Accessibility for Persons with Disabilities Policy

Effective Date: October 30, 2023

Purpose

The goal of this policy is to ensure that Toronto Public Library (“the Library” or “TPL”) meets or exceeds the compliance requirements set by the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and the Integrated Accessibility Standards Regulation (IASR).

The objective is to provide an accessible, equitable, and inclusive work environment for its employees and Library services to its customers.

Scope

The Accessibility for Persons with Disabilities Policy (“the Policy”) applies to all aspects of the Library’s operations, including its services and facilities, information and communications, technology, and employment opportunities. It further applies to staff, volunteers, and any third parties providing goods, services, products, or facilities on the Library’s behalf to the public.

Underlying Principles

Toronto Public Library’s Accessibility for Persons with Disabilities Policy is founded on the following underlying principles:

Policy Statement

Toronto Public Library is committed to providing an open, accessible, and equitable environment that meets the changing needs of its employees and customers, including persons with disabilities, in a welcoming and supportive environment.

The Library will develop and support a work and service environment where the needs of persons with disabilities are addressed in accordance with the principles of dignity, independence, equal opportunity, and integration.

In accordance with its vision, mission, and values, the Library is guided by the service values of equity and diversity in the treatment of its employees and customers. TPL will meet or exceed the standards set by the AODA and the IASR.

The Library will establish, implement and monitor policies, services, and practices that balance the needs of persons with disabilities and others to support the accessibility standards of customer service, information and communication, employment and the built environment established under the AODA.

1.0 General Requirements

1.1 Library Policies

Library policies will be applied in a manner that considers the individual accessibility needs of persons with disabilities and respects the principles of dignity, independence, equal opportunity, and integration.

1.2 Multi-Year Accessibility Plan

The Library will establish, deliver, and maintain a Multi-Year Accessibility Plan (MYAP). The MYAP outlines the projects and initiatives that will be developed and implemented to identify, remove, and prevent systemic accessibility barriers and meet its legislated compliance obligations under the IASR.

The MYAP will be developed in consultation with internal and external stakeholders, including persons with disabilities, and posted to the Library’s external website. The Library will also prepare an annual status report on its Multi-Year Accessibility Plan, and post these reports to its external website. The MYAP and status reports will be provided in an accessible format upon request.

The Multi-Year Accessibility Plan will be updated at the same time, and span the same number of years, as the Library’s Corporate Strategic Plan.

1.3 Procurement

The Library will incorporate accessibility criteria and features into the procurement of any goods, services, products, or facilities obtained through a formal contract or agreement with a third-party, except where it is determined by the Library to be not practicable.

Any third parties that provide goods, services, products, or facilities on the Library’s behalf to the public must ensure their staff has received appropriate accessibility training as required under the IASR.

The Library will also incorporate accessibility features and criteria when designing, procuring or acquiring self-service kiosks such as self-check-out terminals.

In the event where it is not practicable to procure accessible goods, products, services, facilities, or self-serve kiosks, staff will document the reason within any files and reports related to the project.

1.4 Training

The Library will establish, provide, and document ongoing mandatory training on the AODA, IASR, related Library policies, and the Ontario Human Rights Code as it relates to persons with disabilities.

This training will be provided to any individual involved in the development of the Library’s policies, and to its employees, volunteers, and any third parties providing goods, services, and facilities on behalf of the Library to the public, as soon as practicable.

As part of its accessibility training, the Library will provide information on the requirements of the AODA standards under the IASR to its staff as appropriate to the duties of their role(s), including, but not limited to:

2.0 Information and Communication

The Library will communicate with, and provide information to, its employees and customers with disabilities in a manner that takes into account their individual accessibility needs.

2.1 Accessible Websites and Web Content

The Library will ensure its external website, web content, and any web-based applications, developed internally or procured through a third party, comply with all applicable level AA success criteria established under the Web Content Accessibility Guidelines 2.0 (WCAG).

2.2 Accessible Formats & Communication Supports

The Library will provide accessible formats and communication supports to its employees and customers with disabilities upon request, in a timely manner, and at no additional cost to the individual.

