Purpose

This document is the policy and related procedure that will guide Robins Appleby LLP and Talmadge Creek Realty Corp. (together the “Firm”) to make all of the programs and services it offers to the public accessible to Ontarians with disabilities.

This document contains the information that the Firm must provide to meet its obligation under the Accessibility Standards for Customer Service (O. Reg. 429/07) (the “Regulation”) made under the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c.11 (“AODA”).

Compliance

Everyone providing services on behalf of the Firm, including but not limited to all employees, lawyers, volunteers, and third party individuals and entities who deal with the public on the Firm’s behalf are bound by the policy and procedures in this document. These individuals and entities are hereafter referred to as “Service Providers”.

Multi-year accessibility plan

The Firm is committed to ensuring equal access and participation for people with disabilities. We are committed to treating people with disabilities in a way that allows them to maintain their dignity and independence. We are committed to meeting the needs of people with disabilities in a timely manner.

Ongoing Initiatives

In fulfilling its commitment to follow best practices in relation to communication and information strategies, the Firm has:

  • Notified the public regarding the feedback process that is available on its website, effective January 1, 2015
  • Notified the public that accessible formats and communication support are available on its website, effective January 1, 2015
  • Provided information to all staff regarding the availability of communications in accessible formats
  • Completed this initiative by January 1, 2016

Accessible Websites and Web Content

The Firm will ensure that all websites and web content comply with the World Wide Web Consortium (W3C) Web Content Accessibility Guidelines (WCAG) 2.0 at Level A and increasing to Level AA.

    The Customer Service Policy

    This Customer Service Policy (the “Policy”) sets procedures that will help all of the Firm’s Service Providers understand the different needs that some customers with disabilities (as defined under section 2 of the AODA may have and their responsibility to find appropriate ways to help them access our services. Services will be provided in a manner that respects the dignity and independence of persons with disabilities.

    We commit that our policy and procedures meets or exceed the duties and responsibilities required under the Regulation through the following practices:

    Training

    We will provide training on the Policy and the Regulation to all of the Firm’s Service Providers as soon as can be reasonably expected after their hiring or engagement. The primary reason for this training is to create awareness and to ensure compliance with the Policy and the Regulation. Training will be on an ongoing basis as changes occur to the Policy and/or to the Regulation. Training will be provided and materials will be reviewed from time to time to ensure it remains current with current best practices and in compliance with the Regulation.

    Service Providers existing prior to this Policy coming into effect will receive training on the Policy as soon as training can be reasonably performed.

    The training includes but is not limited to:

    1. why the AODA was implemented;
    2. the requirements of the Regulation;
    3. how the Policy and its procedures and practices direct the provision of services to persons with disabilities;
    4. how to interact and communicate with persons with a range of disabilities;
    5. how to handle situations where a person with a disability has difficulty accessing the Firm’s services;
    6. how to interact with persons with disabilities who use assistive devices or require assistance from a support person or service animal; and
    7. the equipment or devices available on the Firm’s premises that may help serve persons with disabilities.

    The Human Resources Manager will maintain written training records.

    Billing

    We are committed to providing accessible invoices to all of our clients. For this reason, invoices will be provided in the following formats upon request: hard copy, large print and e-mail.

    We will answer any questions our clients may have about the content of the invoice in person, by telephone or e-mail.

    Service Animals and Support Persons

    A person with a disability is welcome to enter the Firm’s premises with a service animal. Access by a service animal may be excluded from certain areas of the Firm’s premises where such exclusion is permitted by law. In such rare cases that a service animal is excluded, the onus falls on the Firm to provide other appropriate measures to enable the person with the disability to obtain, use or benefit from the services of the Firm.

    • Section 4(9) of the Regulation states that an animal is a service animal if (1) it is readily apparent that the animal is being used for reasons related to a person's disability; or (2) if the person provides a letter from a doctor or nurse confirming that the animal is required for reasons relating to the disability.
    • Staff will receive training to identify support persons who may be a paid professional, volunteer, family member or friend who accompanies a person who requires help with communication, mobility, personal care, medical issues or to access goods and services.

    Procedures for Support Persons

    A person with a disability is entitled to attend at our firm with his or her support person in all areas where the public or third parties are permitted and/or served. At no time will a person with a disability who is accompanied by a support person be prevented from accessing his or her support person.

    Subsection 4(5) of the Regulation states that we retain the right to require a person with a disability to be accompanied by a support person when on the premises, but only if a support person is necessary to protect the health or safety of the person with a disability or the health or safety of others on the premises.

    Exercise of this authority must be based on clear evidence of a hazard to the person with the disability or others, if unaccompanied.

