Accessibility

Toronto Seniors Housing Corporation (TSHC) Accessibility Policy

Policy Sponsor: Director, Strategy and Business Management

Approver: Board of Directors

Initial Approval Date: May 17, 2022

Last Revision Date: 2024

Effective Date: June 1, 2022

Organizational Statement of Commitment

Toronto Seniors Housing Corporation (TSHC) is committed to providing an inclusive environment to tenants and employees with disabilities in accordance with the core principles of accommodation, dignity, independence, integration and equal opportunity outlined in the Human Rights Code, R.S.O. 1990, c.H.19 and the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c.11, and the complimentary legislation of the Employment Standards Act, 2000, S.O. 2000, c.41, the Ontario Building Code, O. Reg. 332/12, and the Integrated Accessibility Standards, O. Reg.191/11.

Policy Statement

Toronto Seniors Housing Corporation recognizes the need to identify and remove barriers faced by people with disabilities and will achieve greater accessibility by aligning with a culture that recognizes the dignity and worth of every individual.​

This policy provides an overview of all of Toronto Seniors Housing Corporation’s policies, plans and programs as they relate to accessibility. While components of this policy are intended to address the corporation’s compliance with legislation, Toronto Seniors Housing Corporation’s commitment to accessibility extends beyond legislative compliance. As Toronto Seniors Housing Corporation continues to achieve accessible social housing and employment, this policy requires Toronto Seniors Housing Corporation staff to incorporate best practices in accessibility through all aspects of its business. Toronto Seniors Housing Corporation will engage and consult with stakeholders, tenants, and employees with disabilities in the development of its accessibility policies, plans, and programs.

Definitions

​​Accessible formats: ​Formats that are an alternative to standard formats and are accessible to people with disabilities. Accessible formats may include, but are not limited to, large print, recorded audio and electronic formats, braille and other formats usable by persons with disabilities.

​Communication supports: Supports that individuals with disabilities may need to access information. These include, but are not limited to, captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications.

Disability: From the Ontario Human Rights Code, R.S.O. 1990, c. H. 19:

• any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness;
• a condition of mental impairment or developmental disability;
• a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoke language;
• a mental disorder; or
• an injury or disability for which benefits were claimed or received under the Workplace Safety and Insurance Act, 1997, S.O. 1997, c. 16 sche. A, or Ontario Disability Support Program.

​In addition, the definition of disability under the Ontario Human Rights Code, R.S.O. 1990, c. H. 19, may include but is not limited to:

• Acquired Brain Injury
• Deaf, deafened, hard-of-hearing
• Low vision or blind
• Chronic health conditions (cancer, epilepsy, heart disease, etc.)

Accessibility Lead: The member of the leadership team who has been designated as the lead for this policy and all related accessibility initiatives.

Toronto Seniors Housing Corporation staff: All Toronto Seniors Housing Corporation employees, whether full or part-time, temporary or permanent, including secondees. ​

Volunteers: Any individual who works for or on behalf of Toronto Seniors Housing Corporation on an unpaid basis, or for nominal consideration, including, but not limited to, volunteers, tenant volunteers, interns, and students.

Scope

This policy applies to all Toronto Seniors Housing Corporation staff, volunteers, and third party contractors who interact with tenants or staff on behalf of Toronto Seniors Housing Corporation.

​Core Principles

In keeping with our values of respect, inclusion, accountability and innovation, Toronto Seniors Housing Corporation will implement this policy in accordance with the following principles:

Dignity

Tenants and staff are treated in a respectful manner.

Independence

Services, opportunities, programs, and facilities for persons with disabilities will support their independence while respecting their right to safety and personal privacy. Service delivery will consider the nature of the service and alternative accommodation that may be required.

Equity/Equality of Outcome

Tenants and staff with disabilities will be provided the same access to our programs, services, opportunities, and facilities as all other tenants and staff.

Integration

Tenants and staff with disabilities will fully benefit from the same programs, services, opportunities, and facilities, in the same places and in the same or similar way as all other tenants and staff. An emphasis on inclusion will focus on eliminating barriers for people with disabilities.

