This policy establishes the requirements for accessibility standards for customer service in accordance with the Accessibility Standards for Customer Service (Ontario Regulation 429/07) as set out within the Accessibility for Ontarians with Disabilities Act (AODA).
The AODA was enacted for the purpose of developing, implementing and enforcing accessibility standards to ensure that customer service is available to everyone, including persons with disabilities.
This policy applies to: 1. All Ontario Racing Management Inc. (“ORM”) employees including, but not limited to temporary staff, volunteers, contractors and third party service providers who deal with members of the public and other third parties on our behalf.
ORM is committed to the provision of goods and services to all persons we serve, including persons with disabilities. This commitment will be reflected in ORM’s policies, practices and procedures.
Disability: (Source: Guide to the Accessibility Standards for Customer Service, Ontario Regulation 429/07). The following definition is the same as the definition of disability in the Ontario Human Rights Code and applies to the customer service standard of the AODA.
The definition includes disabilities of different severity, visible as well as non-visible disabilities, and disabilities with effects that may come and go.
Products or services that can help an individual carry out daily activities with greater ease and independence, such as a walker, a personal oxygen tank, TTY (Telephone Teletype), or amplification systems.
Service Animal: (Source: guide to the Accessibility Standards for Customer Service, Ontario Regulation 429/07) An animal is a service animal when it is readily apparent that the animal is used for reasons relating to a disability or the person with a disability has a letter from a physician or nurse that states the animal is required for disability related reasons.
Support Person: (Source: Guide to the Accessibility Standards for Customer Service, Ontario Regulation 429/07) A person who accompanies an individual with a disability to assist with communication, mobility, personal care of medical needs or with access to goods or services. The support person could be a paid personal support worker, a volunteer, a friend or a family member.
1.1 ORM will use reasonable efforts to ensure that policies, practices and procedures are documented and consistent with the following core principles of the standard:
2.1 When communicating with a person with a disability, employees will do so in a manner that takes into account the person’s disability.
2.2 When providing a copy of a document to a person with a disability ORM shall give the person the document, or the information contained in the document, in a format that takes into account the person’s disability.
3.1 ORM permits customers with disabilities to use their own personal assistive devices providing the assistive device does not jeopardize or interfere with the integrity, assets of the organization and safety of other customers, employees or equine athletes.
4.1 ORM may offer a person with a disability other reasonable measures to assist the person in obtaining, using or benefiting from ORM’s goods and services. Where ORM provides assisted services they must be documented in policies, practices and procedures.
5.1 ORM ensures entry of customers with disabilities accompanied by a personal support person into ORM premises, with age restrictions in certain areas.
5.2 Where admission fees are charged, the support person will receive access free of charge.
6.1 A person with a disability may enter ORM premises accompanied by their guide dog or service animal in areas of the premises that are open to the public, unless the animal is excluded by another law or for safety considerations. If a service animal is excluded by law or for safety considerations, other measures to provide service to the person with a disability may be used.
7.1 ORM will make reasonable efforts to provide notice to customers, when possible, if services are unavailable.
7.2 When a disruption occurs unexpectedly, notice shall conspicuously be posted as soon as possible.
8.1 ORM will acknowledge feedback in a timely manner that takes into account the customer’s disability.
8.2 ORM will capture and track customer feedback.
9.1 All persons to whom this policy applies will receive training as required by the Accessibility Standards for Customer Service, including contractors, third parties and volunteers.
9.2 Accessible Customer Service training will be provided to all ORM employees.
9.3 Records of training will be kept by the Director, Guest Services, including the dates that training was provided and the number of individuals who received the training.
9.4 Training information will be available to customers upon request while maintaining personnel privacy considerations.
10.1 ORM falls under the Accessibility Plan of Woodbine Entertainment Group (“WEG”). Public access to the annual WEG Accessibility Plan will be available in alternative formats upon request here.
