AODA Multi-Year Accessibility Plan

Background

The Accessibility for Ontarians With Disabilities Act ("AODA") contains accessibility standards in a variety of areas, including Customer Service, Information and Communications, Employment, Transportation and Design of Public Spaces.  On July 1, 2011, the Integrated Accessibility Standards (Ontario Regulation 191/11) came into force. The regulation establishes standards to address barriers that persons with disabilities face in the areas of employment, information and communications, transportation and built environment. As a large, private sector organization, The Children's Place has obligations under the Integrated Accessibility Standards that come into effect on a rolling basis.

The AODA and its standards are not a replacement or substitution for the requirements of the Human Rights Code (Ontario).

About this Document

The Children's Place Multi-Year Accessibility Plan (the "Plan") is a road map for our path to increased accessibility as a company. The goal of the Plan is to provide the action steps that bring life to The Children's Place Integrated Accessibility Standards Policy and Commitment Statement.

This document describes (1) how The Children's Place will meet accessibility requirements within the Integrated Accessibility Standards' mandatory timelines, (2) how The Children's Place will address current accessibility barriers in our organization, and (3) how The Children's Place will identify and remove future barriers.

The document identifies the different standards applicable to The Children's Place and the dates on which compliance with each standard is required. The Children's Place is committed to reviewing the Plan at least once every five years. The Children's Place will prepare and file an annual status report on the progress of measures taken to implement the strategy outlined in our Plan and post the status report on our website. Status reports will be made available in an accessible format upon request.

General Requirements under the Integrated Accessibility Standards:

Detailed Standard Implementation Date Actions
Accessibility Policy - s. 3(1) By January 1, 2014

The Children's Place has adopted an Integrated Accessibility Standards Policy, and a copy is available upon request.

Additionally, upon request, The Children's Place will provide or arrange for accessible formats and communication supports for the Policy for persons with disabilities in a timely manner that takes into account each person's accessibility needs due to disability and (if applicable) at a cost that is no more than the regular cost charged to other persons.

The Children's Place will consult with the person making the request for an accessible format or communication support for the Policy when determining the suitability of an accessible format or communication support.

Statement of Commitment - s. 3(2) By January 1, 2014

The Children's Place has adopted a Statement of Commitment, and a copy is available upon request.

Additionally, upon request, The Children's Place will provide or arrange for accessible formats and communication supports for the Statement of Commitment for persons with disabilities in a timely manner that takes into account each person's accessibility needs due to disability and (if applicable) at a cost that is no more than the regular cost charged to other persons.

The Children's Place will consult with the person making the request for an accessible format or communication support for the Statement of Commitment when determining the suitability of an accessible format or communication support.
Multi-year Accessibility Plan - s. 4 By January 1, 2014

The Children's Place has developed this the Multi-year Accessibility Plan (the "Plan"), with input from applicable departments on an as needed basis.  The Plan has been posted on the website in an accessible format that conforms with, at minimum, WCAG 2.0 Level A. 1

The Plan will be reviewed and updated at least once every five years.

Additionally, upon request, The Children's Place will provide or arrange for accessible formats and communication supports for the Plan for persons with disabilities in a timely manner that takes into account each person's accessibility needs due to disability and (if applicable) at a cost that is no more than the regular cost charged to other persons.

The Children's Place will consult with the person making the request for an accessible format or communication support for the Plan when determining the suitability of an accessible format or communication support.

Finally, prior to the Design of Public Spaces Requirements come into effect under the Integrated Accessibility Standards, The Children's Place will ensure that its Plan is updated to include the items required under the Maintenance Standard (s. 80.44).

Self-service kiosks s. 6 By January 1, 2014

The Children's Place will have regard to the accessibility for persons with disabilities should it design, procure or acquire self-service kiosks by considering what accessibility features could be built into kiosks to best meet the needs of our customers and clients.

Training - s. 7 By January 1, 2015

The Children's Place will provide training to:

  • all of its associates and volunteers,
  • all persons who participate in developing The Children's Place policies, and
  • all other persons who provide goods, services or facilities on behalf of The Children's Place
on the requirements of the accessibility standards referred to in the Integrated Accessibility Standards and continue to provide training on the Human Rights Code (Ontario) as it pertains to persons with disabilities.

Training will be provided as soon as practicable. Training will also be included as part of Orientation for all new hires.

The training provided will take into consideration and be appropriate to the duties of those receiving the training.

The Children's Place will provide training, on an ongoing basis, with respect to changes made to the Integrated Accessibility Policy and Commitment Statement.

Records of the training provided will be maintained and will include: (i) the dates on which training was provided and (ii) the number of individuals to whom training is provided.