Governance and Legislation

Toronto Seniors Housing Corporation will meet or exceed the following legislative requirements:​

Accessibility for Ontarians with Disabilities Act, 2005 (AODA)

The AODA came into effect in 2005. It permits the Ontario government to establish Accessibility Standards to remove or prevent barriers for Ontarians with disabilities by 2025. For details on Toronto Seniors Housing Corporation’s compliance with the AODA and associated legislation refer to the relevant policies as listed in the Policy Details.

Employment Standards Act, 2000 (ESA)

The ESA sets out the minimum standards for working in Ontario and defines the rights and responsibilities of employees and employers. Toronto Seniors Housing Corporation is committed to complying with the standards outlined in the ESA as they relate to accessibility and accommodation on the basis of disability.

Ontario Human Rights Code (OHRC)

The OHRC was enacted in 1990 and ensures the rights of all people to be treated equally and without discrimination based on race, colour, gender identity, sex, sexual orientation, disability, creed and age. Toronto Seniors Housing Corporation is committed to upholding the OHRC in its entirety.

Integrated Accessibility Standards (IASR)

The IASR was enacted under the AODA in 2011, with phased implementation requirements commencing January 1, 2012 through to January 1, 2021.
​The IASR addresses three specific areas of relevance to Toronto Seniors Housing Corporation: accessible employment practices; accessible information and communication supports; and design of the built environment. Provisions that guide staff in complying with the IASR can be found in a number of policies, programs and standards and are noted in the Policy Details below.

Toronto Seniors Housing Corporation tracks the implementation of the IASR in its multi-year Accessibility Plan. The plan is posted on Toronto Seniors Housing Corporation’s website and is made available in accessible formats upon request. The plan is updated on an ongoing basis and is fully reviewed every five years.

Ontario Building Code (OBC)

The OBC is a set of mandated building design and construction standards aimed at minimizing the risk to the health and safety of the occupants of a building and to provide for the barrier-free access to buildings. Toronto Seniors Housing Corporation follows the standards set out in the OBC in order to make sure that the design and construction of all new buildings, and changes and additions to existing buildings serve to increase accessibility for tenants and meet legislative requirements by 2025.

​Accessibility Focus Areas

Accessible Customer Service

Toronto Seniors Housing Corporation will develop best practices to provide accessible customer service in a respectful and transparent manner. The relevant policies and programs are summarized below and the details can be found in the documents themselves.

• Accessible Customer Service Policy: outlines our commitment to provide customer service that is inclusive, barrier free and meets the unique needs of persons with disabilities.
• Communication Standards/Accessible Formats and Communications Supports:outlines the standards that Toronto Seniors Housing Corporation follows in all communications to tenants. These standards include the Information and Communications Standards as outlined in the IASR.
• Human Rights, Harassment & Fair Access Policy:Includes proactive measures to eliminate harassment and discrimination in accommodation, employment, delivery of services, and in all other contract arrangements. It reflects the requirements of the OHRC and policies established by the City of Toronto.
• Self-Service Kiosk Standards:Toronto Seniors Housing Corporation will ensure accessibility for persons with disabilities when designing, procuring and acquiring self-service kiosks, as indicated in the IASR.
• Tenant Transfer Policy:formalizes Toronto Seniors Housing Corporation’s commitment to priority transfers of persons who have a medically documented need for accessible accommodation.
• Tenant Complaints Process:ensures that complaints are heard, the facts of the complaints are established, and where required, remedial actions are taken. The primary objective of this process is to outline a simple process which is accessible to all.

Accessible Homes

Toronto Seniors Housing Corporation will ensure that tenants with disabilities can live in units, buildings and communities that accommodate their needs. The relevant policies and programs are summarized here and the details can be found in the documents themselves.

• Accessibility in the Built Environment Policy:TSHC strives to treat all individuals in a manner that allows them to maintain their dignity and independence and is committed to providing an inclusive environment to tenants with disabilities as outlined in the Human Rights Code, the Accessibility for Ontarians with Disabilities Act, and the complimentary legislation of the Ontario Building Code, and the Integrated Accessibility Standards. As the buildings TSHC manages are owned by Toronto Community Housing Corporation (TCHC), TSHC uses the TCHC’s Build Standards to provide guidance as they apply to minor accessibility modifications that TSHC may make to tenants’ units. TSHC’s Accessibility Plan sets out TSHC’s policy on how we will achieve accessibility generally, as well as in the built environment.
• Accessibility Program: Capital Planning:TSHC participates in TCHC’s capital planning and implementation process for planned capital improvements.
• Accessibility Program: Tenant Request Unit Modifications:includes standards and a process for accessibility-related unit modifications based on tenant request and documented medical need.

