On January 1, 2014, private sector employers with 50 or more employees in Ontario face the next round of compliance requirements under the Accessibility for Ontarians with a Disability Act, 2005 (“AODA”).
Most organizations have already complied with the AODA Customer Service Regulation. The AODA Integrated Accessibility Regulation (“IAR”) sets out the followings requirements to be met in the new year by “Large Organizations”, defined under IAR to include private sector employers with 50 or more employees:
- Accessibility Policies: Large Organizations must develop, implement and maintain policies governing how the organization achieves or will achieve accessibility through meeting its AODA requirements. The policy must be in writing and include a statement of organizational commitment to meet the accessibility needs of persons with disabilities in a timely manner. The policy must be publicly available, and provided in an accessible format upon request.
- Multi-Year Accessibility Plan: Large Organizations must establish, implement, maintain and document a multi-year accessibility plan, which outlines the organization’s strategy to prevent and remove barriers and meet its AODA requirements. The plan must be reviewed and updated at least once every five years. The company must post the accessibility plan on the company’s website, and if requested, provide the plan in an accessible format.
- Self-Service Kiosk: Large Organizations should review any “self-service kiosk” to determine whether the kiosk is accessible to a person with a disability. A kiosk is defined to mean “an interactive electronic terminal, including a point-of-sale device, intended for public use that allows users to access one or more services or products or both.” This will likely capture all self-service online job application and career websites, as well as any other “interactive electronic” parts of an organization’s website or online presence. The IAS requires Large Organizations to have regard to the accessibility for persons with disabilities when designing, procuring or acquiring self-service kiosks, and to consider how to ensure people with disabilities can use the kiosks independently and securely.
- Accessible Websites and Web Content: Large Organizations are required to make their internet websites and web content conform with Level A of the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0. More details (for the company’s IT team) can be found at http://www.w3.org/WAI/intro/wcag. The requirements apply to (a) websites and web content, including web-based applications, that an organization controls directly or through a contractual relationship that allows for modification of the product; and (b) to web content published on a website after January 1, 2012. While only public sector organizations are specifically required to make their intranet accessible, large private employers should be aware of those internal sites that will be captured under the future employment standards accessibility requirements. In many cases, it will be cost-effective to consider the wider range of website material.
The above is intended only to be a brief checklist and overview.