1 Note: The Children's Place will, by 2021, ensure that the Multi-year Accessibility Form is posted in a format that conforms with WCAG 2.0 at Level AA, except with respect to success criteria 1.2.4 and 1.2.5 or where meeting the requirement is not practicable.

Information and Communication Standards:

Detailed Standard Implementation Date Actions
Accessible websites & web content - s. 14(4) By January 1, 2014

The Children's Place will ensure that new internet websites, including web content on those sites (that The Children's Place controls directly or through a contractual relationship that allows The Children's Place to modify the content), conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 at Level A.

Feedback - s. 11 By January 1, 2015

The Children's Place will ensure that its processes for receiving and responding to feedback are accessible to persons with disabilities by, upon request, providing or arranging for the provision of accessible formats and communication supports for persons with disabilities in a timely manner that takes into account each person's accessibility needs due to disability and (if applicable) at a cost that is no more than the regular cost charged to other persons.

The Children's Place will consult with the person making the request for an accessible format or communication support when determining the suitability of an accessible format or communication support.

The Children's Place will continue to advise the public about the availability of accessible formats and communication supports with respect to its feedback processes through a notification on the website.

The processes that The Children's Place develops to meet its feedback obligations under the Integrated Accessibility Standards will be complementary to, and will not detract from, the feedback processes The Children's Place has developed in accordance with the Customer Service Standards.

Accessible formats and communication supports - s. 12 By January 1, 2016

Upon request, The Children's Place will provide or arrange for accessible formats and communication supports for persons with disabilities in a timely manner that takes into account each person's accessibility needs due to disability and at a cost that is no more than the regular cost charged to other persons.

The Children's Place will consult with the person making the request for accessible formats or communication support when determining the suitability of an accessible format or communication support.

The Children's Place will advise the public about the availability of accessible formats and communication supports through a notification on our company website.

Accessible websites and web content By January 1, 2021

The Children's Place will ensure that its websites, including web content on those sites (that The Children's Place controls directly or through a contractual relationship that allows The Children's Place to modify the content), conform with the WCAG 2.0 at Level AA, except with respect to success criteria 1.2.4 (captions (live)) and 1.2.5 (pre-recorded audio descriptions) or where meeting the requirement is not practicable.

Employment Standards:

Detailed Standard Implementation Date Actions
Emergency Procedure, Plans or Public Safety Information - s. 13 By January 1, 2012

The Children's Place has emergency response procedures, plans and public safety information that it makes available to the public.

Upon request, The Children's Place provides or arranges for accessible formats and communication supports for persons with disabilities in a timely manner that takes into account each person's accessibility needs due to disability and (if applicable) at a cost that is no more than the regular cost charged to other persons.

The Children's Place consults with the person making the request for an accessible format or communication support for the procedures, plans and public safety information when determining the suitability of an accessible format or communication support.

Individualized Workplace Response Information - s. 27 By January 1, 2012

The Children's Place provides individualized workplace emergency response information to associates with disabilities where the disability is such that individualized information is necessary and The Children's Place is aware of the need for accommodation.

In the event that an associate who receives individualized workplace emergency response information requires assistance, The Children's Place designates a person to provide assistance and, with the associate's consent, The Children's Place provides the workplace emergency response information to the person.

The Children's Place provides workplace emergency response information as soon as practicable after learning of the need for accommodation due to an associate's disability.

The Children's Place reviews individualized workplace emergency response information, at minimum, whenever:

  • the associate moves to a different location within The Children's Place,
  • the associate's overall accommodation needs or plans are reviewed, or
  • The Children's Place reviews its general emergency response policies.

Recruitment - ss. 22 -24 By January 1, 2016

In our recruitment processes, The Children's Place will advise our associates and the public about the availability of accommodation for applicants with disabilities.

The Children's Place will notify job applicants, when they are individually selected to participate further in an assessment or selection process, that accommodations are available upon request in relation to the materials or processes to be used.

If a selected job applicant requests accommodation, The Children's Place will consult with the individual and provide or arrange for the provision of suitable accommodation that takes into account the applicant's disability-related needs.

When making offers of employment, The Children's Place will notify successful applicants of our policies for accommodating associates with disabilities.

Information for associates regarding supports - s. 25 & 26 By January 1, 2016

The Children's Place will notify our associates of The Children's Place's policies (and any updates to those policies) for supporting associates with disabilities, including (at minimum) our policies regarding the provision of job accommodations that take into account an associate's accessibility needs due to disability.

This information will be provided to new hires as soon as practicable after they commence employment.