Accessible Workplaces

Toronto Seniors Housing Corporation will ensure that employees with disabilities are accommodated in a respectful and transparent manner. The relevant policies and programs are summarized here and the details can be found in the documents themselves.

• Hiring Policy:Outlines Toronto Seniors Housing Corporation’s commitment to meeting its statutory obligations in the hiring process, and ensures that employment accommodation is provided to all candidates in accordance with the OHRC and the ESA.
• Human Rights, Harassment & Fair Access Policy:Includes proactive measures to eliminate harassment and discrimination in accommodation, employment, delivery of services, and in all other contract arrangements. It reflects the requirements of the OHRC and policies established by the City of Toronto.
• Individualized Workplace Emergency Response Information:Individualized workplace emergency response information will be prepared for employees with disabilities where the disability is such that the individualized information is necessary and Toronto Seniors Housing Corporation is aware of the need for accommodation due to the employee’s disability. This will be prepared as soon as practicable after Toronto Seniors Housing Corporation becomes aware of the need for accommodation due to the employee’s disability. A detailed process can be found as part of Toronto Seniors Housing Corporation’s Workplace Accommodation Policy.
• Workplace Accommodation Policy:Facilitates effective responses to accommodation issues that arise in the workplace and ensures Toronto Seniors Housing Corporation meets its duty to accommodate under the OHRC.

Supports for Policy Implementation

• Staff Training:Toronto Seniors Housing Corporation will ensure that accessibility training is provided to all employees and persons who participate in developing our policies.

The training will consist of requirements under the IASR; the parts of the OHRC that pertain to people with disabilities.

​The training will be appropriate to the duties of the person being trained and will be provided as soon as practicable. A record will be kept of the dates of the training and the number of individuals trained.

Toronto Seniors Housing Corporation will also provide training on an ongoing basis when changes are made to the policies and programs listed above, and to new employees as part of the on-boarding process.

• Tenant & Staff Engagement:Toronto Seniors Housing Corporation will consult and work with tenants with disabilities and stakeholders in the development of the above accessibility policies, plans, and programs. Toronto Seniors Housing Corporation will consult with appropriate stakeholders, which may include tenants with disabilities, tenant accessibility advocacy groups, experts in the field of accessibility, and Toronto Seniors Housing Corporation staff when undertaking formal reviews of this policy and any other Toronto Seniors Housing Corporation policies related to accessibility.
• Procuring Goods and Services:Toronto Seniors Housing Corporation’s Procurement Department shall incorporate accessibility criteria and features into its procurement process, procurement documents shall specify the desired accessibility standards to be met and the related submission requirements, except where it is not practical to do so. Where it is impractical to incorporate accessibility criteria and features into the procurement process, the Procurement Department will provide an explanation upon request. The Procurement Department will also ensure that all selected vendors, where applicable, comply with the AODA and its regulations when providing accessible goods and services to Toronto Seniors Housing Corporation.​

Compliance and Monitoring

Accessibility Reviews

All new or revised policies and procedures will be reviewed to ensure legislative compliance. When developing, revising and implementing Toronto Seniors Housing Corporation’s policies and strategies, authorized Toronto Seniors Housing Corporation staff will conduct an accessibility review. This review will consider and address accessibility, with a particular focus on reducing barriers faced by people with disabilities and ensuring the principles guiding this policy are upheld.

Reporting

The accessibility lead will report regularly to the leadership team. Accessibility is an integral component of Toronto Seniors Housing Corporation’s business, and metrics on accessibility improvements will be reported  regularly to the Toronto Seniors Housing Corporation Board of Directors and annually through the annual report.

Related Legislation, Regulations, and TSHC Policies:

• Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11
• Employment Standards Act, 2000, S.O. 2000, c. 41
• Human Rights Code, R.S.O. 1990, c. H. 19
• Integrated Accessibility Standards, O. Reg. 191/11
• ​Ontario Building Code, O. Reg. 332/12
• TSHC Accessible Customer Service Policy (to be reviewed)
• TSHC Hiring Policy
• TSHC Human Rights Policy – staff
• TSHC Human Rights and Harassment Policy – tenants
• TSHC Workplace Accommodation Policy

Amendments (Revision History):

NA

​Next Scheduled Review Date:

This policy will be reviewed once every five years.