The Library will inform its employees and customers of the availability of accessible formats and communication supports on its website and any internal and external documents related to a meeting, program, employment opportunity, and/or event.

2.3 Feedback Process

The Library welcomes continuous feedback from persons with disabilities on the accessibility of its goods, services, programs, and facilities. The Library will accept feedback in a variety of accessible manners, including phone, email, TTY, and its online feedback form, and will communicate with its staff and customers with disabilities in a manner that meets their individual accessibility needs.

Responses to customer feedback will be sent within two business days in accordance with the Library’s Customer Feedback Standard.

2.4 Emergency Procedures, Plans, & Safety Information

The Library will provide its emergency procedures, plans, and health and safety information, that it makes available to the public, to persons with disabilities in an accessible format or with an appropriate communication support upon request.

2.5 Public Libraries

The Library will provide equitable access to library materials in accessible formats, where they exist, to its employees and customers with disabilities, including archival materials and special collections.

The Library will inform the public, through its external website, of the availability of accessible materials and any additional accessibility services offered within its branches and facilities for persons with disabilities.

3.0 Customer Service

In keeping with the Library’s commitment of providing free, equitable, and accessible service in a welcoming and supportive environment, the Library will:

3.1 Service Animals

The Library welcomes service animals, within its branches, facilities, and Book Mobile vehicles, that are needed to assist persons with disabilities.

Persons with disabilities, accompanied by a service animal, shall be permitted to enter a library branch, facility, or Book Mobile vehicle, and shall not be separated from their service animal unless the animal is otherwise excluded from the premises by law.

If a service animal is excluded from entering the Library’s premises by law, the Library will ensure the person with a disability can perform the duties of their employment and/or access the Library’s goods, services, programs, and facilities in a manner that meets their individual accessibility needs.

While accessing the Library’s premises or performing the duties of their employment, the person with a disability is responsible for ensuring their service animal is clearly identified by a vest, harness, or documentation provided by the individual, and that the animal behaves in a professional manner.

3.2 Support Persons

The Library welcomes persons with disabilities and their accompanying support persons within its branches, facilities, and Book Mobile vehicles. If discussing personal or confidential information, staff will ask the person with a disability if they prefer their support person to remain present.

While accessing the Library’s premises, or performing the duties of their employment, the person with a disability shall be permitted to remain with their support person at all times.

In the event where an admission fee is charged for a library program, service, or event, this fee will be waived for support persons, or advanced notice will be given of any admission fees related to support persons.

3.3 Assistive Devices

The Library supports the use of assistive devices that enable persons with disabilities to use the Library’s goods, services, and facilities. The Library will offer a broad range of assistive devices, including communication supports, to help meet the reading and learning needs of persons with disabilities.

The Library also recognizes that equitable service can be achieved by supporting the person’s individual accessibility needs. Customers with disabilities may use personal assistive devices while accessing the Library.

3.4 Notice of Temporary Service Disruptions

In the event of a scheduled service disruption to its goods, services, or facilities, the Library will notify its employees and customers of this disruption at least two business days prior to its planned start date and time. The notice should include the reason for the disruption, how long the disruption will last, and a description of available alternatives, if any.

In the event of an unplanned disruption, notice will be provided as quickly as possible through the Library’s internal and external communication channels.

3.5 Accessibility Accommodations for Persons with Disabilities

The Library will provide accessibility accommodations, upon request, as required under the Ontario Human Rights Code, to its employees and customers with disabilities.

When a request for an accessibility accommodation is received, the Library has a legal duty to provide the requested accommodation in a timely manner that respects the dignity, integrity, independence, and individual accessibility needs of the person.

4.0 Employment

4.1 Recruitment and Hiring Process

The Library will incorporate the requirements, established under the Employment Standards, into its recruitment and hiring practices and procedures, including, but not limited to, the provision of accessible formats and communication supports upon request for candidates with disabilities throughout the entire hiring process.

