Accessibility Policy Multi Year Plan

Accessibility Policy and Multi-Year Plan

I.    PURPOSE AND SCOPE 

The Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”) was passed in 2005. Under the Act, the Ontario government has enacted accessibility standards in the following areas:

• Customer Service
• Employment
• Information and communications
• Transportation
• Built environment

The purpose of this Accessibility Policy is to outline the commitment of CDW, and its subsidiaries, (“CDW”) to improving accessibility for our customers, clients and employees, and our strategy to identify, prevent and remove barriers to accessibility for persons with disabilities.  

This Accessibility Policy has been developed in accordance with the Integrated Accessibility Standards, Ontario Regulation 191/11 (the “IASR”) made pursuant to the AODA and other comparable legislation.

II.    STATEMENT OF COMMITMENT 

CDW is committed to treating all people in a way that allows them to maintain their dignity and independence. We believe in integration and equal opportunity. We are committed to meeting the accessibility needs of people with disabilities in a timely manner, and will do so by identifying, preventing and removing barriers to accessibility, and by meeting the accessibility requirements under the AODA.

III.    GENERAL REQUIREMENTS 

a.    Establishment of Accessibility Policies

CDW has established this Accessibility Policy and will make this document available in an accessible format upon request. CDW will also post this Accessibility Policy on its website.

CDW will update this Accessibility Policy at least every five (5) years to reflect progress and will consult with customers, employees and other stakeholders in the development and implementation of this Policy.

b.    Training 

CDW will provide accessible customer service training to all employees and volunteers, every person who participates in developing CDW’s policies, and others who deal with third parties on CDW’s behalf (collectively referred to as “staff”). Depending on a staff member’s role, they may also receive training on the AODA’s employment and/or information and communications standards.

Staff will complete AODA training within 30 days of being hired. Staff will also be trained when changes are made to our accessible customer service policies. 

Training will cover the following topics:

• An overview of Ontario’s accessibility laws, including the AODA, the IASR and the Ontario Human Rights Code as it pertains to individuals with disabilities;
• How to interact and communicate with people with various types of disabilities;
• How to interact with people with disabilities who use an assistive device or require the assistance of a service animal or support person;
• How to use the accessibility features that may help a person with a disability access goods, services, or facilities; and
• What to do if a person with a disability is having difficulty in accessing CDW’s goods, services and facilities.

Training will be provided in a way that best suits the needs of employees, volunteers and other staff members. Training will be provided to new employees on an ongoing basis.

CDW will take the following steps to ensure employees are provided with the training needed to meet Ontario’s accessibility laws:

• Assess duties and specific training needs of Ontario employees;
• Deliver training modules for all Ontario employees in accordance with the AODA’s customer service standard (the “Customer Service Training”);
• Deliver training modules on the accessibility requirements under the AODA, IASR and the Ontario Human Rights Code (the “IASR Training”) to appropriate employees; and
• Conduct the Customer Service Training and IASR Training on an ongoing basis for new Ontario employees and when changes are made to CDW’s accessibility policies, practices and procedures.

c.    Reporting Compliance 

CDW will file accessibility reports with Ontario’s Ministry of Economic Development, Employment and Infrastructure in accordance with the reporting deadlines set out under the AODA.

IV.    ACCESSIBILITY STANDARD FOR CUSTOMER SERVICE TRAINING GUIDE

a.    Purpose

The IASR’s customer service standard aims to give people with disabilities greater access to goods, services and facilities. This guide will help you do that. 

It will help you learn about:

• The IASR’s customer service standard and how it will help you welcome customers with disabilities
• How to serve customers with different kinds of disabilities
• How to help customers or visitors who use assistive devices, like wheelchairs or oxygen tanks
• Service animals, such as guide dogs, and how to welcome customers or visitors who use them
• What a support person does and how to help someone who is accompanied by a support person
• What to do when a customer with a disability needs assistance accessing CDW’s products and services.

The IASR’s customer service standard applies to all provincially regulated organizations in Ontario that provide goods, services or facilities. It affects the private, non-profit and public sectors.

How to communicate with people with different types of disabilities
There are many types and degrees of disability. Openly communicating and responding to your customers’ needs is the key to excellent customer service for all. If you’re not sure about the best approach, just politely ask a person with a disability how you can best communicate with them.

Here are a few tips for interacting with people who have various disabilities:

People with physical disabilities
Only some people with physical disabilities use a wheelchair. Someone with a spinal cord injury may use crutches while someone with severe arthritis or a heart condition may have difficulty walking longer distances.

• If you need to have a lengthy conversation with someone who uses a wheelchair or scooter, consider sitting so you can make eye contact at the same level.
• Don’t touch items or equipment, such as canes or wheelchairs, without permission.
• If you have permission to move a person’s wheelchair, don’t leave them in an awkward, dangerous or undignified position, such as facing a wall or in the path of opening doors.

People with vision loss
Vision loss can restrict someone’s ability to read, locate landmarks or see hazards. Some customers or visitors may use a guide dog or a white cane, while others may not.

