Accessible Customer Service Policy

Intent

This policy is intended to meet the requirements of Accessibility Standards for Customer Service, Ontario Regulation 429/07 under the Accessibility for Ontarians with Disabilities Act, 2005, and applies to the provision of services to the public or other third parties, not to the goods themselves.

All services provided by Bennett Grant LLP (formerly Madorin, Snyder LLP) shall follow the principles of dignity, independence, integration and equal opportunity.

Scope

a) This policy applies to the provision of services at premises operated by Bennett Grant LLP.

b) This policy applies to employees and volunteers who deal with the public or other third parties on behalf of Bennett Grant LLP, including when the provision of services occurs off the premises of Bennett Grant LLP.

c) The section of this policy that addresses the use of guide dogs, service animals and service dogs only applies to the provision of services that take place at premises operated by Bennett Grant LLP.

Definitions

Assistive Device – is a technical aid, communication device or other instrument that is used to maintain or improve the functional abilities of people with disabilities. Personal assistive devices are typically devices that clients bring with them such as a wheelchair, walker or a personal oxygen tank, that might assist in hearing, seeing, communicating, moving, breathing, remembering and/or reading.

Disability – the term disability as defined by the Accessibility for Ontarians with Disabilities Act, 2005, and the Ontario Human Rights Code, refers to:

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 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.

Guide Dog – is a highly-trained working dog that has been trained at one of the facilities listed in Ontario Regulation 58 under the Blind Persons’ Rights Act, to provide mobility, safety and increased independence for people who are blind.

Service Animal – as reflected in Ontario Regulation 429/07, an animal is a service animal for a person with a disability if:

it is readily apparent that the animal is used by the person for reasons relating to his or her disability; or
if the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disability.

Service Dog – as reflected in Health Protection and Promotion Act, Ontario Regulation 562 a dog other than a guide dog for the blind is a service dog if:

it is readily apparent to an average person that the dog functions as a service dog for a person with a medical disability;
or the person who requires the dog can provide on request a letter from a physician or nurse confirming that the person requires a service dog.

Support Person – as reflected in Ontario Regulation 429/07, a support person means, in relation to a person with a disability, another person who accompanies him or her in order to help with communication, mobility, personal care, medical needs or access to services.

General Principles

In accordance with the Accessibility Standards for Customer Service, Ontario Regulation 429/07, this policy addresses the following:

A. The Provision of Services to Persons with Disabilities;
B. The Use of Assistive Devices;
C. The Use of Guide Dogs, Service Animals and Service Dogs;
D. The Use of Support Persons;
E. Notice of Service Disruptions;
F. Client Feedback;
G. Training; and
H. Notice of Availability and Format of Required Documents.

A. The Provision of Services to Persons with Disabilities

Bennett Grant LLP will make every reasonable effort to ensure that its policies, practices and procedures are consistent with the principles of dignity, independence, integration and equal opportunity by:

ensuring that all clients receive the same value and quality;
allowing clients with disabilities to do things in their own ways, at their own pace when accessing services as long as this does not present a safety risk;
using alternative methods when possible to ensure that clients with disabilities have access to the same services, in the same place and in a similar manner;
taking into account individual needs when providing services; and
communicating in a manner that takes into account the client's disability.

B. Assistive Devices

Client’s own assistive device(s):

Persons with disabilities may use their own assistive devices as required when accessing services provided by Bennett Grant LLP. If we receive appropriate notice, we will make arrangements to accommodate any requirements for assistive devices for use within our office at the time of a client's visit.

In cases where the assistive device presents a safety concern or where accessibility might be an issue, other reasonable measures will be used to ensure the access of services. For example, where elevators are not present and where an individual requires assistive devices for the purposes of mobility, service will be provided in a location that meets the needs of the client.

C. Guide Dogs, Service Animals and Service Dogs

A client with a disability that is accompanied by guide dog, service animal or service dog will be allowed access to premises that are open to the public unless otherwise excluded by law. “No pet” policies do not apply to guide dogs, service animals and/or service dogs.

Exclusion Guidelines:

If a guide dog, service animal or service dog is excluded by law (see applicable laws below) Bennett Grant LLP will offer alternative methods to enable the person with a disability to access services, when possible (for example, securing the animal in a safe location and offering the guidance of an employee).

Applicable Laws:

Dog Owners' Liability Act, Ontario: If there is a conflict between a provision of this Act or of a regulation under this or any other Act relating to banned breeds (such as pitbulls) and a provision of a by-law passed by a municipality relating to these breeds, the provision that is more restrictive in relation to controls or bans on these breeds prevails.