Policy Contact

Director, Strategy and Business Management

Toronto Seniors Housing Corporation (TSHC) Accessible Customer Service Policy

Policy Sponsor: Director, Strategy and Business Management

Approver: Board of Directors

Initial Approval Date: May 17, 2022

Effective Date: June 1, 2022

Policy Statement

Toronto Seniors Housing Corporation (TSHC) recognizes that accessibility for persons with disabilities is an important issue that needs to be addressed throughout our portfolio. Toronto Seniors Housing Corporation is committed to the principles of accommodation outlined in the Accessibility for Ontarians with Disabilities Act, 2005 (AODA), the Accessibility Standards for Customer Service, Ontario Regulation 429/07 (the Customer Service Standard), and the Ontario Human Rights Code. The Accessibility Standards for Customer Service, Ontario Regulation 429/07 (the Customer Service Standards) is an accessibility standard created under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA).

Toronto Seniors Housing Corporation will continue to provide customer service for persons with disabilities in a manner that respects their dignity and independence while allowing them the same opportunity as any other customer to access and benefit from our services.

As additional standards identified in the AODA pass into regulation, this policy will be adjusted to include these new standards.

Policy Objectives

In fulfillment of its obligations under the Customer Service Standards and in keeping with its values, this policy outlines Toronto Seniors Housing Corporation’s commitment to provide customer service that is inclusive, barrier free and meets the unique needs of persons with disabilities.

The purpose of this policy is to lay out Toronto Seniors Housing Corporation’s commitment to providing accessible customer service. This policy sets out key customer service commitments in several areas relating to accessibility.

Guidelines will set out detailed procedures and protocols that guide Toronto Seniors Housing Corporation in applying this policy. The policy and Guidelines will inform tenants and the public of our commitment and will guide them in requesting accommodation in service and providing feedback about our services.

Scope

This policy applies to all persons who interact with tenants, members of the public or third parties on behalf of Toronto Seniors Housing Corporation, as an employee, contractor, volunteer, member of the Board of Directors or otherwise.

Key Values

Toronto Seniors Housing Corporation shall provide accessible customer service in accordance with the following key principles:

Dignity

Service is provided in a respectful manner consistent with the needs of the individual.

Independence

Services for persons with disabilities shall support their independence while respecting their right to safety and personal privacy. As such, service delivery shall consider the nature of the service and alternative accommodation that may be required.

Equity/Equality of Outcome

Customers with disabilities will be provided with the same opportunity to access our services as all other customers.

Integration

Customers with disabilities shall fully benefit from the same services, in the same place and in the same or similar way as all other customers.

Definitions

Under the Customer Service Standards (O.Reg. 429/07):

Assistive Device: A device used to assist persons with disabilities in carrying out activities of daily life or accessing the services provided by Toronto Seniors Housing Corporation including, but not limited to, wheelchairs, walkers, canes, note-taking devices, portable magnifiers, recording machines, personal oxygen tanks and devices for grasping.

Barrier: Anything that prevents a person with a disability from fully participating in all aspects of society because of their disability, including a physical barrier, an architectural barrier, an information or communications barrier, an attitudinal barrier, a technological barrier, a policy a practice.

Disability: (a) 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 co- ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device, (b) a condition of mental impairment or a developmental disability, (c) learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language, (d) mental disorder, or (e) an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

Service Animal: An animal trained specifically to assist an individual with a disability, either where it is readily apparent that the animal is a service animal or where a letter has been provided by a doctor or nurse confirming that the person requires the animal for reasons related to a disability.

Support Person: Someone who accompanies a person with a disability and assists them with communication, mobility, personal care, medical needs or with access to goods or services.

Customer Service Commitments

Training

Toronto Seniors Housing Corporation will provide training to all Board Members, employees, volunteers and others who interact with the tenants, the public or other third parties on its behalf, and all those who are involved in the development and approvals of customer service policies and procedures. Training will include the following:

The purposes of the AODA; the requirements of the customer service standard; and any subsequent legislation.