4.2 Workplace Emergency Response Information

The Library will provide its employees with disabilities with workplace emergency response information. Upon consultation with the employee and their supervisor and/or manager, this information will be delivered in a manner that takes into account the employee’s individual accessibility needs.

4.3 Documented Individualized Accommodation Plans

The Library will establish a process for the development of documented individualized accommodation plans for its employees with disabilities.

In consultation with the employee, their manager, and union representative, if applicable, the Plan will document the workplace accommodations that will be required by the employee to perform the duties of their role at the Library.

4.4 Return to Work Process

When absent from work due to a disability, the Library will adhere to its return to work process, as outlined in its Collective Agreement, for its employees, including the provision of accessibility accommodations if required.

The process referenced in this section does not replace or supersede an existing return to work process created, or mandated, under another statute. Rather, it will support the successful return to work of all employees.

4.5 Performance Management

The Library, throughout its performance management process, will take into account the individual accessibility needs of its employees with disabilities and their documented accommodation plan, if one has been established.

4.6 Career Development & Advancement

When establishing policies, programs, or strategies that support the career development and advancement of its employees, the Library will take into account the individual accessibility needs of its employees with disabilities, and their documented accommodation plan if one has been established.

4.7 Position & Location Changes

When transferring or relocating employees with disabilities to a new work location or position, the Library will take into account their individual accessibility needs, as well as their documented accommodation plan if one has been established.

5.0 Built Environment & Public Spaces

When designing newly constructed or renovated branches or facilities, the Library will incorporate the requirements established under the City of Toronto’s Accessibility Design Guidelines (TADG).

The TADG serves as a guiding set of standards that aims to meet and exceed the Ontario Building Code Barrier-Free design requirements and the technical requirements under the AODA Design of Public Spaces Standards.

When conducting public consultations on a newly constructed or renovated branch or facility, the Library will hold such consultations in an accessible venue and location, include people with disabilities, and provide any related documents in an accessible format or through an appropriate communication support upon request.

Accountability

The City Librarian and Directors are responsible for the implementation of this policy.

The Director, Human Resources, through the Manager, Accessibility, is responsible for monitoring, analyzing, and reporting on any amendments made to the Standards under the IASR.

The Library is responsible for reporting to the Ministry for Seniors and Accessibility every three (3) years on its compliance with the requirements under the IASR.

Related Legislation

Definitions

Accessible Formats: Accessible formats, sometimes called alternate formats, are ways of presenting printed, written, or visual material so that people with print disabilities can access it. People with print disabilities may:

Accessible formats may include, but are not limited to:

Assistive Device: 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, communicating or lifting. Examples include, walkers, magnifiers for reading, computer hardware and software, white canes, wheelchairs, scooters, and smart phones or tablets.

Barrier: A barrier is any systemic, attitudinal, technological, informational, or architectural limitation that prevents someone from participating fully in society due to their disability.

Communication Supports: Communication supports are ways for people who cannot access verbal or audio information to receive it visually or ways for people who are non-verbal to communicate with people who speak. For instance, people who do not understand verbal communication may:

Some common communication supports include:

Disability: As defined in the AODA, disability means:

(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) a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,

(d) a 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;

Goods, Services, and Facilities: All aspects of the Library as an employer and service provider, including: delivery of goods, services, and programs, all information and communication including verbal, print, audio, video, websites, web applications and web content, and other digital technologies including kiosks, and all buildings, facilities, public spaces, and the public realm.

Kiosk: An interactive electronic terminal, including a point-of-sale device, intended for public use that allows users to access one or more services or products or both.

Practicable: Capable of being done or put into practice; capable of being used. Factors relevant to determining if accessibility is practicable may include:

Service Animal: An animal is 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 one of the following regulated health professional confirming that the person requires the animal for reasons relating to the disability:

Support Person: In relation to a person with a disability, another person who accompanies the individual with a disability in order to help with communication, mobility, personal care or medical needs or with access to goods, services, or facilities.

Contact

Contact
Director, Human Resources