Presented by: Dorothy Macnaughton Accessibility and Diversity Training January 31, 2009 Copyright ©...

How to Implement Ontario’s Accessible Customer Service

Standards in Your Library

Presented by:Dorothy Macnaughton

Accessibility and Diversity TrainingJanuary 31, 2009

Copyright © 2009 Accessibility and Diversity Training

OLA Superconference, 2009Session 1812

Customer Service Everyone can be great because everyone

can serve. Martin Luther King Jr.

Great customer service for everyone makes sense. Customer service that meets the needs of people with disabilities not only makes sense, it will soon be something you must do under new legislation in Ontario.

Introduction

Making your library as accessible as possible for people with disabilities in your local communities, schools, colleges and universities means everyone can have access to all of the great programs and services that today’s libraries offer.

It also means that any new programs, a new website or new services will need to be designed so they will be accessible from the time they are introduced.

Introduction

The Accessibility for Ontarians with Disabilities Act (AODA), 2005, will create provincial standards for accessibility for persons with disabilities by 2025.

The Standards will outline legal requirements and deadlines.

Accessibility for Ontarians with Disabilities Act

Purpose: Section 1 …the purpose of this Act is to

benefit all Ontarians by, (a) developing, implementing and

enforcing accessibility standards in order to achieve accessibility for Ontarians with disabilities with respect to goods, services, facilities, accommodation, employment, buildings, structures and premises on or before January 1, 2025.

Accessibility for Ontarians with Disabilities Act

Accessibility Standards for Customer Service

Accessibility Standards for Information and Communications (draft form for public feedback)

Accessibility Standards for Transportation (have been sent to Minister)

Accessibility Standards for the Built EnvironmentAccessibility Standards for Employment

Five Accessibility Standards

Accessibility Standards for Customer Service were the first of the Standards to be declared regulations, under the AODA, and came into effect in January, 2008.

These Standards must be implemented by public sector organizations by January 1, 2010.

The next set of Standards which will likely become regulations will be those for Information and Communications. These Standards will, of course, have important implications for all types of libraries.

Accessible Standards for Customer Service

ONTARIO REGULATION 429/07made under the

Accessibility For Ontarians With Disabilities Act, 2005 Made: July 25, 2007

http://www.e-laws.gov.on.ca/html/source/regs/english/2007/elaws_src_regs_r07429_e.htm

Accessible Standards for Customer Service

This Regulation establishes accessibility standards for customer service and it applies to every designated public sector organization and to other third parties.

“Designated public sector organization” means …every ministry of the Government of Ontario, every municipality…”◦ Guide to Accessibility Standards for Customer Service

Public Sector Organizations

Examples of providers of goods or services: Municipal and provincial governments

programs and facilities that they run, including social assistance services, public meetings, public transit, libraries, and employment centres;

CollegesUniversitiesSchools

Are Libraries in the Public Sector?

Prevention of New Barriers

Ordering goods Delivering New Services, Revising Current

Services or Programs **Strategic Planning

◦ Mission StatementShort term planningLong term planning

Philosophy of Accessibility

Written Policies• Human Rights Principles• Training• Service Animals• Support Persons• Personal Assistive Devices• Temporary Disruption• Feedback Process

Required Components

Practices Procedures

Required Components

Overarching Human Rights Principles will apply to all five Standards.

When designing your policies, practices and procedures consistent with human rights principles, your organization will want to take into account your own unique situations.

Human Rights Principles

In 3. (2), you are expected to use reasonable efforts to ensure that your policies, practices and procedures are consistent with the principles of dignity, independence, integration, (except when alternate measures are necessary to meet the needs of people with disabilities) and equal opportunity.


An example of “using reasonable efforts”:

A customer who is blind and reads Braille may need to know exactly what is on her bill, but be unable to read a print copy.

Each organization has designed solutions to meet that customer’s needs in different ways.


At a small coffee shop, a waiter or cashier might read the bill to the person. A florist shop might offer to read a bill by phone. A mid-sized utility company might offer monthly bills in Braille and then might hire another company to print and send the Braille bills. A larger utility with more customers who use Braille might determine that it is more cost effective to purchase equipment to create its own monthly bills in Braille and may also offer an accessible website that allows bill viewing and payment online.