Instruction on Toronto Seniors Housing Corporation’s policies, and procedures pertaining to the provision of goods and services to persons with disabilities, including the customer service standard.

How to interact and communicate with persons with various types of disabilities.

What to do if a person with a disability is having difficulty accessing Toronto Seniors Housing Corporation’s goods and services.

New staff will be trained upon their initial orientation. Following initial training, existing staff will receive training on a regular basis and when changes are made to these policies and procedures or regulations.

Service Animals

Toronto Seniors Housing Corporation is committed to welcoming persons with disabilities who are accompanied by a service animal on the parts of our premises that are open to the public.

If a service animal is excluded by law, Toronto Seniors Housing Corporation will suggest appropriate alternatives and provide assistance in order to ensure that the person is able to access, obtain, use or benefit from Toronto Seniors Housing Corporation’s services where possible.

Support Persons

Any person with a disability who is accompanied by a Support Person will be allowed to access any services provided by Toronto Seniors Housing Corporation with their Support Person. At no time will Toronto Seniors Housing Corporation prevent a person with a disability who is accompanied by a Support Person from having access to their Support Person.

Where there are barriers to access or attendance by a Support Person at sponsored meetings, consultations or events, Toronto Seniors Housing Corporation will seek to facilitate access so as to ensure the participation of persons with disabilities.

Assistive Devices

Persons with disabilities shall be permitted to obtain, use or benefit from goods or services through the use of their own assistive devices. Staff will be trained so as to be familiar with various assistive devices that may be used by customers with disabilities while accessing services.

In the event a person with a disability is hindered from accessing any goods or services offered, Toronto Seniors Housing Corporation will seek to accommodate the person by offering the use of another assistive device that is available or an alternative way of delivering the same service.

Toronto Seniors Housing Corporation will ensure that staff know how to use assistive devices available in their various locations for customers and inform customers of the assistive devices that are available.

Notice of Temporary Disruptions

Toronto Seniors Housing Corporation is aware that the operation of its services and facilities is important to its customers. However, temporary disruptions in services and facilities may occur.

Toronto Seniors Housing Corporation will provide its customers with notice of any disruption to its services, including information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if any, that may be available.

Notice of service disruptions will be provided as soon as staff is aware of the disruption, or in advance in the case of planned disruptions. Notice will be provided by a variety of methods, depending on the circumstances, and may include postings in conspicuous places at the affected premises, in other Toronto Seniors Housing Corporation facilities, on Toronto Seniors Housing Corporation’s website or by any other means that will ensure that the notice reaches those persons potentially affected by the temporary disruption in a manner that is accessible to them.

Feedback Policy

The goal of Toronto Seniors Housing Corporation is to meet and surpass expectations while providing services to customers with disabilities. Feedback on our services and whether expectations are being met are welcome and appreciated. Feedback may be provided by a person with a disability in the manner deemed most convenient to them, such as in person, by telephone, in writing, by email or otherwise. All feedback will be kept in strict confidence and used to improve customer service. In addition, the author of the feedback will be provided a response in the format requested (or the most appropriate format where no request was made) outlining actions taken. Where an individual is not satisfied with Toronto Seniors Housing Corporation’s response to their feedback, staff will direct their complaint to the appropriate individual to respond.

Related Legislation, Regulations, and TSHC Policies:

• Accessibility for Ontarians with Disabilities Act, 2005 (AODA)
• Accessibility Standards for Customer Service, Ontario Regulation 429/07
• Ontario Human Rights Code
• TSHC Human Rights and Harassment Policy – Tenants
• TSHC Accessibility Policy
• TSHC Multi-year Accessibility Plan
• TSHC Tenant Complaint Procedure
• TSHC Accessibility Customer Service Policy Guidelines (to be reviewed)

Amendments (Revision History):

NA

Next Scheduled Review Date: 2025

This policy will be reviewed once every 5 years.

Policy Contact

Director, Strategy and Business Management

Toronto Seniors Housing Corporation Multi-Year Accessibility Plan

(the “Accessibility Plan”)

(Ontario Regulation 191/11) of the Accessibility for Ontarians with Disabilities Act, 2005

Introduction

The Integrated Accessibility Standards Regulations (“IASR”) under the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”), require that Toronto Seniors Housing Corporation (TSHC) establish, implement, maintain, and document its accessibility policies and multi-year accessibility plan (the “Accessibility Plan”), which outlines TSHC’s strategy to prevent and remove barriers for persons with disabilities and to meet its requirements under the IASR.