11.1 Annual reporting to the Ministry.
11.2 Annual reporting to WEG’s CSR Officer.
ORM is committed to ensuring equal access and participation for people with disabilities. We are committed to treating people with disabilities in a way that allows them to maintain their dignity and independence.
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 by meeting our accessibility requirements under Ontario’s accessibility laws.
APPLIES TO: All Employees
This policy establishes Ontario Racing Management’s (ORM’s) commitment to meet the accessibility needs of persons with disabilities in compliance with the Integrated Accessibility Standards Regulation in the areas of Employment, Information and Communications, Transportation and Public Spaces in accordance with Ontario Regulation 191/11 (the “Regulation”).
This policy has been written in accordance with the Regulation and addresses how ORM achieves accessibility through meeting the Regulation’s requirements. It provides the overall strategic direction that we will follow to provide accessibility supports to Ontarians with disabilities.
The requirements of the Regulation include the following four (4) items:
ORM is committed to and guided by the following four (4) core principles:
We support the full inclusion of persons as set out in the Ontario Human Rights Code and the Accessibility for Ontarians with Disabilities Act, 2005.
ORM shall endeavor to ensure that we meet the needs of people with disabilities, in a timely manner, through the implementation of this policy.
Below is a list of fifteen (15) definitions used in this policy, listed in alphabetical order:
Accessible Formats may include, but are not limited to, large print, recorded audio and electronic formats, Braille and other formats usable by persons with disabilities.
Accommodation means the special arrangement made or assistance provided so that persons with disabilities can participate in the experiences available to persons without disabilities. Accommodation will vary depending on the person’s unique needs.
Communication Supports may include, but are not limited to, captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications.
Communications means the interaction between two or more persons or entities, or any combination of them, where information is provided, sent or received.
Conversion Ready means an electronic or digital format that facilitates conversion into an accessible format.
IAP means Individualized Accommodation Plan.
Information includes data, facts and knowledge that exists in any format, including text, audio, digital or images, and that conveys meaning.
Internet Website means a collection of related web pages, images, videos or other digital assets that are addressed relative to a common Uniform Resource Identifier (URI) and is accessible to the public.
Maintenance of Public Spaces means activities that are intended to keep existing public spaces and elements in existing public spaces in good working order or to restore the spaces or elements to their original condition, examples of which include painting and minor repairs.
Mobility Aid means a device used to facilitate the transport, in a seated posture, of a person with a disability.
Mobility Assistive Device means a cane, walker, wheelchair, scooter or similar aid.
New Internet Website means either a website with a new domain name or a website with an existing domain name undergoing a significant refresh.
Redeployment means the reassignment of employees to other departments or jobs within the organization as an alternative to layoff, when a particular job or department has been eliminated.
Unconvertible means that it is not technically feasible to convert the information or communications. It also means that the technology to convert the information or communications is not readily available.
Web Content Accessibility Guidelines means the World Wide Web consortium recommendation, dated December 2008, entitled “Web Content Accessibility Guidelines” (WCAG) 2.0.
This section covers the general requirements of the Integrated Accessibility Standards Regulation.
ORM falls under the Multi-Year Accessibility Plan of Woodbine Entertainment Group (“WEG”). WEG’s Multi-Year Accessibility Plan outlines a phased-in strategy to prevent and remove barriers and addresses the current and future requirements of the Accessibility for Ontarians with Disabilities Act (AODA). WEG reviews the progress and implementation of the plan, posts the plan on its website and provides it in alternative formats upon request. The plan is reviewed and updated at least once every five years.
ORM will use accessibility criteria and features when procuring or acquiring goods, services or facilities, except where it is not practical to do so, in which case, if requested we will provide an explanation.
ORM will ensure that training is provided to employees on the requirements of the accessibility standards referred to in the Regulation and in the Human Rights Code as it pertains to persons with disabilities. Training will be provided as soon as practicable following the hiring of new employees, and will be refreshed for existing employees from time to time. If any changes are made to this policy, further training will be provided. We shall maintain a record of the dates when training is provided and the number of individuals to whom it was provided.