3. (2) 1. The goods or services must be provided in a manner that respects the dignity and independence of persons with disabilities.(Ontario Regulation 429/07, Accessibility Standards For Customer Service)

Respecting a person’s dignity means they are treated in a way that does not put them down or demean them because they have a disability.Most people with disabilities want to be as independent as possible and appreciate it when someone values their independence.


3. (2) 2. The provision of goods or services to persons with disabilities and others must be integrated, unless an alternate measure is necessary, whether temporarily or on a permanent basis, to enable a person with a disability to obtain, use or benefit from the goods or services.(Ontario Regulation 429/07, Accessibility Standards For Customer Service)


Integrated services are those that allow people with disabilities to fully benefit from the same services, in the same place and in the same or similar way as other customers.

Sometimes integration does not serve the needs of all people with disabilities. In these cases, it is necessary to use alternate measures to provide goods or services. Goods or services may need to be provided to people with disabilities in a different place or in a different way than other customers.◦ using TTYs or e-mail to communicate with customers who

are deaf or have speech impairments, instead of providing services by phone


3. (2) 3. Persons with disabilities must be given an opportunity equal to that given to others to obtain, use and benefit from the goods or services.

(Ontario Regulation 429/07, Accessibility Standards For Customer Service)


Equal opportunity means having the same chances, options, benefits and results as others. People with disabilities need to have the same opportunity to benefit from the way you provide goods or services as others.

You may have to treat individuals slightly differently, so they can benefit fully from your services. Individual needs should be taken into account when providing goods or services.◦ Reading titles on DAISY books to a library patron with low

vision◦ Reading information on a poster describing a library

program to someone with a learning disability


Service AnimalsSupport PersonsUse of Personal Assistive DevicesNotice of Temporary DisruptionReceiving and Responding to FeedbackTraining Policy

Written Documents Required

Service animals allowed on your premises Support persons permitted to accompany a

person with a disability◦ Explanation of fee, if applicable

Use of personal assistive devices allowedNotice of temporary disruption

Steps to be takenWritten Process for receiving and

responding to feedbackSteps to be taken to respond to complaint

Written Documents Required

Public sector organizations must prepare a document describing your training policy, including a summary of the contents of the training and details of when the training was provided.

Every designated public sector organization must keep records of the training provided, including the dates on which the training was provided and the number of individuals to whom it was provided.

Training

If there are changes to policies, practices and procedures governing the provision of goods or services to persons with disabilities, training about those changes must be provided.

Training

If a person with a disability is accompanied by a guide dog or other service animal, your organization must ensure that the person is permitted to enter the premises with the animal and to keep the animal with him or her.

This must be included in a written policy.

Service Animals

If a person with a disability is accompanied by a support person, your organization must ensure both people are permitted to enter the premises together, and that the person with a disability is not prevented from having access to the support person while on the premises.

If an admission fee is charged, your organization must ensure notice is given in advance about the amount to be paid by the support person.

These must be included in your written policies.

Support Persons

Your written policy must allow people to use their own personal assistive devices to access your goods and services, and must describe situations where such use may not be permitted.

Personal Assistive Devices

If people with disabilities usually use your facilities or services, and if there is a temporary disruption, you must give notice of the disruption to the public, including the reason for the disruption, its anticipated duration and a description of alternative facilities or services that are available.

This information must be posted. A document must outline steps to be taken

when there is a temporary disruption and, upon request, must be provided to anyone who requests it.

Temporary Disruption

A written process must be outlined for receiving and responding to feedback about the manner in which your organization provides goods or services to persons with disabilities.

This process must be communicated to the public.

Feedback can be provided in person, by telephone, in writing, or by email, on disc, or otherwise.

Feedback Process

The feedback process must specify the actions you will be taking if a complaint is received.

Your organization must prepare a document describing your feedback process and provide a copy to anyone requesting it.

