Frequently Asked Questions

Definitions of Key Terms

Q.  Tell me some keywords I should know about the AODA customer-service standard.

A.  Here are a few common terms, or keywords, that you’ll come across when talking about the AODA Standards for Customer Service:

• Customer-service standard or the standard:  Handy short names for the AODA Standards for Customer Service. 
• Designated public-sector organizations - for compliance purposes of the standard are The Legislative Assembly, and those appointed on the address of the Assembly, Ministries of the Government of Ontario, all Ontario municipalities, (whether they are small rural townships or major cities), all district school boards, hospitals, colleges, universities, and public transportation organizations, boards, commissions, authorities, and agencies of the Government of Ontario.
• Organizations include persons, businesses, or other organizations such as charities or government agencies.
• Provider refers to persons, businesses or other organizations that must comply with the standard.
• Staff is a term that includes employees, volunteers, agents, and others who provide services on behalf of a provider.
• The terms I, me, and you are understood here to refer to providers, organizations, and agencies as well as to individuals.
• Customers are people who receive goods or services.
• Other third parties in this instance any other persons or organizations other than the general public with whom you do business.  They can include, for example, consultants, manufacturers, wholesalers, suppliers of professional services, or government agencies.  The customer-service standard requires that you provide the same level of service to other third parties as the standard requires to the general public.
• Policies are the broad outlines of what you intend to do, including any rules for your staff.
• Procedures set out the individual steps of how you or members of your staff intend to achieve the objectives of your policies. 
• Practices are what you and members of your staff actually do, as opposed to what you intend to do, with regard to providing your goods or services on a day-to-day basis.

Q.  I understand what the principles of the standard mean, but what does it mean to make “reasonable efforts” to conform to those principles?

A.  There are as many “reasonable efforts” to meet the principles as there are ways to create accessibility.  You can create accessibility by changing a procedure, installing an assistive device, or simply by taking individual needs into account when you offer services.  Each business or organization needs to determine how to create accessibility based on its services, the type of business or organization, its resources and its options available at a given time.  There’s nothing in the standard that says an organization’s measure for accessibility has to be set in stone; indeed, your business or organization may very well find that one method of providing accessibility works well at one time, but another works better at another point in time.  You may also find a customer-service measure that you know will work very well for people you serve with disabilities, but you’re not in a position to provide that measure—an assistive device, for example—at the present time.  In that case, you should make plans, such as a timetable, for implementing that new measure in the future, and use other accessible means of providing the same service in the meantime.

Contracting Outside Services 

Q.  My business contracts out its billing services to another company outside Ontario.  Does the customer-service standard apply to them?

A.  Yes.  You must make sure that the company to which you contract out your services to also meets your obligations under the customer-service standard.  If any company provides service to Ontario, it is bound by the customer-service standard, even if it isn’t located here.

Policies on Service Animals and Support Persons

Q.  What details should I include in my policy on service animals and support persons?

A.  Your policy on service animals and support persons should include the following:

• When you may exclude service animals because of another law, if applicable 
• If you have a policy on pets—for example, a prohibition against pets or a policy that allows pets for an additional deposit or fee—an additional clause that clearly recognizes the distinction between a pet and a service animal, which is not a pet 
• Alternative measures that allow a person with a disability to access your goods or services in situations where a service animal is excluded by another law 
• If you charge admission, the amount you’ll charge for support persons 
• If and when it may be necessary to require a person with a disability to be accompanied by a support person in order to protect the health and safety of the person with a disability, or that of others on the premises. 

Policies on Temporary Disruptions to Service

Q.  What happens if things go wrong, and a person with a disability cannot access assistive measures?   Do I have to document all that, too?

A.  Yes.  You have to make a policy on the steps your organization will take in connection with a temporary disruption, whether planned or unexpected, to the facilities or services that people with disabilities usually use to access your goods or services.  Your policy should include the following:

• Under what circumstances you will provide notice about a temporary disruption, and where you will post that notice;
• A commitment to provide in the disruption notice information about the reason for the disruption and how long you expect it to last;
• What alternative facilities or services, if any, you will make available during the temporary disruption so that you may continue providing service to people with disabilities.

Policies on Training of Staff 

Q.  You said I have to train my staff in providing accessible customer service.  Do I have to write up a policy on that training?

A.  Yes, you do.  You should document your policy on providing training in accessible customer service.  Your written policy should include:

• A summary of the contents of the training, and
• Details of when you will provide that training.

Policies on a Feedback Process

Q.  You said that I need to establish a feedback process dealing with how I provide goods and services to people with disabilities.  What needs to be in that policy when I write it up?

A.  Your written feedback policy needs to include descriptions of:

• How you will accept feedback
• What actions you will take if you receive a complaint.

For All Businesses:  Ongoing Requirements for Compliance

Q.  Once all of my documentation is ready.  What else do I have to do from day to day to stay in compliance with the standard?

A.  There are a number of steps that you should integrate into the way you provide customer service from day to day in order to stay in compliance with the standard.  They are discussed in the questions that follow.

Ongoing Requirements for Service Animals and Support Persons

Q.  How can our business make the public areas of our premises welcoming for people with disabilities and their service animals or support persons?