• When you know someone has vision loss, don’t assume the individual can’t see you. Many people who have low vision still have some sight.
• Identify yourself when you approach and speak directly to them.
• Ask if they would like you to read any printed material out loud.
• When providing directions or instructions, be precise and descriptive.
• Offer your elbow to guide them if needed.

People who have hearing loss
People who have hearing loss may be deaf, deafened or hard of hearing. They may also be oral deaf – unable to hear but prefer to talk instead of using sign language. These terms are used to describe different levels of hearing and/or the way a person’s hearing was diminished or lost.

• Once a person has identified themselves as having hearing loss, make sure you are in a well-lit area where they can see your face and read your lips.
• As needed, attract the person’s attention before speaking. Try a gentle touch on the shoulder or wave of your hand.
• If a person uses a hearing aid, reduce background noise or move to a quieter area.
• If necessary, ask if another method of communicating would be easier (for example, using a pen and paper).

People who are deaf/blind
A person who is deaf/blind may have some degree of both hearing and vision loss. Many people who are deaf/blind will be accompanied by an intervener, a professional support person who helps with communication.

• Someone who is deafblind is likely to explain to you how to communicate with them, perhaps with an assistance card or a note.
• Speak directly to your customer, not to the intervener.

People with speech or language impairments
Cerebral palsy, hearing loss or other conditions may make it difficult for a person to pronounce words or may cause slurring. Some people who have severe difficulties may use a communication board or other assistive devices.

• Don’t assume that a person with a speech impairment also has another disability.
• Whenever possible, ask questions that can be answered with “yes” or a “no”.
• Be patient.  Don’t interrupt or finish the person’s sentences.

People who have learning disabilities
The term ‘learning disabilities’ refers to a variety of disorders. One example is dyslexia, which affects how a person takes in or retains information. This disability may become apparent when a person has difficulty reading material or understanding the information you are providing.

• Be patient – people with some learning disabilities may take a little longer to process information, understand and respond.
• Try to provide information in a way that takes into account the person’s disability. For example, some people with learning disabilities find written words difficult to understand, while others may have problems with numbers and math.

People who have intellectual/developmental disabilities
Developmental or intellectual disabilities, such as Down Syndrome, can limit a person’s ability to learn, communicate, do every day physical activities and live independently. You may not know that someone has this disability unless you are told.

• Don’t make assumptions about what a person can do.
• Use plain language.
• Provide one piece of information at a time.

People who have mental health disabilities
Mental health issues can affect a person’s ability to think clearly, concentrate or remember things. Mental health disability is a broad term for many disorders that can range in severity. For example, some customers may experience anxiety due to hallucinations, mood swings, phobias or panic disorder.

• If you sense or know that a person has a mental health disability be sure to treat them with the same respect and consideration you have for everyone else.
• Be confident, calm and reassuring.
• If a person appears to be in crisis, ask them to tell you the best way to help.

How to interact with people who use assistive devices
An assistive device is a tool, technology or other mechanism that enables a person with a disability to do everyday tasks and activities, such as moving, communication or lifting. Personal assistive devices can include things like wheelchairs, hearing aids, white canes or speech amplification devices.

• Don’t touch or handle any assistive device without permission.
• Don’t have assistive devices or equipment, such as canes and walkers, out of the person’s reach.
• Let customers and visitors know about accessible features in the immediate environment that are appropriate to their needs (e.g. Accessible washroom).

How to interact with a person who has a guide dog or other service animal
People with vision loss may use a guide dog, but there are other types of service animals as well. Hearing alert animals help people who are deaf, deafened, oral deaf, or hard of hearing. Other service animals are trained to alert an individual to an oncoming seizure.

Under the IASR customer service standard, service animals must be allowed to accompany visitors into the parts of CDW’s premises that are accessible to the public.

• Remember that a service animal is not a pet. It is a working animal. Avoid touching or addressing them.
• If you’re not sure if the animal is a pet or a service animal, ask the person.

How to serve a customer accompanied by a support person
Some people with disabilities may be accompanied by a support person, such as an intervener. A support person can be a personal support worker, a volunteer, a family member or a friend. A support person might help your customer or visitor with a variety of things from communicating, to helping with mobility, personal care or medical needs.

• If you’re not sure which person is the customer, take your lead from the person using or requesting your goods or services, or simply ask.
• Speak directly to your customer, not to their support person.

How to assist people with disabilities who need help accessing goods or services
It is critical that our customers be able to access our goods & services. If you notice that your customer is having difficulty accessing your goods or services, a good starting point is to simply ask “How can I help you?”. If you need to get them additional support, please contact Coworker Services. For external inquiries, our website directs a customer to contact Customer Support.

Notice of temporary disruption 
CDW will give notice of temporary disruptions to any of its services or facilities that may be used by persons with disabilities, including the reason(s) for the disruption and expected duration. This clearly posted notice will include information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if available. The notice will be clearly placed at the main entrances of our facilities and on our website, as well as where the disruption is taking place.  In the event of an unexpected disruption to services or facilities used by persons with disabilities, CDW will notify promptly notify the public.