ORM will create and provide information and communications in ways that are accessible to people with disabilities.
If ORM determines that it is not technically feasible to convert the information or communications, or the technology to convert the information or communications is not readily available, we will provide the person that requires the information with an explanation as to why the information or communications are unconvertible; and a summary of the unconvertible information or communications.
If ORM prepares emergency procedures, plans or public safety information and makes the information available to the public, we shall provide the information in an accessible format or with appropriate communication supports, as soon as practicable, upon request.
ORM shall provide all feedback received with respect to its compliance with the Regulation and/or this Policy from customers to WEG’s Customer Service Department. WEG’s Customer Service Department shall respond to customer feedback and will ensure that any responses are provided in accessible formats and with communication supports upon request. We will notify the public about the availability of accessible formats and communication supports. Where feedback is received from an employee with respect to ORM’s compliance with the Regulation and/or this Policy, the employee’s supervisor will provide such feedback to WEG’s Human Resources Department, who will respond to the employee.
ORM shall provide or arrange for accessible formats and communication supports for persons with disabilities in the following manner:
ORM and WEG are committed to digital accessibility, and to conforming to the Web Content Accessibility Guidelines (WCAG) 2.0, Level AA and complying with the Accessibility for Ontarians with Disabilities Act (AODA) effective communication requirements, and other applicable regulations.
To accomplish this, we have partnered with eSSENTIAL Accessibility to administer our accessibility program and oversee its governance. Their accessibility program evaluates and audits our digital products on an ongoing basis in accordance with best practices and is supported by a diverse team of accessibility professionals, including users of assistive technologies. The platform, moreover, goes beyond minimum compliance requirements by making an assistive CX technology application available to customers who have trouble typing, gesturing, moving a mouse, or reading. The application is free to download, and it incorporates tools such as mouse and keyboard replacements, voice recognition, speech enablement, hands-free/touch-free navigation, and more.
We want to hear from you if you encounter any accessibility barriers on our digital properties. Please contact our Customer Support at HZA@woodbine.com.
The Employment Standards of the Regulation build upon the existing requirements under the Ontario Human Rights Code in relation to how we provide accessibility throughout the entire employment cycle. It applies with respect to employees but does not apply to volunteers and other non-paid individuals.
The requirements of the Employment Standard shall be met by ORM by January 1, 2016 unless otherwise specified.
ORM shall notify employees and the public about the availability of accommodations for applicants with disabilities as listed below:
ORM shall inform its employees of its policies used to support its employees with disabilities, including but not limited to, policies on the provision of job accommodations that take into account an employee’s accessibility needs due to a disability.
ORM shall provide information required under this section to new employees as soon as practicable after they begin their employment and whenever there is a change to existing policies on the provision of job accommodations that take into account an employee’s accessibility needs due to a disability.
In addition and where an employee with a disability requests it, ORM will consult with the employee to provide or arrange for the provision of accessible formats and communication supports as listed below:
ORM shall consult with the employee making the request in determining the suitability of an accessible format or communication support.
An IAP shall be provided to an employee with a disability upon request. ORM will develop and document such individual accommodation plans for employees with disabilities in accordance with the following:
ORM will develop and document a return to work process for employees who have been absent from work due to a disability and require disability-related accommodation in order to return to work. Such process shall outline the steps that ORM will take to facilitate the return to work and include an individual accommodation plan.
ORM will take into account the accommodation needs and/or individual accommodation plans of employees when:
ORM shall provide individualized workplace emergency response information to employees who have a disability as per the four (4) points below:
ORM will incorporate accessibility into public spaces that are newly constructed or redeveloped on and after January 1, 2017. ORM will follow the existing requirements stated under the Design of Public Spaces Standards (Accessibility Standards for the Built Environment). ORM will provide maintenance and restoration of public spaces, where applicable, and notify the public of temporary disruptions and alternatives available.