Table of Contents
Serving Customers With Disabilities
The Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”) is legislation for the purpose of developing, implementing, and mandating accessibility standards to achieve accessibility with respect to goods, services, facilities, accommodation, employment, buildings, structures, and premises for persons with disabilities.
Under the AODA, Ontario Regulation 191/11: Integrated Accessibility Standards (“the Regulation”) came into effect on July 1, 2011. The Regulation establishes accessibility standards specific to customer service for private sector organizations that provide goods and services to members of the public or other third parties and includes:
- Information and Communications Standards
- Employment Standards
- Transportation Standards
- Design of Public Spaces Standards
- Customer Service Standards
Economical Insurance (“Economical”) is committed to ensuring the services we provide are as accessible as possible to persons with disabilities, and are compliant with the Regulation set forth by the Government of Ontario. To fulfil this commitment, Economical has developed inclusive policies and procedures that mirror the regulatory standards. These policies and procedures will be regularly monitored and reviewed to ensure access and accommodation for all persons with disabilities.
The Accessibility Policy mirrors the regulatory standards both developed by the government and its representatives on the standards development committees.
The purpose of the policy is to:
- identify, remove, and prevent barriers to accessing our services for people with disabilities
- build awareness within the Economical community of the rights of persons with disabilities and our responsibility to foster an accessible and inclusive environment
- provide equal access to services and facilities for all customers
- provide equal opportunity in employment
- monitor the continual improvement of access to our properties, facilities, and services
- define the development, publication, and review of the annual Accessibility Plan
- ensure quality in what and how we deliver services to all members of Economical community
- ensure compliance with all regulatory standards legislated by the government of Ontario
The objective of this policy is to address the following with respect to service delivery to persons with disabilities:
- the provision of goods and services
- the use of assistive devices
- the use of guide dogs and service animals
- the use of support persons
- receiving customer feedback
- employee training
- notice of availability and format of required documents.
Statement of Commitment and Accountabilities
Economical supports and promotes the rights of all persons with disabilities as outlined in the Ontario Human Rights Code, AODA, and the Regulation. Economical also affirms the rights of all persons, including those with disabilities, to have access to equal opportunity in employment or business dealings with Economical.
Economical strives to provide an accessible environment for all persons with disabilities who interact with us and affirms its commitment to promoting the following principles in all of its policies and interactions with persons with disabilities:
Dignity — Respecting the dignity of a person with a disability means treating them as valued customers, deserving of the same high quality and timely service as any other customer. Persons with disabilities are not treated as an afterthought or forced to accept lesser service, quality, or convenience. The delivery of goods and services must take into account how persons with disabilities can effectively access and use them.
Independence — In some instances, independence means freedom from control or influence of others; freedom to make one’s own choices. In other situations, it may mean the freedom to do things in one’s own way. Economical must allow persons with disabilities to take the time they need, without rushing or taking over a task from a person who prefers to do it themselves.
Integration — The provision of goods or services to persons with disabilities and others must be integrated to allow persons with disabilities to fully benefit from the same services, in the same place, and in the same or similar way as other customers. Integration means that policies, programs, and services, including practices and procedures, are designed to be accessible to everyone.
Equal opportunity — Persons with disabilities must be offered the same chances, options, benefits, and results to obtain, use, and benefit from the goods or services provided by Economical. They should not have to make significantly more effort to access or obtain services, or accept lesser quality of services.
- Ensure all leaders and employees are aware of the Accessibility Policy and its application
- Hold all leaders and employees accountable for their responsibilities in related program elements and obligations
- Advocate and support accessibility through assigning internal responsibility, and aligning the required resources and behaviours to targeted initiatives, programs, and policies
- Consider accessibility of people with disabilities as part of the regular development and ongoing review of existing policies and practices
- Amend existing policies as needed to comply with the law in any jurisdiction Economical operates
- Communicate the Accessibility Policy to all employees
- Inform employees of their obligations and accountabilities to adhere to the requirements of the policy as an element of their work performance and a condition of employment
- Implement, monitor, and evaluate compliance to the Accessibility Policy in their business unit
- Ensure employees are responding to requests for accommodation in a timely manner
- Ensure all complaints, or identified risks about accessibility, are dealt with in a timely manner
Human resources accountabilities
- Identify, develop, and deliver required training on policy
- Review the policy and procedures related to accessibility on an annual basis
- Monitor developments of the accessibility standards and communicate these developments to the business
- Support the implementation of accessibility standards in the workplace
- Participate in required training related to the accessibility and Economical policies and procedures
- Promote the principles of dignity, independence, integration, and equal opportunity when providing customer service
- Forward feedback from customers regarding accessibility to their leader
Scope of the Accessibility Policy
The Accessibility Policy applies to the provision of goods and services at premises owned or operated by Economical, as well as any interactions with employees, customers, and clients via telephone, email, post, websites or through social media
This policy applies to employees, as well as volunteers, agents, and contractors who deal with the public or third parties that interact with the public on behalf of Economical.