Your customers are your best source for information about their needs. A solution can be simple, and they will likely appreciate your attention and consideration.

V.    INFORMATION AND COMMUNICATIONS STANDARD

a.    Feedback Process

Individuals who wish to provide feedback on the way CDW provides goods and services to people with disabilities may do so in person, by telephone, phone or email as follows: 

By Email: [email protected]
By Phone: +1.905.215.1609
Address: 
CDW, and its subsidiaries
1700-185 The West Mall, 
Etobicoke, ON M9C 5L5, Canada

Feedback forms will also be made available upon request in accessible formats. As needed, CDW will consult with the person making the request or providing the feedback as to the suitability of feedback mechanisms available and will provide alternative formats or communication supports for providing feedback.

Individuals who provide feedback can expect a response, if requested, within 10 business days.

b.    Accessible Formats and Communication Supports

CDW is committed to meeting the communication needs of people with disabilities. When requested, CDW will provide publicly available information and communications materials in accessible formats or with communication supports in a timely manner and at no additional cost to the individual. This includes publicly available information about our goods, services and facilities, as well as publicly available emergency information. 

CDW will consult with persons making requests for accessible formats to determine the suitability of a particular accessible format or communication support.

CDW will take the following steps to make sure all publicly available information is made accessible upon request:

• Review accessible formats and communication supports currently available at CDW;
• Review the current process in place for requesting accessible formats and communication supports; 
• As needed and where practical, update the current the process for requesting accessible formats and communication supports;
• As needed and where practical, create additional accessible formats and communication supports for publicly available information; 
• Develop a process for responding to requests for accessible formats and communication supports; and 
• Where practical, incorporate language in marketing materials and on CDW’s external website to advise that, in accordance with the AODA, accessible formats may be made available on request.

VI.    EMPLOYMENT STANDARD

CDW is committed to fair and equitable employment practices. In accordance with this commitment, CDW will take steps to identify existing barriers to accessibility and solicit employee feedback on how to minimize and eliminate those barriers.

a.    Recruitment, Assessment and Selection Process

CDW will take the following steps to notify its employees, the public and job applicants that CDW will accommodate individuals with disabilities during the recruitment, assessment and selection process:

• Conduct a review of all mechanisms for job postings in Ontario;
• Incorporate language into all job postings in Ontario notifying applicants that CDW will accommodate disabilities during the recruitment and selection process;
• Incorporate language into all notifications to applicants for interviews in Ontario that accommodation is available upon request;
• Ensure that any job applicants self-identifying as requiring accommodation in the recruitment process are consulted with to determine their individual accommodation needs;
• Review the current hiring process (tests, assessments, interview rooms) to ensure barriers may be removed or accessible features provided, upon request; and
• Review employment policies and procedures to ensure they reflect our commitment to employment practices which attract and retain employees with disabilities.

b.    Informing Employees of Accessible Formats and Communication Supports 

CDW will take the following steps to notify successful applicants and employees of our policies for accommodating employees with disabilities:

• Incorporate a section in each offer letter regarding CDW’s accessibility policies and provide information on where employees can access additional information; and
• Incorporate training and awareness of CDW’s accessibility policies into orientation procedures.

c.    Performance Management, Career Development and Advancement 

CDW will take the following steps to ensure the accessibility needs of employees with disabilities are considered if CDW is using performance management or career development processes: 

• Assess current performance review and career development processes to ensure accessibility features are incorporated and accessibility needs are considered;
• Review any individualized accommodation plans when performing assessments of performance or managing career development;
• Ensure promotion criteria, practices and processes consider individualized accommodation plans; and
• Ensure equal opportunities for employees with disabilities to undertake professional development, such as attending courses or seminars.

d.    Workplace Emergency Response Information 

CDW will provide individualized workplace emergency response information to employees who have a disability if the disability is such that the individualized information is necessary, and the employer is aware of the need for accommodation. 

CDW will take the following steps to ensure individualized workplace emergency response plans are in place: 

• Circulate an email to all employees in order to identify the availability of individualized emergency response information; 
• Develop and implement a process for consulting with employees to determine accommodation needs;
• Where accommodation needs are identified, work with employees requiring accommodation to develop an individualized workplace emergency response plan;
• Ensure consent is obtained from the employee to share information with those designated to assist the employee in the event of an emergency; and
• Review the individualized workplace emergency response plan and information when the employee moves to a different location in the workplace, when the employee’s accommodation needs or plans are reviewed and when CDW reviews its general emergency response policies.

VII.    MODIFICATION TO THIS OR OTHER POLICIES

CDW is committed to developing accessibility policies that respect and promote the dignity and independence of persons with disabilities. Therefore, no changes will be made to this Accessibility Policy before considering the impact on persons with disabilities. 

Any CDW policy that does not respect and promote the dignity and independence of persons with disabilities will be modified or removed.

For more information about CDW’s Accessibility Policy, contact Coworker Services.
By Email: [email protected]
By Phone: +1.905.215.1609

Last updated: OCTOBER 27, 2020