The Accessibility Plan will be available in an accessible format upon request.

The Accessibility Plan will be reviewed and updated at least once every five years. The Director of Strategy and Business Management will lead the review process in consultation with tenants, staff, the TSHC Leadership Team, and other relevant groups. The plan will be approved by the TSHC Leadership Team.

Application

The Accessibility Plan applies to all employees, tenants, and clients of TSHC, and, where indicated, to any independent contractor representatives working for the company.

Our Commitment

In fulfilling our mission, TSHC strives to treat all individuals in a manner that allows them to maintain their dignity and independence. TSHC promotes integration and equal opportunity and is committed to meeting the needs of people with disabilities in a timely manner. We will seek to achieve this by preventing and removing barriers to accessibility and by meeting accessibility requirements under the AODA. This Accessibility Plan sets out TSHC’s policy on how we will achieve accessibility generally, as well as in employment, information and communications, and the design of public spaces (built environment).

Under the IASR, the following accessibility strategies set out the requirements that are applicable to TSHC:

• Workplace Emergency Response Information
• Training
• Information and Communication
• Employment
• Design of Public Spaces Standards

Accessibility Standards for Customer Service

TSHC is committed to compliance with the Accessibility Standards for Customer Service Regulation (O.Reg.429/07) under the AODA, which involves providing its services in ways that respect the dignity and independence of people with disabilities.

TSHC’s employees who are involved in providing customer service to its customers and the general public have been trained on TSHC’s Accessible Customer Service Policy, and all new employees hired to provide such services will receive such training as part of their orientation with the company.

Copies of TSHC’s Accessible Customer Service Policy will be made available to members of the public and third parties on request and is available on the TSHC website here.

Integrated Accessibility Standards Regulations (IASR)

The following sets out how TSHC is committed to complying with the IASR.

1. Workplace Emergency Response Information

Where TSHC is aware that an employee has a disability and that there is a need for accommodation, individualized workplace emergency response information will be provided to the employee as soon as practicable if such information is necessary given the nature of the employee’s disability.

Action Taken:

TSHC will be implementing the following measures to address Emergency Response for employees who have disabilities:

• individualized workplace emergency response information procedures will be developed for employees with disabilities where required.
• where employees disclose a disability and are being accommodated according to their disabilities, workplace emergency response information forms will be prepared where required.
• where required, TSHC provides assistance to specific disabled employees, with the disabled employees’ prior consent, to help them evacuate the workplace in case of an emergency or disaster. Plans for providing assistance will be set out in individualized emergency plans for the employees.
• individualized emergency plans will be communicated to the employees’ respective managers and safety personnel on an ‘as needed’ basis.
• on an ongoing and regular basis, and as per the applicable terms of the IASR, TSHC will review and assess general workplace emergency response procedures and individualized emergency plans to ensure accessibility issues are addressed.

Compliance Date: June 2022

2. Training

TSHC is committed to providing training on the requirements of the accessibility standards referred to in the IASR and on the Human Rights Code, as it pertains to persons with disabilities.

Planned Action:

In accordance with the IASR, TSHC will:

• determine and ensure that appropriate training on the requirements of the IASR and on the Human Rights Code as it pertains to persons with disabilities, is provided to all employees, independent contractor representatives, volunteers, third-party service providers who provide services related to products, services, and facilities on TSHC’s behalf, and persons participating in the development and approval of TSHC’s policies.
• ensure that the training is provided to persons referenced above as soon as practicable.
• keep and maintain a record of the training provided, including dates the training was provided and number of individuals to whom it was provided.
• ensure training is provided on any changes to TSHC’s policies on an ongoing basis.

