The Accessibility Standards for Customer Service under the Accessibility for Ontarians with Disabilities Act (AODA) require employers to provide accessible customer service to persons with disabilities. In order to comply with the legislation, all businesses and organizations providing goods or services to the public with at least one employee in Ontario must meet several requirements by January 1, 2012. These include:
- Establishing policies and procedures relating to the provision of goods and services to persons with disabilities, including persons using service animals or accompanied by a support person
- Developing alternative modes of communication with persons with disabilities
- Developing a process to notify customers of a disruption in service
- Providing training to all staff who participate in the development of customer service policies and procedures or deal with members of the public pertaining to the AODA and its requirements, including how to use assistive devices on the premises, what to do if a person with a disability is having difficulty accessing goods or services and how to interact with persons with disabilities who use assistive devices, support persons and service animals
- Developing a process for receiving and responding to feedback about the manner in which the organization provides goods and services to persons with disabilities
- Where the employer or organization has more than 20 employees, documenting actions related to the standards and filing an accessibility report with the Government of Ontario
Failure to meet these requirements by January 1, 2012, may result in significant monetary penalties.
What we gathered at our most recent AODA seminar is that employers are very concerned about the training aspect of the customer service obligations.
Customer service training must include:
- The purpose of the Accessibility for Ontarians with Disabilities Act and Regulations
- The purpose and requirements of the Accessibility Standards for Customer Service
- How to interact and communicate with people with various types of disabilities
- How to interact with people with disabilities who use an assistive device or require the assistance of a service animal or support person
- How to use the assistive devices available or made available at your organization for use by people with disabilities
- What to do if a person with a disability is having difficulty accessing your organization’s goods and services, including asking the person how he or she can be accommodated and what alternative methods of service provision would be more accessible
- Your organization’s policies, practices and procedures relating to the provision and access of goods and services to the public and other third parties
Training must be provided to all current and new staff that deal with members of the public or other third parties, whether the person is an employee, agent, volunteer or otherwise. Organizations should further ensure that every person who participates in developing the organization’s policies, practices and procedures governing the provision of goods or services to members of the public or other third parties receives training.
Training must be ongoing, for example, when there are changes to your policies, practices and procedures dealing with the provision and access of goods and services, including changes to the law.
Every designated public sector organization and every other provider of goods or services that has at least 20 employees in Ontario shall keep records of the training provided, including the dates on which the training is provided and the number of individuals to whom it is provided.
We recommend that all organizations (no matter the size) keep records of training that include the training occurrence dates for each staff member and the number of people receiving training. Organizations are responsible to ensure all new staff members are trained and to monitor compliance with training requirements under the AODA.
But how do you train?
The customer service standard does not state how the training should be provided. It could be a separate training program specifically about customer service for people with disabilities, or part of a larger training program as part of orientation. The training could be provided through handouts at an orientation session, through a mandatory online module, in a classroom setting, or in other formats. The law leaves it to the organization to decide how they deliver training as long as they meet the above requirements. The information that needs to be communicated to staff is straightforward enough that it should not be a burdensome process.
Here are certain elements you should consider.
Consider who must be trained: Training must be given to everyone in your organization who deals with members of the public or other third parties (other organizations) as well as to others who deal with members of the public or other third parties on your behalf. Determining which employees to train should not just be based on a person’s job description. It should be based on what the person does in practice on a regular basis. For example, training could apply to people who provide directions to customers, whether in person or over the phone, complete orders over the Internet, deal with billing information (account receivable and payable), answer questions or feedback, and give any type of information about your goods or services. This also includes management and senior leaders of an organization, even though they may not be directly involved in providing goods or services to people with disabilities. If they direct, monitor or evaluate policies on how goods or services are provided, it is important that they too understand those areas that must be covered in the training.
Determine the content of training: Training content might vary depending on who is receiving the training and the nature of your services and your organization. For example, web development staff, senior management and policy staff each might have unique training needs. Training provided to staff who deal with the public could focus more on person-to-person interaction than the training provided to staff who have less contact with customers. Each provider can choose the particular content of the training and the way each of the topics is addressed.
Decide on the format of training: Providers should decide on a training format that is appropriate for them and that reflects the needs of the people being trained. It can be formal or informal. Training could be provided through workbooks, videos, handouts such as fact sheets or brochures at an orientation session, through a mandatory online module, in a classroom setting or in another format. Training could be delivered as a separate program specifically about providing goods or services to people with disabilities or as part of a larger training program, such as basic orientation, training on effective communication or general customer service.
Determine the timing of training: Provide training to all applicable staff by the date that you are required to comply with the standard. As training should include information on your policies, procedures and practices, these will have to be developed before training can take place. Providers will therefore need to begin developing policies, practices, procedures and related training with enough advance time to carry out training prior to the required compliance date. The standard requires that training must be provided “as soon as practicable”, or as soon as it can be done in the circumstances, after someone is assigned to the applicable duties. Training must also be ongoing, so when someone new is hired, or is assigned duties for which training is required, they need to be trained as soon as practicable. When your policies, practices or procedures change in any significant way, training will need to be carried out in relation to these changes.
Note that the AODA customer service training you have received as a manager, human resources professional and employer in the last months can be used and adapted to train your staff. All you need to do is include the actual policies, practices and procedures you have developed.
It is strongly recommended that any training include a final quiz designed to test knowledge and understanding of rights and obligations by all staff. Also, have employees sign an attendance document at the end of each training session.
Yosie Saint-Cyr
First Reference Human Resources and Compliance Managing Editor
Marie-Yosie Saint-Cyr, LL.B. Managing Editor
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Great overview of the legal requirements, Yosie! As a provider of AODA training I would like to say that this overview will serve any organization well when planning for this mandatory training. A great source of information for the customer service component are organizations that provide services to persons with disabilities such as the Canadian National Institute for the Blind (CNIB).