Feedback Process

Examples:◦Human Rights/Diversity Policies◦Training Policies

Policies

Written steps staff are expected to take Examples:

◦How meetings with customers will be conducted

◦How staff will assist people with disabilities who require assistance using screen reading software

Procedures

Day-to-day interaction, communication How your staff actually offer or deliver your

services, flexibility Examples:

◦ Requirements for filling out forms – someone with a learning disability may require assistance

◦ Requirements for signatures or showing of ID◦ Someone with a mental health issue may require

extra time and patience if they are agitated about an overdue fine

◦ How to communicate with someone who is deaf

Practices

Examples:◦ Written directions/tip sheets on how to interact

and communicate with people with each type of disability

◦ People First Language

Practices

There is a requirement to prepare one or more documents describing your policies, practices and procedures and to provide a copy, upon request.

When providing a copy of a document to a person with a disability, the provider must give the person the document, or the information contained in the document, in a format that takes into account the person’s disability.

The format of the document or information can be determined by agreement between the organization and the person with the disability.

Copies of Policy Documents

• Information and Communications Standard • will impact on formats in which documents are

provided, as well as language, including plain language•

http://www.mcss.gov.on.ca/mcss/english/pillars/accessibilityOntario/accesson/business/information/

• Annotated Version of the Information and Communication Standard

• http://www.mcss.gov.on.ca/mcss/english/pillars/accessibilityOntario/accesson/business/information/standard/index.htm

Still time for public feedback until February 6

Documents and the Information and Communications Standard

Use of Plain Language for public documents

Plain Language – a way of writing and presenting information and complex messages so that it is easy to read, understand and use; some characteristics of plain language may include writing to a simpler reading level, eliminating jargon and unnecessary words, using familiar words in a conversational style, and the use of uncomplicated sentence structure and grammar.

Documents and the Information and Communications Standard

Plain Language: (taken from:

http://www.plainlanguage.gov/howto/guidelines/reader-friendly.cfm

Federal Plain Language Guidelines (U.S.)

Written material is in plain language if your audience can:

Find what they need; Understand what they find; and Use what they find to meet their needs.

Documents and the Information and Communications Standards

Every person who participates in developing the provider’s policies, practices and procedures governing the provision of goods or services to members of the public or other third parties.

Customer Service TrainingWho Requires Training?

Every person who deals with members of the public or other third parties on behalf of the provider, including volunteers.◦ Library volunteers interacting with the public◦ Include Accessible Customer Service Training

with Volunteer Training and Orientation


A library has full-time and part-time staff who do a variety of tasks, such as serve patrons at the circulation or reference desks. A janitor is on-site to take care of the building and to close the library. He does not deal with the public for library-related services. All library staff, except the janitor, must receive training, to meet the requirement of the customer service standard, as they deal with members of the public on behalf of the library.


The training must be provided to each person, as soon as practicable, after he or she is assigned the applicable duties.

Importance of Accessible Customer Service orientation materials for new staff, including up-to-date copies of all policies, procedures and practices• document date new staff received basic

materials and when they received full training

Customer Service TrainingWhen is Training Required?

Purposes of the Accessibility for Ontarians with Disabilities Act

Definition of “disability” It helps to include the definition of “barrier”

and “accessibility” (Ministry of Municipal Affairs and Housing) and “barrier-free” (Ontario Building Code)

Customer Service TrainingWhat Must Be Included

AODA Section 2 In this Act, “disability” means,(a) 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,

What is a “disability”?

(b) a condition of mental impairment or a developmental disability,

(c) a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,

(d) a mental disorder, or (e) an injury or disability for which benefits

were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997;

What is a “disability”?

Disabilities may: be visible (person carrying a white cane) be invisible (a learning disability) have effects which may come and go differ in severity (degree of vision or

hearing loss) Example: A person with multiple sclerosis may experience periods when the condition does not have an effect on her daily routine and other periods when it does.

Types of Disabilities

Information about one’s disability is personal and private and must be treated confidentially. In most cases, it will not be necessary to ask for proof of a disability. Some providers, such as schools, colleges and universities may require proof of disability, because of the type of services that they provide. In such cases, these providers may be subject to privacy-related laws with respect to that information.

This may come into play when employment is involved.