Anticipated Compliance Date: March 2024

3. Information and Communication

TSHC is committed to making company information and communications accessible to persons with disabilities. TSHC will incorporate new accessibility requirements under the information and communication standards to ensure that its information and communications systems and platforms are accessible and are provided, upon request, in accessible formats that meet the needs of persons with disabilities.

a. Feedback, Accessible Formats, and Communication Supports

Planned Action:

In accordance with the IASR, TSHC will:

• ensure that existing and new processes for receiving and responding to feedback are accessible to persons with disabilities by providing or arranging for the provision of accessible formats and communication supports, upon request and in a timely manner.
• more broadly, as a general principle where accessible formats and communication supports for persons with disabilities are requested:
  • provide or arrange for the provision of such accessible formats and communication supports.
  • consult with the person making the request to determine the suitability of the accessible format or communication support.
  • provide or arrange for the provision of accessible formats and communication supports in a timely manner that takes into account the person’s accessibility needs due to disability, and at a cost no more than the regular cost charged to other persons.
• notify the public about the availability of accessible formats and communication supports.

Compliance Date: January 2023

b. Accessible Websites and Web Content

Planned Action:

In accordance with the IASR, TSHC recognizes its obligation to provide web content which conforms with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG 2.0) Level AA.

Any website hosted by TSHC shall meet the requirements set out in the IASR.

Compliance Date: September 2023

4. Employment

a. Recruitment

TSHC is committed to fair and accessible employment recruiting practices that attract and retain employees with disabilities. This includes providing accessibility at all stages of the employment cycle.

Planned Action:

In accordance with the IASR, TSHC will do the following:

(i) Recruitment General

TSHC will notify employees and the public of the availability of accommodation for applicants with disabilities in the recruitment process. This will include:

• review and, as necessary, modification of existing recruitment policies, procedures, and processes.
• specifying that accommodation is available for applicants with disabilities, on TSHC’s website and on job postings.

Anticipated Compliance: March 2024

(ii) Recruitment, Assessment, and Selection

TSHC will notify job applicants, when they are individually selected to participate in an assessment or selection process and inform them that accommodations are available upon request in relation to the materials or processes to be used in the assessment/selection process. This will include:

• review and, as necessary, modification of existing recruitment policies, procedures, and processes.
• inclusion of availability of accommodation notice as part of the script in the scheduling of an interview and/or assessment.
• consultation with the applicant and arrangement for provision of suitable accommodations in a manner that takes into account the applicant’s accessibility needs due to the disability where a selected applicant requests accommodation.

Compliance Date: June 2022

(iii) Notice to Successful Applicants

When making offers of employment, TSHC will notify the successful applicant of its policies for accommodating employees with disabilities. This will include:

• A review and, as necessary, modification of existing recruitment policies, procedures, and processes.
• inclusion of notification of TSHC’s policies on accommodating employees with disabilities in offer of employment letters.

Compliance Date: June 2022

b. Informing Employees of Supports and General Provision of Accessible Formats and Communications Supports

In accordance with the IASR, TSHC will inform all employees of policies that support employees with disabilities, including, but not limited to, policies on the provision of job accommodations that take into account an employee’s accessibility needs due to a disability.

This will include:

• informing current employees and new hires of TSHC’s policies supporting employees with disabilities, including, but not limited to, policies on the provision of job accommodations that take into account an employee’s needs due to disability.
• providing information as soon as practicable after the new employee begins employment, specifically in the orientation process.
• keeping employees up to date on changes to existing policies on job accommodations with respect to disabilities.
• where an employee with a disability so requests it, TSHC will provide or arrange for provision of suitable accessible formats and communications supports for:
  • information that is needed in order to perform the employee’s job.
  • information that is generally available to employees in the workplace.
• in meeting the obligations to provide the information that is set out above, TSHC will consult with the requesting employee in determining the suitability of an accessible format or communication support.

Compliance Date: June 2022

c. Documented Individual Accommodation Plans/Return to Work Process

TSHC will incorporate new accessibility requirements under the IASR to ensure that barriers in accommodation and return to work processes are eliminated and corporate policies surrounding accommodation and return to work are followed, where applicable.

Planned Action:

TSHC’s existing policies include steps that TSHC will take to accommodate employees with disabilities and to facilitate employees’ return to work after absence due to disability.

TSHC will review and assess the existing policies to ensure that they include a process for the development of documented individual accommodation plans for employees with disabilities, if such plans are required.