A.  You are required under the customer-service standard to welcome service animals and support persons.  The way to do that is by doing the following:

• Allow guide dogs and other service animals to accompany people with disabilities in those areas of your premises that are open to the public or other third parties, except where prohibited by another law.
• In situations where guide dogs or other service animals are excluded by law, provide alternative ways for people with disabilities to access your goods and services.
• Permit people with disabilities to bring their support persons with them in those parts of your premises that are open to the public or to other third parties.
• If you charge admission, provide notice in advance about what admission fee you’ll charge to support persons.

Ongoing Requirements for Temporary Disruptions in Services

Q.  What’s the right approach to letting people know about temporary disruptions to services?

A.  You are required under the customer-service standard to provide notice to the public anytime there is a temporary disruption, planned or not, to facilities or services usually used by people with disabilities.

• Include information in your notice about the reasons for the disruption, how long you expect it to last, and whatever alternative facilities or services, if any, that you may offer in the meantime.
• Put up the notice in an obvious place on your premises, post it on your website if you have one, or post it by another method that’s reasonable under the circumstances.

Ongoing Requirements for Providing Training

Q.  Do all my staff have to be trained in providing customer service to people with disabilities, or just some of them? 

• You should train everyone on your staff that provides goods and services to the public or to other third parties about providing customer service to people with disabilities.
• You should also make sure that everyone involved in developing your policies, procedures, and practices on customer service receives the same training as people who deal with the public or with other third parties.
• Provide ongoing training, so that everyone on your staff that’s involved in providing goods or services to people with disabilities is kept up to date on any changes that may come down the line.

Ongoing Requirements for Communicating with People who have a Disability

Q.  I don’t have much experience in communicating with people who have a disability.  What’s the right way to do it?

A.  The customer-service standard requires you to communicate with people who have a disability in a manner that takes into account each person’s disability.  Broadly speaking, there are three main ways to make communications more accessible for people with disabilities:

• Making the original communication more accessible
• Changing the usual method of communication
• Using assistive devices or services

To make communication more accessible, it is often useful to offer the same piece of information in a variety of different ways, such as in person, by telephone, online, through print signs, handouts, and brochures, and through television or radio advertisements.  As examples, you could also offer:

• Large print for people who have low vision;
• Audio formats such as cassettes or digital audio files;
• Braille used by some people who are blind or deaf-blind;
• Videos that people with some learning disabilities might find useful;
• Loudspeakers, amplifiers, or closed captioning on screens to assist those who are hard of hearing;
• TTY devices to assist those who are Deaf, deafened, or hard of hearing;
• Easy-read, simplified summaries of materials for people who have trouble reading
• Interpreters skilled in helping people with intellectual or learning disabilities understand lengthy or complicated information

Remember, too, that changing methods of communication to make it more accessible doesn’t have to be complicated.  For example, in the case of somebody who is Deaf or hard of hearing, you might be able to communicate information very effectively with a pen and paper.  It’s important to remember that communicating effectively all comes down to taking each individual’s needs and circumstances into consideration.  Don’t make assumptions about the most effective way to communicate with someone who has a given disability.  Whenever possible, the best way to figure out how to communicate with a person who has a disability is to simply ask them directly.   Don’t be afraid to ask. 

Ongoing Requirements for Providing Documentation

Q.  Are all organizations subject to ongoing requirements to provide documentation?

A.  No.  The ongoing requirement to provide documentation under the customer-service standard applies only to providers with 20 or more employees, as well as designated public-sector organizations as previously defined.

Q.  What must I do to meet the ongoing documentation requirements under the standard?

A.  You must:

• Let your customers know that the documents required under the standard are available upon request.
• Post the notice of your documents’ availability in an easily seen place on your premises, by posting it on your website, or by some other method that’s reasonable under the circumstances.
• Provide copies of your documents to anyone who asks for them.
• If the person to whom you are providing your documents is a person with a disability, provide the documents in a format that takes into account that person’s disability.

More to Come from the AODA

Q.  Is customer service the only area governed by a standard under the AODA

A.  No, customer service will not be the only area governed by an AODA standard.  AODA standards are being developed in other areas.  They include:

• Employment.  The forthcoming Employment Accessibility Standard (EAS) is intended to facilitate accessible employment of Ontarians with disabilities.  Proposed standards deal with employer-employee relationships and will cover such areas as recruitment, hiring, retention policies, return-to-work procedures, and other practices. 
• Buildings and other structures.  This standard will cover access to buildings and outdoor spaces.  Among the issues that will be covered in this standard are counter height, aisle width, door width, parking, pedestrian signals, and signage.
• Information and Communications.  These standards now being developed will address the removal of barriers to information.  They will cover the manner in which information is made available, such as in person, in print, through a website, or by other means.

• Public Transportation.  Since many people rely on public transportation for commuting to work and getting around, proposed standards are intended to make it more accessible.

These additional standards, which are also part of the AODA, but are separate standards besides the customer-service standard, are still being developed by a series of proposals being studied by committees.  They have not yet become law.  The Government of Ontario will make a public announcement when legislation is introduced, passed, and signed into law.  An effective date for the new standards will be announced at that time.  For now, however, providers will need to be ready for when the customer-service standard comes into effect for private-sector organizations.  Just to recap, that will take place on January 1, 2012.