    If no support person is available, the manager or designate must determine whether there is an acceptable alternative. (One alternative may be to assign a member of the Accessibility Standards for Customer Service Provider team to accompany the person with a disability). Another option may be to reschedule services when appropriate arrangements can be made.

    The provision of our services often includes the private disclosure of personal information and legal advice, which would ordinarily be protected from disclosure to others by lawyer/client privilege. While we treat all such communication to be subject to lawyer/client privilege, that privilege might not exist if a support person is present during the communication, with the result that any person present could be compelled to disclose the information or advice in court proceedings.

    Procedures for Assistive Devices

    All appropriate measures will be taken to provide services to persons with disabilities who use assistive devices. We will inform clients of the availability of assistive devices on our website. Accommodations can be made. However, please note that some accommodations may require more notice and we would ask that clients advice us of their needs in advance. Any devices provided by the Firm on the premises will be in good repair and kept on a regular maintenance schedule.

    Service Providers will not operate or otherwise interfere with a person's personal assistive device unless invited to do so by the person or his/her support person. As an example, we will not move a wheelchair or cane without permission.

    Training will be provided to enough staff members to ensure there is always someone who is familiar with the operation of any device(s) provided by the Firm on the premises. Training will cover use of each assistive device, correcting common issues, how to reset devices and the use of any security features associated with them such as passwords or security cards.

    Notice of Temporary Disruptions

    We will endeavour to provide notice of temporary disruptions to service or facilities used by persons with disabilities including the reason(s) for the disruption. When the disruption is planned, we will endeavour to provide advance notice.

    Our staff will be trained to deal with emergency procedures and will know the most appropriate ways to assist clients or staff who need assistance during an emergency.

    Temporary service disruptions affecting the Firm’s provision of services will be communicated by the following:

    1. Physical facility service interruptions to; washrooms, elevators, doors, entrances, and corridors, will be communicated by notices posted at the location of the service disruption.
    2. Service or program closures or shortened hours caused by severe weather, disease outbreak and mechanical difficulties (e.g. a power outage) will be posted on the firm’s website and communicated by a general voice message at the Firm’s regular phone number.
    3. Notices will give the reason for the disruption, the expected duration, if known, and describe possible alternatives.
    4. Notices will be posted in prominent locations, such as public entrances, information and reception desks, on the website and any other reasonable location that suits the circumstances.
    5. We will endeavour to provide information related to temporary disruption of local services (such as washrooms, elevators) in person and by telephone.
    6. Reception staff will provide information about temporary service interruptions. If requested and if available, a staff member will guide the person to an alternate service, if available.

    Employment Practices

    The Firm is committed to providing fair and accessible employment practices. We will accommodate people with disabilities during the recruitment and assessment processes and when people with disabilities are hired.

    The Firm develops an individual accommodation and return-to-work plan for firm members who have been absent from work due to a disability and require accommodation upon their return.

    Workplace individual emergency response information

    On learning of an employee’s needs, the Firm works with the employee to create an individualized emergency response plan. With consent, we share this information with those responsible for helping in emergencies.

    We review individualized emergency response plans whenever the employee moves to a different location, overall accommodation needs or plans are reviewed and we review our general emergency response policies.

    Informing employees of supports

    The Firm is committed to fair and accessible employment practices. The Firm will notify the public and staff that, when requested, it will accommodate individuals with disabilities during the recruitment and assessment processes and when they are hired;

    The Firm will develop and put in place a process for developing individual accommodation plans for employees with disabilities;

    The Firm will develop and put in place a return to work process for employees who have been absent from work due to a disability and require disability-related accommodations in order to return to work; and

    The Firm will ensure the accessibility needs of employees with disabilities are taken into account if using performance management, career development and advancement, or redeployment processes.

    The Firm will also take reasonable steps to prevent and remove other accessibility barriers that are identified.

    Recruitment, assessment and selection

    In recruiting new employees, the Firm notifies potential applicants that we accommodate applicants with disabilities. On request, we will provide accommodation appropriate to the applicants’ accessibility needs.

    Feedback

    We welcome your comments and feedback on this Policy which can be provided on our website at www.robinsappleby.com. We will also note comments and feedback provided in person, in writing, online, by telephone, or any other means.

    Anyone with a complaint, question, concern or compliment about the Policy may contact the Firm’s Director of Administration, Raili O’Born, who can be reached at roborn@robapp.com, (416) 868-1080.

    We will acknowledge your correspondence and will provide a written response within fourteen (14) business days of receiving your correspondence.

    This Policy is available in large print format, upon request, to accommodate persons with visual disabilities.

    Policy Review 

    This policy was last updated March 1, 2023 and will be reviewed annually.