ACCESSIBLE CUSTOMER SERVICE POLICY
1. Purpose / Background Information
The Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) is a Provincial Act with the purpose of developing, implementing and enforcing accessibility standards in order to achieve accessibility for persons with disabilities with respect to goods, services, facilities, accommodation, employment, buildings, structures and premises.
Under the AODA, Ontario Regulation 429/07 entitled “Accessibility Standards for Customer Service” came into force on January 1, 2008. That Regulation establishes accessibility standards specific to customer service for public sector organizations and other persons or organizations that provide goods and services to members of the public or other third parties.
This policy is drafted in accordance with the Accessibility Standards for Customer Service (Ontario Regulation 429/07) and addresses the following:
- the provision of goods and services to persons with disabilities;
- the use of assistive devices by persons with disabilities;
- the use of service animals by persons with disabilities;
- the use of support persons by persons with disabilities;
- notice of temporary disruptions in services and facilities;
- training;
- customer feedback regarding the provision of goods and services to persons with disabilities; and
- notice of availability and format of
2. Application
This policy applies to all persons who deal with the public and those specifically designated, by contract to act, from time to time, on behalf of the London Transit Commission. This includes persons who are employees (full time, part time and/or on contract) and Members of the Commission and the Commission’s Accessible Public Transit Service Advisory Committee.
3. Definitions
Assistive Device
A device used to assist persons with disabilities in carrying out activities or in accessing the services of persons or organizations covered by the Customer Service Standard.
Commission
The London Transit Commission
Disability
Disability, defined to include:
- 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,
- a condition of mental impairment or a developmental disability,
- a learning disability, or a 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.
Nurse
A Registered Nurse or Registered Practical Nurse who is a registered member in good standing with the College of Nurses of Ontario.
Physician
A physician who is a registered member, in good standing, with the College of Physicians and Surgeons of Ontario.
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 professionals confirming that the person requires the animal for reasons relating to the disability:
- A member of the College of Audiologists and Speech-Language Pathologists of
- A member of the College of Chiropractors of
- A member of the College of Nurses of
- A member of the College of Occupational Therapists of
- A member of the College of Optometrists of
- A member of the College of Physicians and Surgeons of
- A member of the College of Physiotherapists of
- A member of the College of Psychologists of
- A member of the College of Registered Psychotherapists and Registered Mental Health Therapists of
Support Person
In relation to a person with a disability, another person who accompanies the person with a disability in order to help with communication, mobility, personal care or medical needs or with access to goods, services or facilities
4. Policy Statement
The London Transit Commission is committed to continuing to build, for all customers, an effective, efficient fully accessible public transit service
5. General Principles
a. The Provision of Goods and Services to Persons with Disabilities
The Commission will use reasonable efforts to ensure that its policies, practices and procedures are consistent with the following principles:
- the Commission’s services are provided in a manner that respects the dignity and independence of persons with disabilities;
- the provision of the Commission’s services to persons with disabilities are to be integrated with those provided to persons who do not have disabilities unless an alternative measure is necessary to enable a person with a disability to obtain, use or benefit from the Commission’s services and,
- persons with disabilities are given opportunities equivalent to that of persons without disabilities to obtain, use or benefit from the Commission’s
b. Communication with Persons with Disabilities
When communicating with a person with a disability, the Commission will do so in a manner that takes into account the person’s disability.
c. Notice of Temporary Disruptions in Services and Facilities
The Commission is aware that the operation of its services is important to the public. However, temporary disruptions in the Commission’s services and facilities may occur due to reasons that may or may not be within the Commission’s control or knowledge. Reference to services includes both “on-road” services as well as ancillary services supporting the on-road service.
For the purpose of this policy statement, a “temporary disruption of service” is defined as a known or planned event that results in a deviation in regular service routing and/or
schedule for an extended period of time, generally beyond one day. The known or planned nature of the event affords the Commission the opportunity to affect a revised service routing and/or schedule and provide timely communication to its customers.
The communication will include a reason for the disruption, the anticipated duration and a description of the alternative/amended routing and/or schedule as may be applicable. Such information will be provided from a menu of options, selected at the time as appropriate in the circumstances, giving consideration to time and duration. The options include:
- various news media (radio, paper, television)
- Commission website
- Commission Customer Service Staff; and
- posting of the appropriate notice either/or on-board the buses and at the affected bus stops
For all other occurrences of service disruption, the Commission, as considered appropriate in the circumstances, will make reasonable effort to advise the public of the disruption including information about the reason for the disruption, its anticipated duration, and a description of alternative/amended service if any, that may be available.
d. Assistive Devices and other Measures that Assist with Accessibility
A person with a disability is to provide their own assistive device for the purpose of obtaining, using and benefiting from the Commission’s services. Exceptions may occur in situations where the Commission has determined that the assistive device (example segways) may pose a risk to the health and safety of a person with a disability or the health and safety of others on the services and/or at the premises.
In these situations and others, the Commission may offer a person with a disability other reasonable measures to assist him or her in obtaining, using and benefiting from the Commission’s services, where the Commission has such other measures available. This includes having the person leave the assistive devices and sit in a passenger seat in the vehicle.
Persons with a disability are responsible to ensure their assistive device is operated in a safe and controlled manner at all times in accessing Commission services. This includes setting the brakes as appropriate on manual assistive devices (wheelchairs) or in the case of power assistive devices (chair or scooter) switching the power off.
Bus Operators are responsible for ensuring that wheeled mobility devices are properly secured, complete with the appropriate tie-downs and restraining devices and securely fastened before moving the bus. Should the passenger refuse to have his or her mobility device secured, the Operator will advise that it is mandatory for safety reasons. If the problem persists, the Operator will contact Dispatch and request assistance from an Inspector.
