This policy reflects the July 1, 2018 changes to the regulations under Ontario’s Health Protection and Promotion Act.
Prodemnity is committed to meet its current and ongoing obligations under the Ontario Human Rights Code respecting non-discrimination. This document establishes programs and procedures for developing, implementing, and enforcing accessibility standards included in the Integrated Accessibility Standards Regulation under the Accessibility for Ontarians with Disabilities Act, 2005, to achieve accessibility for persons with disabilities with respect to the goods and services provided by Pro-Demnity.
The Provision of Goods and Services to persons with Disabilities
Pro-Demnity Insurance Company will make every reasonable effort to ensure that its policies, practices, and procedures are consistent with the principles of dignity, independence, integration, and equal opportunity by:
- Ensuring that all customers receive the same value and quality of service;
- Allowing customers with disabilities to do things in their own way, at their own pace when accessing goods and services, as long as this does not present a health and safety risk and meets our business objectives;
- Using alternative methods when possible, to ensure that customers with disabilities have access to the same services, in the same place and a similar manner;
- Taking into account individual accommodation needs when providing goods and services; and
- Communicating in a manner that considers the customer’s disability.
The Use of Assistive Devices
Persons with disabilities may use their own assistive devices as required when accessing goods or services provided by the company.
In cases where the assistive device presents a health and safety concern or where accessibility might be an issue, other reasonable measures will be used to ensure the access of goods and services, up to the point of undue hardship. For example, if elevators are not in a working condition and a customer requires assistive devices for mobility, service will be provided in a location that meets the needs of the customer.
Guide Dogs and Service Animals
A customer with a disability who is accompanied by a guide dog or service animal will be allowed access to premises that are open to the public unless otherwise excluded by law. “No pet” policies do not apply to guide dogs or service animals.
Staff may respectfully ask if an animal is a service animal and will not ask the nature of the person’s disability or purpose of the animal. The customer who is accompanied by a guide dog or service animal is responsible for the care and control of the animal at all times.
In very exceptional circumstances where a service animal becomes out of control, causing a clear disruption or a threat to the health and safety of others, and the animal’s behaviour is not corrected by the owner, employees may respectfully request that the person with a disability remove their service animal from the premises.
Company will offer alternative methods to enable the person with a disability to access goods and services, when possible. For example, the company might accommodate a customer’s disability by securing the animal in a safe location and offering the assistance of an employee to facilitate the delivery of goods and services.
If there is a conflict between a provision of Dog Owners’ Liability Act, 2005 or of a regulation under this or any other act relating to banned breeds (such as pit bulls) and a provision of a by-law passed by a municipality relating to these breeds, the provision that is more restrictive in relation to controls or bans on these breeds prevails. Staff will respectfully explain that the service animal must be removed from the public area due to a municipal by-law and make alternate arrangements or provide the service outside the public area.
Allergies and Other Health and Safety Concerns
If a health and safety concern present itself, for example, in the form of a severe allergy to the animal, Pro-Demnity Insurance Company will make all reasonable efforts to meet the needs of all individuals. According to the company’s obligations under the Human Rights Code and the Occupational Health and Safety Act, each customer’s accommodation needs will be considered on a case-by-case basis, up to the point of undue hardship.
The Use of Support Persons
If a customer with a disability is accompanied by a support person, Pro-Demnity Insurance Company will ensure that both persons may enter the premises together and that the customer is not prevented from having access to the support person.
In situations where confidential information might be discussed, consent will be obtained from the customer before any potentially confidential information is mentioned.
Notice of Disruptions in Service
Service disruptions may occur for reasons that may or may not be within the control or knowledge of Pro-Demnity Insurance Company. In the event of any temporary disruptions to facilities or services that customers with disabilities rely on to access or use goods or services, reasonable efforts will be made to provide advance notice. The company may post notification in a conspicuous place, on the company website, or by contacting/communicating with customers directly.
The following information will be included in the notification:
- Goods or services that are disrupted or unavailable;
- Reason for the disruption;
- Anticipated duration; and
- A description of alternative services or options.
In some circumstances, such as in the situation of unplanned temporary disruptions, advance notice may not be possible.
Pro-Demnity Insurance Company shall provide customers with the opportunity to provide feedback on the service provided to customers with disabilities. Feedback forms, along with alternate methods of providing feedback verbally (in person or by telephone) or written (handwritten, delivered, website, or e-mail), will be available upon request.
Customers can submit feedback to:
Manager Operational Execution Phone: +1 416 386-1770, Address: 160 Bloor St. East, Suite 1001, Toronto, ON M4W 1B9 or Email: email@example.com
Customers may also provide feedback by completing an onsite or online customer feedback form or by verbally advising any Pro-Demnity employee.
Customers who provide formal feedback will receive acknowledgement of their feedback, along with any resulting actions based on concerns or complaints that were submitted.
Training will be provided to every employee of or a volunteer with Pro-Demnity Insurance Company.
Regardless of the format, training will cover the following:
- A review of the purpose of the Accessibility for Ontarians with Disabilities Act, 2005;
- A review of the requirements of the customer service standards;
- Instructions on how to interact and communicate with people with various types of disabilities;
- Instructions on how to interact with people with disabilities who:
- Use assistive devices;
- Require the assistance of a guide dog or other service animal; or
- Require the use of a support person
- Instructions on what to do if a person with a disability is having difficulty accessing our services; and
- Policies, procedures, and practices of the company pertaining to providing accessible customer service to customers with disabilities.
Assistive device: A technical aid, communication device, or other instruments that are used to maintain or improve the functional abilities of people with disabilities. Personal assistive devices are typically devices that customers bring with them, such as a wheelchair, walker, or a personal oxygen tank, and that might assist in hearing, seeing, communicating, moving, breathing, remembering, or reading.
Disability: As defined by the Accessibility for Ontarians with Disabilities Act, 2005, and the Ontario Human Rights Code, refers to:
- 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 coordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or a wheelchair or other remedial appliance or device;
- A condition of mental impairment or a developmental disability;
- A learning disability, or dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
- A mental disorder; or
- An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.
Guide dog: A highly-trained working dog that has been trained at one of the facilities listed in Ontario Regulation 58 under the Blind Persons’ Rights Act, to provide mobility, safety, and increased independence for people who are blind.
Service animal: A service animal for a person with a disability if:
- The animal can be readily identified as one that is being used by the person for reasons relating to the person’s disability, as a result of visual indicators such as the vest or harness worn by the animal; or
- The person provides documentation from a member of one of the following regulated health professional colleges confirming that the person requires the animal for reasons relating to the disability:
o College of Audiologists and Speech-Language Pathologists of Ontario;
o College of Chiropractors of Ontario;
o College of Nurses of Ontario;
o College of Occupational Therapists of Ontario;
o College of Optometrists of Ontario;
o College of Physicians and Surgeons of Ontario;
o College of Physiotherapists of Ontario;
o College of Psychologists of Ontario; or
o College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario.
Support person: Concerning a person with a disability, another person who accompanies them to help with communication, mobility, personal care, medical needs, or access to goods and services.
The policy and its related procedures will be reviewed as required in the event of legislative changes or changes to company procedures. This policy will next be reviewed in March 2022.