Personal Information About One’s Disability

How to interact and communicate with persons with various types of disability• need to understand basic information about the

types of disabilities listed in the definition of “disability” in the AODA, in the ODA and the Ontario Human Rights Code• must gain a good understanding of how to treat

people with disabilities in general • must develop a knowledge of effective

communication methods for each specific disability


TIP #1: ACT AS YOU WOULD WITH A PERSON WHO

IS NOT DISABLED. TIP # 2: DON’T MAKE ASSUMPTIONS ABOUT THE

PERSON’S DISABILITY OR THEIR NEED FOR ASSISTANCE.◦ JUST ASK!◦ Listen

How to Interact with Someone with a Disability

TIP #3: PUT THE PERSON FIRST AND THE DISABILITY

SECOND.◦ People First Language◦ Body Language◦ Tone of Voice

How to Interact with Someone with a Disability

How to Communicate with:◦ people who are blind or who have low vision◦ individuals who are deafblind◦ people who are deaf, deafened or hard of hearing◦ people with physical disabilities◦ those who have speech impediments◦ individuals with learning disabilities◦ people with mental health disabilities◦ those with developmental disabilities◦ people who have a brain injury

Communicating with People with Disabilities

How to interact with persons with disabilities who use an assistive device◦ Example:

A government office that provides detailed information by phone might use a TTY to communicate with its clients who are deaf, hard of hearing, have speech impairments or are deaf-blind.


How to interact with persons with disabilities who require the assistance of a guide dog or other service animal, or the assistance of a support person◦ Understanding of basic “guide dog etiquette”◦ Role of the support person – not to speak to the

support person, rather than the person with a disability


How to use equipment or devices available on your premises, or otherwise provided by you, that may help with the provision of goods or services to a person with a disability.◦ Example: if you have screen magnification or

screen reading software installed on computers in your library, your staff assisting people using those computers must have training in how to use that software so they will be able to assist the person, as required.


Communication of feedback policy(customer who has experienced a barrier/ who

has a concern)What to do if a person with a particular type of

disability is having difficulty accessing your goods or services

How to provide this documented information in a manner the person with a disability requires


Meets all of the requirements of the legislation

Explains the rationale for policies, practices, procedures and training

Has clear explanations of goals of training Involves plain language documents

available in public location Includes summary of training Is meaningful

Effective Training

Leads to a better understanding of the needs and challenges of the person with a disability; staff can put themselves in the position of the person with a disability

Has interactive components Provides practical tips and useful resources

which can be used to apply what has been learned

Ensures resources will be available to refer to when difficult situations arise

Effective Training

Accessibility report 14. (1) A person or organization to whom

an accessibility standard applies shall file an accessibility report with a director annually or at such other times as the director may specify. 2005, c. 11, s. 14 (1).

Report available to public (2) A person or organization shall make an

accessibility report filed under subsection (1) available to the public. 2005, c. 11, s. 14 (2).

Reporting Under the AODA

Inspectors 18. (1) The Deputy Minister shall appoint

one or more inspectors for the purposes of this Act and the regulations within a reasonable time after the first accessibility standard is established under section 6. 2005, c. 11, s. 18 (1).

Inspectors under the AODA

Penalties (3) Every person who is guilty of an offence

under this Act is liable on conviction, (a) to a fine of not more than $50,000 for

each day or part of a day on which the offence occurs or continues to occur; or

(b) if the person is a corporation, to a fine of not more than $100,000 for each day or part of a day on which the offence occurs or continues to occur. 2005, c. 11, s. 37 (3).

Penalties under the AODA

Though there is still close to a year to implement the Accessibility Standards for Customer Service, it will take time to examine your policies, procedures and practices and to make the necessary changes or to develop new ones. If you haven’t already begun this process, you should consider beginning this process now.

Conclusion

Your policies, procedures, practices and documentation should be in place by January, 2010 to meet the Accessibility Standards for Customer Service and the overall AODA requirements.

Accessibility reporting will be much easier if you have comprehensive, well designed documents and training.

Conclusion

You will also need to provide the required training for staff and third party providers within the next 11 months to meet your obligations under the Standard.

Any planning you will be undertaking during 2009 and beyond must take into account the requirements of this Standard.

A logical and well planned approach is critical to implementing the Standards.

Conclusion

Well-informed staff who have received thorough training will go a long way towards providing excellent customer service in your library. Remember, a complaint is a tremendous opportunity. If your staff listen and respond to a complaint from someone with a disability by addressing the customer’s concerns and sending your customer away happy, they will tell at least 10 other people about their experience. However, if you fail to resolve a complaint, they will talk with even MORE people about it!

Conclusion

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