Recognizing a Guide Dog, Service Dog and/or Service Animal:

If it is not readily apparent that the animal is being used by the client for reasons relating to his or her disability, Bennett Grant LLP may request verification from the client. Verification may include:

a letter from a physician or nurse confirming that the person requires the animal for reasons related to the disability;
a valid identification card signed by the Attorney General of Canada; or,
a certificate of training from a recognized guide dog or service animal training school.

Care and Control of the Animal:

The client that is accompanied by a guide dog, service dog and/or service animal is responsible for maintaining care and control of the animal at all time.

Allergies:

If a health and safety concern presents itself for example in the form of a severe allergy to the animal, Bennett Grant LLP will make all reasonable efforts to meet the needs of all individuals.

D. Support Persons

If a client with a disability is accompanied by a support person, Bennett Grant LLP will ensure that both persons are allowed to enter the premises together and that the client is not prevented from having access to the support person.

In situations where confidential information might be discussed in the presence of a support person, a signed consent must be obtained from the client prior to any conversation where confidential information might be discussed.

E. Notice of Disruptions in Service

Service disruptions may occur due to reasons that may or may not be within the control or knowledge of Bennett Grant LLP. In the event of any temporary disruptions to facilities or services that client's with disabilities rely on to access or use Bennett Grant LLP's services, reasonable efforts will be made to provide advance notice. In some circumstances such as in the situation of unplanned temporary disruptions, advance notice may not be possible.

Notifications will Include:

In the event that a notification needs to be posted the following information will be included unless it is not readily available or known:

services that are disrupted or unavailable
reason for the disruption
anticipated duration
a description of alternative services or options

Notifications Options:

When disruptions occur Bennett Grant LLP will provide notice by:

posting notices in conspicuous places including at the point of disruption, in the elevator lobby on the main floor and the nearest accessible entrance to the service disruption and/or on the Bennett Grant LLP website;
contacting clients with appointments;
verbally notifying clients when they are making a reservation or appointment; or
by any other method that may be reasonable under the circumstances.

F. Feedback Process

Bennett Grant LLP shall provide clients with the opportunity to provide feedback on the service provided to clients with disabilities. Information about the feedback process will be readily available to all clients and notice of the process will be made available on our website, by completion of the Customer Service Feedback Form and remittance by e-mail to the Administration Manager. Feedback forms along with alternate methods of providing feedback such as verbally (in person or by telephone) or written (hand written, delivered, website or email), will be available upon request from Reception.

Submitting Feedback:

Clients can submit feedback to:

Stephen R. Grant, Managing Partner
519-744-4491
P O Box 1234, 55 King Street West
Kitchener, ON N2G 4G9
sgrant@kw-law.com

Clients who wish to provide feedback by completing an onsite client feedback form can do so by requesting a form from Reception at Bennett Grant LLP.

Clients that provide formal feedback will receive acknowledgement of their feedback within 72 hours, together with any resulting actions based on concerns or complaints that were submitted.

G. Training

Training will be provided to all employees and volunteers who deal with the public or other third parties on behalf of Bennett Grant LLP during their initial orientation and when the plan is amended in the event of changes to legislation, procedures and/or practices.

Training Provisions:

As reflected in Ontario Regulation 429/07, regardless of the format, training will cover the following:

A review of the purpose of the Accessibility for Ontarians with Disabilities Act, 2005.
A review of the requirements of the Accessibility Standards for Client Service, Ontario Regulation 429/07.
Instructions on how to interact and communicate with people with various types of disabilities.
Instructions on how to interact with people with disabilities who:
use assistive devices;
require the assistance of a guide dog, service dog or other service animal; or
require the use of a support person
Instructions on how to use equipment or devices that are available at our premises or that we could provide that may help people with disabilities.
Instructions on what to do if a person with a disability is having difficulty accessing your services.
Bennett Grant LLP's policies, procedures and practices pertaining to providing accessible client service to clients with disabilities.

Record of Training:

Bennett Grant LLP will keep a record of training that includes the dates training was provided and the number of employees who attended the training.

Notice of Availability and Format of Documents:

Bennett Grant LLP shall notify clients that the documents related to the Accessibility Standard for Customer Service are available upon request and in a format that takes into account the client's disability. Notification will be given by posting the information in Reception at the facilities operated by Bennett Grant LLP, our website and/or any other reasonable method.

Administration

If you have any questions or concerns about this policy or its related procedures please contact:

Sarah Tangney, Administration Manager
519-744-4491
55 King Street West, P O Box 1234
stangney@kw-law.com

This policy and its related procedures will be reviewed as required in the event of legislative changes.

Referenced Documents

Accessibility for Ontarians with Disabilities Act, 2005

Accessibility Standards for Customer Service, Ontario Regulation 429/07

Blind Person’s Rights Act, 1990

Dog Owners' Liability Act, Ontario

Food Safety and Quality Act 2001, Ontario Regulation 31/05

Ontario Human Rights Code, 1990