Disability — The definition of disability used in this policy is the same as that used by the AODA and the Ontario Human Rights Code, defined in five points:
- 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
- an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997
Assistive device — Any device used to assist persons with disabilities in carrying out activities or in accessing the services of our organization. This could include technical devices such as communication devices or personal assistive devices such as a walker.
Support person — An individual hired or chosen by a person with a disability to provide service or assistance with communication, mobility, personal care, medical needs, or access to goods or services.
Guide dog — A highly-trained working dog that has been trained at one of the special facilities to provide mobility, safety, and increased independence for people with visual impairments.
Service animal — The Regulation defines a service animal as “an animal for a person with disability.” For the purposes of this policy, a service animal is any animal used by a person with a disability for reasons relating to the disability, where the person provides:
- a letter from a physician confirming that they require the animal for reasons relating to their disability, or
- 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.
Customers — Include direct customers and customers of third party providers that represent Economical (i.e., brokers).
Barriers — As defined by the AODA, barriers are anything that prevents a person with a disability from fully participating in all aspects of society because of his or her disability. There are several types of barriers:
- physical barrier
- architectural barrier
- information or communications barrier
- attitudinal barrier
- policy, practice, or procedural barrier
Information and Communication
Upon request, Economical will communicate with people with disabilities in ways that take into account each individual’s needs, in a timely manner at no additional cost to the person.
Accessible websites and web content
Economical internet websites and web content will conform to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, initially at Level A and increasing to Level AA, and shall do so in accordance with the schedule set out in the Regulation.
In preparing emergency procedures, plans, and public safety information documents, Economical will ensure that all documents made available to the public will be made available in an accessible format or with appropriate communication supports, upon request.
The purpose of the employment standard is to integrate accessibility into a regular workplace process, and to ensure that Economical provides accessibility across all stages of the employment lifecycle. The employment standard applies only with respect to paid employees. This includes, but is not limited to, full-time and part-time employees and contract employees. The employment standard does not apply to volunteers or other unpaid staff.
Workplace emergency response information
Should any employee at Economical with a disability, whether permanent or temporary, require a personalized workplace emergency response plan, Economical will create such document as soon as the information is provided from the employee. Economical will work with the employee, their leader, and the Occupational Health and Safety committee for that location to ensure a plan is in place in the event of an emergency.
This information shall be reviewed if the employee moves to a different location in the organization, if the employee’s overall accommodation needs or plans change, and when Economical reviews its general emergency response policies.
Economical will notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment process.
Recruitment, assessment, and selection process
Economical will notify job applicants when they are 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 accommodation, Economical 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 due to disability.
Notice to successful applicants
When making offers of employment, Economical will notify the successful applicant of its policies for accommodating employees with disabilities.
Informing employees of supports
Economical will inform its employees of the policies used to support employees with disabilities, including but not limited to policies on the provision of job accommodation that take into account an employee’s accessibility needs due to disability. This information will be provided to new employees as soon as possible after commencing employment.
Accessible formats and communication supports for employees
Upon the request of an employee with a disability, Economical will consult with the employee to provide, or arrange for the provision of accessible formats and communication supports for information that is needs to perform the employee’s role, and information that is generally available to other employees.
Documented individual accommodation plans
Economical will maintain a written process for the development of documented individual accommodation plans for employees with disabilities.
If requested, information regarding accessible formats and the communications supports provided will also be included in individual accommodation plans.
In addition, the plans will include the individual’s workplace emergency response information (where required), and will identify any other accommodation that is to be provided.
