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Accommodations Policy

Statement of Commitment

OREA is committed to providing an environment that is inclusive and that is free of barriers based on age, race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex (including pregnancy), sexual orientation, gender identity, gender expression, marital status, family status, and disability. OREA commits to provide accommodation for needs related to the grounds of the Human Rights Code (Ontario) (the "Code"), unless to do so would cause undue hardship to OREA, as defined by the Ontario Human Rights Commission’s Policy on disability and the duty to accommodate.

Accommodation will be provided in accordance with the principles of dignity, individualization, and inclusion. OREA will work cooperatively, and in a spirit of respect, with all partners in the accommodation process.

OREA will make efforts to build or adapt its services to accommodate staff, members and other stakeholders with Code-related needs in a way that promotes their inclusion and full participation. Preventing and removing barriers means all stakeholders should be able to access their environment and face the same duties and requirements with dignity and without impediment.

Objectives of the Policy

The purpose of this Accommodation Policy is to:

  • Ensure that all staff, members, and other stakeholders of OREA are aware of their rights and responsibilities under the Code with respect to accommodation.
  • Set out in writing OREA’s procedures for accommodation and the responsibilities of each of the parties to the accommodation process.

Training

We are committed to training all OREA staff and volunteers in Ontario’s accessibility standards and aspects of the Ontario Human Rights Code that relate to persons with disabilities.

Training of our employees and volunteers on accessibility relates to their specific roles.

Training includes:

  • purpose of the Accessibility for Ontarians with Disabilities Act, 2005
  • our policies related to Accessibility for Ontarians with Disabilities Act, 2005
  • 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 a support person
  • how to use the equipment or devices available on-site or otherwise that may help with providing services or facilities to people with disabilities
  • what to do if a person with a disability is having difficulty in accessing OREA’s services or facilities.

We train every person as soon as practicable after being hired and provide training in respect of any changes to the policies. We maintain records of the training provided including the dates on which the training was provided.

Application of the Policy

This Accommodation Policy and procedure applies to all employees, including full-time, part-time, temporary, casual and contract staff, as well as people who work to gain experience or for benefits, such as volunteers, co-op students, interns and apprentices. It also applies to people who are applying for employment with the organization.

It applies at all stages and to all aspects of the employment relationship, including recruitment and selection, promotions and transfers, and conditions of work such as hours of work and leaves of absence.

All new and existing employees will be provided with a copy of this accommodation policy and procedure. All job applicants who are selected for an interview will be notified of the accommodation policy and procedure before the interview.

Requests for Accommodation:

Accommodation requests should, whenever possible, be made in writing. The accommodation request should indicate:

  • The Code ground the accommodation is being requested on
  • The reason accommodation is required, including enough information to confirm the existence of a need for accommodation
  • The specific needs related to the Code ground.

All accommodation requests will be taken seriously. No person will be penalized for making an accommodation request.

Accommodation requests will be dealt with promptly. Where necessary, interim accommodation will be provided while long-term solutions are developed.

The Accommodation Process

At the heart of the accommodation process is the responsibility, shared by all parties, to engage in meaningful dialogue about accommodation, and to seek out expert assistance as needed. All parties will work together cooperatively, engage in the process, share information and avail themselves of potential accommodation solutions to develop an accommodation plan.

There is no set formula for accommodation. Each individual's needs are unique and will be considered when an accommodation request is made.

Providing Information

OREA may require further information related to the accommodation request, in the following circumstances:

  • Where the accommodation request does not clearly indicate a need related to a Code ground
  • Where further information related to the individual’s limitations or restrictions is required to determine an appropriate accommodation
  • Where there is a demonstrable objective reason to question the legitimacy of the request for accommodation

Where expert assistance is necessary to identify accommodation needs or potential solutions, the individual seeking accommodation is required to cooperate in obtaining that expert advice.

Failure to respond to requests for further information may delay the provision of accommodation.

OREA Human Resources Department will maintain information related to:

  • The accommodation request
  • Any documentation provided by the accommodation seeker or by experts
  • Notes from any meetings
  • Any accommodation alternatives explored
  • Any accommodations provided.

This information will be maintained in a secure location and will be shared only with those persons who need the information.

Privacy and Confidentiality

OREA will maintain the confidentiality of information related to an accommodation request, and will only disclose this information with the consent of the indivudal seeking accommodation.

Accommodation Plan

The Accommodation Plan, when agreed on, will be put in writing, and signed by the individual requesting accommodation, the Manager and the Human Resource Manager. It may include:

  • A statement of the accommodation seeker’s relevant limitations and needs, including any needed assessments and information from experts or specialists, bearing in mind the need to maintain the confidentiality of medical reports
  • Arrangements for needed assessments by experts or professionals
  • Identification of the most appropriate accommodation short of undue hardship
  • A statement of annual goals, and specific steps to be taken to meet them
  • Clear timelines for providing the accommodation
  • Criteria for determining the success of the accommodation plan, together with a process for reviewing and re-assesing the accommodation plan as needed
  • An accountability mechanism.

Monitoring Accommodations

The manager and the person receiving accommodation will monitor the success of the Accommodation Plan, and promptly address any deficiencies or any relevant changes in the workplace or the employee’s needs.

Undue Hardship

Accommodation will be provided to the point of undue hardship. A determination regarding undue hardship will be based on an assessment of costs, outside sources of funding, if any, and, health and safety requirements, if any. It will be based on objective evidence.

A determination that an accommodation will create undue hardship may only be made by the Chief Executive Officer.

Where a determination is made that an accommodation would create undue hardship, the individual requesting accommodation will be given written notice, including the reasons for the decision, and the objective evidence relied upon.

Where a determination has been made that an accommodation would cause undue hardship, OREA will proceed to implement the next best accommodation short of undue hardship or will consider phasing in the requested accommodation.

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