If an associate with a disability asks for information in an accessible format or to receive communication supports, The Children's Place will consult with the associate to provide, or arrange for the provision of, accessible formats and communication supports for information that the associate needs to perform his/her job, as well as information that is generally available to other associates.

In determining the suitability of an accessible format or communication support, The Children's Place will consult with the associate making the request.

Documented Individual Accommodation Plans - s. 28 By January 1, 2016

The Children's Place will develop and maintain a written process for the development of documented individual accommodation plans for associates with disabilities.

The process for the development of documented individual accommodation plans will include the following elements:
1. The manner in which an associate requesting accommodation can participate in the development of the individual accommodation plan.
2. The means by which the associate is assessed on an individual basis.
3. The manner in which The Children's Place can request an evaluation by an outside medical or other expert, at The Children's Place' expense, to assist The Children's Place in determining if accommodation can be achieved and, if so, how accommodation can be achieved.
4. The manner in which the associate can request the participation of a representative from the workplace in the development of the accommodation plan.
5. The steps taken to protect the privacy of the associate's personal information.
6. The frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done.
7. If an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the associate.
8. The means of providing the individual accommodation plan in a format that takes into account the associate's accessibility needs due to disability.

If requested, information regarding accessible formats and communication supports provided will also be included in individual accommodation plans, in accordance with the Accessible Formats and Communication Supports for Employees Standard (s. 26).

Additionally, the plans will include individualized workplace emergency response information (where required) and will identify any other accommodation that is to be provided, in accordance with the Workplace Emergency Response Information Standard (s. 27).

Finally, individual accommodation plans will identify any other accommodation that is to be provided.

Return to Work Process - s. 29 By January 1, 2016

The Children's Place will develop and maintain a documented return to work process for its associates who have been absent from work due to a disability and who require disability-related accommodations in order to return to work.

The return to work process will, as part of the process, outline the steps that The Children's Place will take to facilitate the return to work and will include documented individual accommodation plans.

The Children's Place notes that this return to work process will not replace or override any other return to work process created by or under any other statute (for example, the Workplace Safety Insurance Act, 1997).

Performance Management (s. 30), Career Development and Advancement (s. 31), and Redeployment (s. 32) By January 1, 2016

The Children's Place will take into account the accessibility needs of associates with disabilities, as well as individual accommodation plans, when conducting performance management, providing career development and advancement to associates, or when redeploying associates.

Design of Public Spaces:

Detailed Standard Implementation Date Actions
Outdoor Public Use Eating Areas - ss. 80.16 and 80.17 By January 1, 2017 The Children's Place will adhere to the general obligations and technical requirements of the Integrated Accessibility Standards when we construct new or redevelop outdoor public use eating areas that we intend to maintain.
Exterior Paths of Travel - ss. 80.21 - 80.31 By January 1, 2017

The Children's Place will adhere to the general obligations and technical requirements of the Integrated Accessibility Standards when we construct new or redevelop exterior paths of travel that we intend to maintain (including ramps, stairs, curb ramps, depressed curbs, pedestrian signals and rest areas) that are intended to serve a functional purpose, subject to applicable exceptions and limitations as contemplated by the Integrated Accessibility Standards.

Accessible Parking - ss. 80.32 - 80.39 By January 1, 2017

The Children's Place will adhere to the general obligations and technical requirements of the Integrated Accessibility Standards when we construct new or redevelop off-street parking facilities that we intend to maintain, subject to applicable exceptions and limitations as contemplated by the Integrated Accessibility Standards.

Obtaining Services - ss. 80.40 - 80.43 By January 1, 2017

The Children's Place will adhere to the general obligations and technical requirements of the Integrated Accessibility Standards when we construct new or redevelop service counters, fixed queuing guides and waiting areas.

Maintenance - s. 80.44 By January 1, 2017

Prior to the Design of Public Spaces Requirements come into effect under the Integrated Accessibility Standards, The Children's Place will ensure that its multi-year accessibility plan is updated to include:

1. Procedures for preventative and emergency maintenance of the accessible elements in The Children's Place' public spaces that are governed by the Integrated Accessibility Standards.

2. Procedures for dealing with temporary disruptions when accessible elements in The Children's Place's public spaces that are governed by the Integrated Accessibility Standards are not in working order.

Full Accessibility:

Detailed Standard Implementation Date Actions
By January 1, 2025

This is the date by which the development, implementation and enforcement of accessibility standards is contemplated by the AODA in order to achieve accessibility for Ontarians with disabilities with respect to goods, services, facilities, accommodation, employment, buildings, structures and premises. The Children's Place will ensure compliance with its obligations under the AODA and its regulations by this date.