In the event that the passenger is traveling with an attendant who wishes to secure the mobility device the Operator must check to ensure the devices have been properly secured.
e. Service Animals
Service animals are permitted on the services and/or enter premises owned and operated, or operated by the Commission, noting such permission may be subject to presentation of the appropriate identification by the owner.
Service animals are permitted on buses if working in aid of the person making the trip.
Service animals on buses must remain in the care and control of the owner at all times. The owner must be prepared to demonstrate to the Operator how this requirement will be achieved (i.e. leash, cage, etc.).
This applies as follows:
- 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 customer provides documentation from a health professional confirming that the person requires the animal for reasons relating to the
f. Support Persons
A person with a disability may utilize the services and/or enter premises owned and operated, or operated, by the Commission with a support person and have access to the support person while on the service and/or on the premises.
The Commission may require a person with a disability to be accompanied by a support person while on the service and/or on the Commission premises in situations where, in the opinion of the Commission it is necessary to protect the health and safety of the person with a disability or the health and safety of others on the premises.
A support person, when assisting a person with a disability to use the Commission services, will be subject to the prevailing fare as defined in the Commission’s fare policy, associated with the use of the services, noting the Commission’s fare policy is subject to amendments from time to time.
g. Feedback
The Commission as provided by its’ mission statement is committed:
To develop and maintain an effective, efficient and safe public transit service operating as a key component of a sustainable transportation system while being competitive, customer focused and financially responsible and providing a work environment that fosters accountability, pride, teamwork and job satisfaction.
Feedback from the public is welcomed as it may identify areas that require change and encourage continuous service improvements. Feedback from a member of the public about the delivery of goods and services to persons with disabilities may be given by telephone, in person, in writing, in electronic format or through other methods.
Information about the feedback process will be readily available to the public and notice of the process will be posted on the Commission’s website (www.londontransit.ca) and/or in other appropriate locations.
h. Training
The Commission will ensure that all persons to whom this policy applies receive training as required by the Accessibility Standards for Customer Service. The amount and format of training given will be tailored to suit each person’s interactions with the public and his or her involvement in the development of policies, procedures and practices pertaining to the provision of goods and services.
The content of the training will include:
- a review of the purposes of the AODA;
- the requirements of the Accessibility Standards for Customer Service (Ontario Regulation 429 / 07);
- instruction on the Commission policies, procedures and practices pertaining to the provision of goods and services to persons with disabilities;
- how to interact and communicate with persons with various types of disabilities;
- what to do if a person with a particular type of disability is having difficulty accessing the Commission services;
- how to interact with persons with disabilities who use assistive devices or who require the assistance of a support person or service animal; and
- information about the equipment or devices available on the Commission premises that may help with the provision of the services to persons with disabilities.
Timeline for Training
The various training requirements are addressed through a variety of programs/initiatives using a variety of training approaches. Such training has and/or is provided as soon as reasonably practicable based upon an individual being assigned the applicable duties as well as on an ongoing basis as changes occur to the applicable Commission policies, procedures and practices governing the provision of services to persons with disabilities.
Records of Training
The Commission will keep records of the training, including the date on which training is provided and the number of individuals to whom it is provided. The names of individuals trained will be recorded for training administration purposes, subject to the Municipal Freedom of Information and Protection of Privacy Act (“MFIPPA”).
6. Availability and Format of Documents Required by the Accessibility Standards for Customer Service (Ontario Regulation 429/07)
Recognizing its responsibility under various Federal and Provincial legislation, and the Commission’s intent to fulfill its mandate in an open and accessible manner, the Commission supports the principles with respect to freedom of access to information and protection of personal information, as defined in the National Standard of Canada Model Code for the Protection of Personal Information (Can/CSA 830-96). The principles cover the areas of:
- Accountability
- Identifying purposes of collection
- Obtaining consent
- Limiting collection to the purposes required
- Limiting use, disclosure and retention of personal information to that reasonably related to the stated purpose of collection
- Accuracy in collecting and maintaining records
- Safeguarding the information collected
- Being open
- Providing individual access
- Addressing challenges regarding
Further the Commission designates the General Manager as being accountable on behalf of the Commission for the implementation of these principles in all aspects of the Commission’s functions.
All documents required by the Accessibility Standards for Customer Service, including the Commission’s Accessible Customer Service policies, procedures and practices,
notices of temporary disruptions, training records, and written feedback process are available upon request, subject to MFIPPA.
When providing a document to a person with a disability, the Commission will provide the document, or the information contained in the document, in a format that takes the person’s disability into account.
7. Notice of the Availability of Documents
Notice of the availability of all documents required by the Accessibility Standards for Customer Service will be posted on the Commission’s website, and available through the General Manager’s office.
8. Training of Agents
Responsibility for training of independent contractors, selling the Commission’s fare media is assessed as attached to the individual organization versus the Commission. The position recognizes the independence of the contractors, noting the selling of fare media is not an integral or essential part of the contractor’s business and as such LTC does not exercise control over such businesses, the manner in which they conduct their business, nor in the training and monitoring of employees
9. Supporting or Linked Policy/Procedure Documents
- Standing Operating Procedures – Conventional Transit Services
- Specialized Transit Services – Policies and Procedures
- Commission Fare Policy/Program
- London Transit Commission – Privacy Policy
- London Transit Commission – Purchasing Policy
- London Transit Commission – Mutual Respect Policy
- London Transit Commission – Policy Respecting Ontario Human Rights
10. Link to Other AODA Standards
The Customer Service Standard policy statement herein described is subject to review and amendment from time to time as other common and sector specific standards developed under the AODA come into force.