For further information on our process for creating documented accommodation plans for employees with disabilities, please see our Accommodation Policy.
Economical is committed to supporting employees who have been absent from work due to illness, injury, or disability, and require accommodation in order to return-to-work. Economical will work with the returning employee and other stakeholders to create a return–to-work plan to ensure a successful reintegration of the employee into the workplace. If required, Economical will create an individual accommodation plan as per our Accommodation Policy.
Performance management, career development, advancement, and redeployment
Economical is committed to providing all employees equal opportunity for advancement. Economical will take into account the accessibility needs of its employees with disabilities, as well as individual accommodation plans (where they are in place), when undertaking performance management, and providing career development and advancement to employees with disabilities. When conducting any redeployment initiatives, Economical will also take into account the accessibility needs and individual accommodation plans (where they are in place).
Design of Public Spaces
Economical is committed to ensuring its buildings are accessible. Economical reviews the requirements associated with the Regulations on a regular basis.
In such cases where a person with a disability requires the use of their own personal assistive devices in order to access the goods and services provided by Economical, they are welcome to do so. Assistive devices include, but are not limited to hearing aids, wheelchairs, electronic organizers, magnifying devices, and electronic voice synthesizers.
In cases where the assistive device presents a safety concern or where accessibility might be an issue, other reasonable measures will be used to facilitate access to goods and services.
Guide dogs and service animals
Persons with disabilities who rely on the use of guide dogs or service animals are welcome to bring such animals with them to Economical in order to access the goods and services provided. The only exception to this practice is where such animals are prohibited by law.
Dog Owners' Liability Act, Ontario
If there is a conflict between a provision of this act or of a regulation under this or any other act relating to banned breeds (such as pit bulls) and a provision of a bylaw passed by a municipality relating to these breeds, the provision that is more restrictive in relation to controls or bans on these breeds prevails.
If a guide dog or service animal is excluded by law, Economical will make all reasonable efforts to offer alternative methods to enable the person with a disability to access goods and services.
Recognizing a guide dog and/or service animal
If it is not readily apparent that the animal is being used by the customer for reasons relating to a disability, Economical may request verification from the customer which should include
- a letter from a physician, therapist, or nurse confirming that the person requires the animal for reasons related to the disability,
- 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.
If the use of a support person is required in order to access the goods and services provided by Economical, persons with disabilities are welcome to have the support person present when interacting with Economical. If necessary, Economical will request written authorization to validate that the support person can act on the customer’s behalf.
Economical recognizes that at times, a support person may be necessary for the health and safety of the person with the disability or for the health and safety of others on the premises.
All customer confidentiality requirements and practices will also apply to support person.
Economical will ensure all members of the organization strive to communicate with a person with a disability in a manner that takes into account their disability. All employees will be trained on how to interact and communicate with customers with disabilities. We will offer alternative communication and document formats that will meet the needs of customers with disabilities as promptly as feasible.
Training will be provided to all employees and volunteers who interact with the public on behalf of Economical. Training will be provided as soon as practicable upon the individual being assigned the applicable duties, and on an ongoing basis as changes occur to Economical policies, procedures, and practices relating to the provision of services to persons with disabilities.
Economical will keep a record of training that includes the dates training was provided, the number of employees, and names of employees trained.
The training will be conducted in an online format and will include information on the purposes of the Regulation, how to communicate and interact with people with disabilities, how to interact with a service animal or support person, how to utilize assistive devices that are available on our premises, how to interact with persons with disabilities who use an assistive device or require assistance of a service animal or support person, what to do if a person with a disability has difficulty accessing Economical services or facilities, and our policies, procedures, and practices pertaining to accessibility.
Contractors and agents providing services to the public on behalf of Economical will also be required to ensure their staff has received appropriate training.
Disruption of service
Service disruptions may occur due to reasons that may or may not be within the control or knowledge of Economical. In the event of temporary disruption to facilities or services that customers with disabilities rely on, reasonable efforts will be made to provide advance notice. In some circumstances, such as an unplanned temporary disruption, advance notice may not be possible.