In accordance with the provisions of the IASR, TSHC will ensure that the process for the development of documented individual accommodation plans includes the following elements:

• information regarding the manner in which the employee requesting accommodation can participate in the development of the plan.
• information regarding the means by which the employee is assessed on an individual basis.
• information regarding the manner in which TSHC can request an evaluation by an outside medical or other expert, at TSHC’s expense, to assist TSHC in determining if and how accommodation can be achieved.
• steps to protect the privacy of the employee’s personal information.
• information regarding the frequency with which individual accommodation plans will be reviewed and updated and the manner in which this will be done.
• the reasons for a denial where an individual accommodation plan is denied.
• information regarding the means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs,
• the following will be included if individual accommodation plans are established:
  • any individualized workplace emergency response information that is required.
  • any information regarding accessible formats and communication supports that have been provided for or arranged, in order to provide the employee with:
    • information that is needed in order to perform the employee’s job.
    • information that is generally available to employees in the workplace.
• identify any other accommodation that is to be provided to the employee.

TSHC will ensure that the return-to-work process as set out in its existing policies outlines:

• the steps TSHC will take to facilitate the employee’s return to work after a disability-related absence.
• the development of a written individualized return to work plan for such employees.
• the use of individual accommodation plans, as discussed above, in the return-to-work process.

Compliance Date: June 2022

d. Performance Management, Career Development and Redeployment

TSHC will take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans:

• when using its performance management process in respect of employees with disabilities.
• when providing career development and advancement to employees with disabilities.
• when redeploying employees with disabilities.

Planned Action:

In accordance with the IASR, TSHC will:

• review, assess and, as necessary, modify existing policies, procedures, and practices to ensure compliance with the IASR.
• take the accessibility needs of employees with disabilities and, as applicable, their individualized accommodation plans, into account when:
  • assessing performance
  • managing career development and advancement
  • redeployment is required
• review, assess and, as necessary, include in performance management workshops, accessibility criteria.
• take into account the accessibility needs of employees with disabilities when providing career development and advancement to its employees with disabilities, including notification of the ability to provide accommodations on internal job postings.
• take into account the accessibility needs of employees with disabilities when redeploying employees, including review and, as necessary, modification of the employee transfer checklist.

Compliance Date: June 2022

Integrated Accessibility Standards Regulations – Design of Public Spaces

While TSHC has no plans to engage in new construction or redevelopment which would be captured by the requirements of the IASR concerning the Design of Public Spaces, TSHC recognizes its obligations under the relevant sections of the Regulation and is committed to incorporating barrier-free design principles into any public spaces that are newly constructed and redeveloped on or after January 1, 2017.

Toronto Seniors Housing Corporation manages the Landlord and Tenant relationship.  All 83 of the TSHC-managed buildings are owned by the Toronto Community Housing Corporation.

Procedures for Preventative and Emergency Maintenance.

Toronto Community Housing Corporation is responsible for undertaking all preventative and emergency maintenance of the accessible elements in public spaces. TCHC’s procedures include:

• Conducting regular inspections for accessible and life safety equipment in all buildings throughout the year;
• Providing tenants 24/7 access to TCHC’s Client Care Centre (a shared service, referred to at TSHC as the Tenant Support Centre) to have their needs addressed during planned and temporary service disruptions (dispatching staff for repair or direct tenant support);
• Notifying tenants during extended service disruptions and providing direct support, including providing all impacted individuals with reasonable alternative solutions where necessary; and
• Dispatching emergency maintenance service immediately when notified of a service disruption.

Feedback:

For more information on this Accessibility Plan or for accessible formats of the Accessibility Plan, please contact:

Grant Coffey, Director of Strategy and Business Management

Email: Grant.Coffey@torontoseniorshousing.ca

Telephone: 416-981-4548

Plan version:  August 2024

One of the most important elements of the Accessibility​ for Ontarians with Disabilities Act Customer Service Standard is ensuring customers know the ways to share feedback about our accessible customer service. Toronto Seniors Housing Corporation (TSHC) welcomes feedback on how we provide accessible customer service. Customer feedback will help us identify barriers and respond to concerns.

How to share your feedback​​:

• Call the Tenant Support Centre at 416-945-0800—24 hours a day, seven days a week
• Visit your Regional office by appointment—Monday to Friday, 10 a.m. to 4 p.m.
• ​Email us at ​support@torontoseniorshousing.ca​

Feedback will be directed to the appropriate individual to respond.

TSHC ensures our feedback process is accessible to people with disabilities by providing or arranging for accessible formats and communication supports, on request.