service disruptions may occur due to reasons that may or may not be within the control or knowledge of MBCHCH.  In the event of any temporary disruptions to facilities 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 needs to be posted, the following information will be included unless it is not readily available or known:  goods or services that are disrupted or unavailable, reason for the disruption, anticipated duration, and a description of alternative services or options.

MBCHCH will provide notice by posting in conspicuous places including at the point of disruption, at the main entrance, and the nearest accessible entrance to the service disruption; on the MBCHCH website and/or social media accounts; and by contacting clients with appointments when appropriate.

Feedback Process

MBCHCH shall provide clients, including those with disabilities, with the opportunity to provide feedback on the services they receive using a variety of methods including:

Phone (8079342674)

In person (ask for the Executive Director)

Email (hwest@maryberglund.com)

In writing via suggestion boxes (situated in Primary Care reception areas)

Feedback is also solicited in focus groups, program evaluations and formal surveys.

All feedback is reviewed by the Executive Director or delegate.  Complaints are investigated and follow up is provided to the client if requested.

Training

MBCHCH will ensure that training is provided to:

• all employees, volunteers, agents and/or contractors who deal with the public or other third parties that act on behalf of MBCHCH;
• those who are involved in the development and approval of client service policies, practices and procedures.

Training will include:

• the purpose of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the Customer Service Standards
• our policies related to the Customer Service Standards
• how to interact and communicate with people with various types of disabilities
• how to interact with people 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 onsite or otherwise that may help with providing goods, services or facilities to people with disabilities.

Ongoing training will be provided to new employees as soon as practicable.  If any changes are made to this policy or the requirements, additional training will be provided.

Notice of Availability and Format of Documents

Upon request, MBCHCH will provide its documents related to the Accessibility Standards for Customer Service in a format that takes into account the client’s disability.

Definitions

Accessible:  service is provided in a manner that is easily understood or appreciated; easily obtained or used; able to be reached, entered, or used by people who have a disability.

Assistive Device:  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 members of the public, or other stakeholders 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.

Barrier:  anything that prevents a person with a disability from fully participating in all aspects of society because of his or her disability, including a physical barrier, an architectural barrier, an information or communications barrier, an attitudinal barrier, a technological barrier, a policy or a practice.

Disability:  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 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 WSIB.

Guide Dog:  a dog trained as a guide for a blind person and having the qualifications prescribed by the Blind Persons’ Rights Act R.S.O. 1990, c. B.7, s. 1 (1).

Service Animal:  as reflected in Ontario Regulation 429/07, 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 if the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disability.

Service Dog:  as reflected in Health Protection and Promotion Act, Ontario Regulation 562, a dog other than a guide dog for the blind is a service dog if:  it is readily apparent to an average person that the dog functions as a service dog for a person with a medical disability; or the person who requires the dog can provide on request a letter from a physician 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.

References

Accessibility for Ontarians with Disabilities Act, 2005
Accessibility Standards for Customer Service, Ontario Regulation 429/07
Blind Person’s Rights Act, 1990
Dog Owners’ Liability Act, Ontario
Food Safety and Quality Act 2001, Ontario Regulation 31/05
Health Protection and Promotion Act, Ontario Regulation 562
Ontario Human Rights Code, 1990