Notification will be given by posting the information in a conspicuous place that is owned and operated by Economical, the website, or any other reasonable method. In the event that a notification needs to be posted, the following information will be included, unless it is not readily available or known:
- the goods or services that are disrupted or unavailable
- the reasons for the disruption
- the anticipated duration
- description of alternative service or options
Customers will have an opportunity to provide feedback on how Economical provides goods or services to people with disabilities. This feedback will be received by the Economical human resources department, and feedback will be forwarded to the relevant business unit. Economical will respond to any feedback and take immediate action on any complaints. Feedback forms, along with alternate methods of providing feedback, such as verbally (in person or by telephone), or written (paper or electronic), will be made available upon request.
Availability and format of documents (alternative formats)
All documents required by the Regulation, as well as related policies, including the Accessibility Policy, notices of temporary disruptions, training policy, and written feedback process, are available upon request. When providing these documents to a person with a disability, Economical will endeavour to provide the document, or the information contained in the document, in a format that takes the person’s disability into account.
Review and Administration
All areas of Economical are accountable for ensuring that the principles of this policy are upheld. However, it is the responsibility of human resources to ensure that this policy is reviewed every three years, or as required, to ensure adherence to developing law (i.e., regulatory standards for accessibility). Should you have any questions or concerns about this policy or the related procedures, please contact Economical:
Economical Insurance Accessibility Plan
At Economical, we strive to meet the needs of our customers, partners, and employees with disabilities, and are actively working to remove and prevent barriers to accessibility.
We are committed to fulfilling our requirements under the Accessibility for Ontarians with Disabilities Act (AODA), 2005. This multi-year accessibility plan outlines the steps Economical has taken, and is taking, to meet those requirements, and to create or improve opportunities for people with disabilities.
Achievements to Remove and Prevent Barriers
The following represents a summary of the accessibility initiatives Economical has completed up to and including December 31, 2017.
Economical is committed to ensuring our customer service policies and practices meet or exceed the Customer Service Standard established by the AODA. We have done this by:
- Providing appropriate and timely training to all necessary persons that is aligned with the requirements of the accessibility standards referred to in the Integrated Accessibility Standards Regulation (IASR), and continuing to provide training on the AODA as it pertains to persons with disabilities. Appropriate records of training are maintained.
- Establishing processes for customers to provide feedback or request an accommodation through all channels including telephone, TTY service, email, and post. Through these processes, we have received customer requests to supply alternative formats and have worked with those customers to provide solutions that meet their needs in a timely fashion.
Information and Communication
Economical is committed to ensuring we meet or exceed the communication and information requirements of people with disabilities. We have done this by:
- Introducing a digital accessibility specialist role responsible for ensuring all external digital messaging is rigorously tested to comply with the WCAG 2.0 A standard or better
- Conducting ongoing, extensive testing using assistive technology devices on all digital properties to confirm compliance
- Identifying gaps in the WCAG Level A requirements and establishing an internal standard for all Economical digital properties that exceeds the compliance requirements to deliver an experience that is accessible to all users. To address these gaps we have incorporated the following additional WCAG 2.0 Level AA criteria:
- 2016 — Colour contrast requirements for web and digital messaging
- 2016 — Focus position is identified on all interactive controls
- 2016 — Resize text 200% without reflow issues
- 2016 — Images of text all have alternative text relayed through screen reader
- 2016 — Multiple ways of finding content on digital properties (increased to three ways rather than the AA required two)
- 2016 — Descriptive headings and labels
- 2016 — Consistent navigation
- 2016 — Error prevention (legal, financial, data)
- Conducting internal training sessions as required for developers, designers, and content creators on meeting WCAG 2.0 Level A compliance and our internal AA criteria
- Conducting third-party accessibility audits and user testing on external digital properties when new sites are launched
- Acquiring automated accessibility testing and reporting tool for our web properties
- Curating an extensive library of accessibility requirements, samples, and tools for development and content creation teams to reference and review
Economical is committed to ensuring our standards for accessibility training are in full compliance with applicable regulations. We have done this by:
- Mandatory AODA training for all new employees
- Transitioning our eLearning authoring tools for employee and partner audiences to one that allows HTML output, removing a dependency on Flash-based content (net new eLearning content is created using accessible technologies)
- Documenting barriers in our current state of training platform and materials against accessibility requirements and developing a roadmap for remediation
- Developing a learning module for customer-facing roles to address specific accommodation requests
Economical is committed to being an inclusive and accessible employer. We have done this by:
- Workplace emergency response information — Individual workplace emergency response plans have been developed, documented, and implemented for employees with disabilities.
- Recruitment — Open positions are posted on economical.com and include notice of the availability of accommodation for applicants with disabilities in the recruitment process. In addition, applicants are notified when they are called for an interview about the availability of recruitment-related accommodations during the selection process.
- Informing employees of support available — Economical advises potential employees of supports available during the offer process and is outlined in our employment offer letter. Updated information on accommodations policies is provided to employees when changes occur.
- Individual accommodation plans — On request, we will consult with an employee with a disability to create an individual accommodation plan to determine which accessible formats or communication supports they require to perform the duties of their job. The plan will cover:
- Providing individual accommodation plans in a format that meets the needs of the employee
- Individualized workplace emergency response information, if required
- Regular review and updates to the individual accommodation plan, where required
- Return to work process to ensure successful re-integration to their role
- Privacy considerations
- Performance management, career development, advancement, and redeployment — When undertaking performance management, and providing career development and advancement opportunities to employees with disabilities, we will take into account the accessibility needs as well as individual accommodation plans (where they are in place). We will also regularly review and update our internal people practices and procedures.
Economical is committed to ensuring our procurement processes prevent barriers to accessibility. We have done this by:
- 2017 —Procurement and selection of third party digital tools must meet accessibility compliance requirements.
- 2017 and beyond — Business continuity and disaster recovery plans are in place to address the needs of our customers, partners, and employees with disabilities during times of service disruption.
- 2017 — Launched an Accessibility Advisory Committee to review accessibility compliance efforts.
- 2017 — Established a Diversity and Inclusion Advisory Committee and two employee resource groups.
Future Strategies and Actions
The following represents a summary of the accessibility initiatives Economical is committed to pursuing in 2018 and beyond.
Economical is committed to providing ongoing accessible customer service, providing goods and services to people with disabilities with the same high quality and timeliness as others.
- 2018 — All employees must complete the AODA training course within their first month of employment.
- 2018 — Economical will introduce a training course specifically for customer service representatives, focusing on interacting with customers with diverse needs.
Information and Communications
Economical is committed to making our information and communications accessible to people with disabilities.
- 2018 and beyond — Economical is committed to delivering digital properties which meet or exceed WCAG 2.0 Level A requirements. Additionally, any significant, net new changes to our web properties will be designed and developed to meet WCAG 2.0 Level AA compliance in advance of the January 2021 deadline.
- 2018 — Document accessibility will be incorporated at the asset design phase.
- 2018 — Automated accessibility reporting will be incorporated and integrated within development and design workflows
Economical is committed to providing training in the requirements of Ontario’s accessibility laws and the Ontario Human Rights Code as it applies to people with disabilities.
- 2018 and beyond — All employees will continue to be required to complete the AODA training module
- 2018 — Review the current employee training portal for accessibility compliance
- 2018 — Addition of a customer service representative specific training module available to employees related to interacting with users with diverse needs
- 2018 — Finalize internal accessibility review process for developing accessible learning assets
- 2018 — Selection of alternate training platform solution that provides a more robust accessible experience for all employees
- 2018 and beyond — New eLearning content will be created using accessible technologies
Economical is committed to fair and accessible employment practices.
Economical is committed to ensuring our procurement processes include accessibility checkpoints for all digital and physical products and services where applicable.
- 2018 and beyond — Procurement for digital solutions will incorporate accessibility requirements as an integrated step in the sourcing and selection processes.
Design of Public Spaces
Economical continues to meet accessibility laws when building or making major changes to public spaces.
- 2017 — Work is underway to reconstruct the employee entrance of the Economical head office. The construction incorporates changes to outdoor eating areas and outdoor paths of travel. Construction is planned for completion mid-2018 and will meet the technical requirements for public space accessibility.
- 2017 — Procedures are being developed to prevent service disruptions to the accessible parts of our public spaces.
For More Information
For more information on this accessibility plan, please contact us at:
You can also submit your comments through our online Customer Service Feedback form or contact us through our website or our social media channels:
Standard and accessible formats of this document are available on request from firstname.lastname@example.org.