Employer Requirements for the AODA Customer Service Standard

Businesses need to comply with 11 specific requirements and Clear Path can help!
Remember that the Customer Service Standard is the first of five standards.

Requirement #1

Establish policies, practices & procedures on providing goods or services to people with disabilities

Note: Businesses with over 20 employees have additional requirements:
  • Policies must be available to the public (and provided in a way that takes into account the nature of a person's disability)
  • Staff training must be documented for the public, including a summary of its content and records kept of dates and attendees.

Details

  • Policies are what you intend to do, including rules for staff
  • Practices are how you will go about it
  • Procedures are what you actually do on a day-to-day basis ​
  • The Act allows each company to decide what steps they are able to take to make their goods and services more accessible

Examples

  • A clothing store with change rooms that are too small for a support worker or not accessible for a wheelchair may alter its return policy for those with disabilities
  • A blind customer may need a staff person to read their bill or product details to them
  • A person with severe arthritis may not be able to stand in a long line at the cash register. Staff may offer that person a chair and help them when it is their turn in line

Requirement #2

Use reasonable efforts to ensure that your policies, practices & procedures are consistent with the core principles of:
  • Dignity
  • Independence
  • Integration &
  • Equality of Opportunity

Sometimes the principles need to be balanced in order to achieve the outcome that meets the needs of the person with a disability.

Details

Dignity
  • Service is provided in a way that allows person with disability to maintain self-respect and the respect of other people
  • Provider treats them as customers and clients who are as valued and as deserving of effective and full service as any other customer
  • Do not treat people with disabilities as an afterthought or force them to accept lesser service, quality or convenience

Examples


  • A person with a disability is asked for identification. He slowly and carefully pulls out his wallet. The individual at the counter offers him assistance. When he indicates that he does not require help, the individual at the counter does not rush him and allows the line behind him to get longer because of the delay 
  • By respecting his wishes and not interfering with the man's efforts to get his wallet and ID on his own, the organization is respecting the dignity of this person 
Independence
  • Allowed to do things on their own without unnecessary help or interference, freedom to make their own choices without control or influence of others or to do things in their own way
  • Even if a support person is present, speak and address the person with the disability
  • People who may move or speak more slowly should not be denied an opportunity to participate in a program or service because of this factor
  • A staff person should not hurry them or take over a task for them if they prefer to do it themselves in their own way
​
  • A person with a developmental disability wishes to get a divorce from his wife. His mother drives him to a lawyer's office and then sits in the waiting area while her son approaches the reception desk to explain why he is there
  • When the client explains that he has an appointment with a lawyer to discuss a divorce, the receptionist ignores him and asks his mother which lawyer he has an appointment with and if it is true that he wants a divorce 
  • By ignoring the client with a disability and instead speaking to his mother, the receptionist has not followed the principle of independence. 
Integration
  • Fully benefit from the same services, in the same place, and in the same or similar way as other customers
  • When necessary, alternate measures should be established in order to accommodate them
  • Alternative measures, rather than integration, might be necessary because the person with a disability requires it or because you cannot provide another option at the time.
  • If you are unable to remove a barrier to accessibility, you need to consider what else can be done to provide services to people with disabilities.
​
  • On-line business provides services only through the Internet and doesn't have a physical location 
  • If its website is fully accessible to customers who use screen readers (software that reads text aloud), its services are integrated as customers with low vision are able to access its goods in the same way as other customers
  • If website is not accessible to customers who use screen readers, but company makes its telephone customer service centre available to assist customers who have vision disabilities make purchases and review merchandise, it is providing an alternative measure to integration
Equality of Opportunity
  • Have the same chances, options, benefits and results as others
  • Should not have to make significantly more effort to access or obtain service
  • They should also not have to accept lesser quality or more inconvenience
  • Sometimes this may mean that you have to treat individuals slightly differently so that they can benefit fully from your services
​
  • A bakery advertises its products available for sale through visual displays 
  • If its staff fail to assist people with vision disabilities to understand the variety of products available, they are preventing people with disabilities from having as much information as other customers who benefit from seeing a list of products. The bakery is not acting in accordance with the principle of equal opportunity

Requirement #3

Set a policy on allowing people to use their own personal assistive devices to access your goods and use your services and about any other measures your organization offers

Details

Allow people to use their own personal assistive devices to access your goods and use your services,  including:
  • Walker
  • Wheelchair
  • TTY
  • Cane
  • Hearing aid
  • Amplifying system
  • Magnifying glass
  • Scooter with a basket

Considerations

  • Businesses may invest in assistive devices for customers to use (ex. walkers, wheelchairs), but are not mandated to do so
  • The Customer Service Standard does not require your premises to be wheelchair accessible (must offer alternative service options)

Requirement #4

Communicate with a person with a disability in a manner that takes into account his or her disability

Details

Some options:
  • Staff member read out material
  • Large print and/or Braille
  • Simplified explanations
  • Video or audio
  • Speaking slowly

Considerations

  • Consider the impact of providing individuals with written, video or audio formats of your intellectual property or sensitive information. Such material can be shared with others
  • Standard marketing and product material should not be an issue

Requirement #5

Allow people with disabilities to be accompanied by their guide dog or service animal in areas of the premises that are open to the public, unless animal is excluded by law

Details

Guide dogs and service animals are only allowed where public has access.

In addition to seeing eye dogs, service animals can also be used for people with autism, mental health disabilities, epilepsy, and physical/dexterity issues.

Considerations

  • Questioning the validity of a service animal: If it is not readily apparent to an average, informed person that the animal in question is a service animal, you may request a letter from a doctor or nurse 
  • Ontario Regulation 562 under the Health Protection & Promotion Act  states that animals are not permitted in places where food is manufactured, prepared, processed, handled, served, displayed, sold, or offered for sale. 
  • Exception for guide dogs to allow them where food is normally served, stored, sold, or offered for sale. This does not apply to other service animals. 

Requirement #6

Permit people with disabilities who use a support person, to bring that person with them while accessing goods or services in premises open to the public/3rd parties

Details

Support person can be any person who accompanies a person with a disability in order to help with:
  • Communication
  • Mobility
  • Personal Care or Medical Needs
  • Access to Goods & Services

May be family/friend, no specific qualifications

Considerations

  • Provider may require a person with disabilities to obtain a support person only when necessary to protect the health & safety of the person with the disability or others on the premises (including staff)
  • Support person may have to agree to rules or requirements specific to the kinds of services you provide. Example: sign a confidentiality agreement in a doctor's office 

Requirement #7

Where admission fees are charged, provide notice ahead of time on what admission, if any, would be charged for a support person of a person with a disability

Details

  • Customer Service Standard does not require support persons be admitted for free or reduced fare, if admission is charged
  • However, provider must provide notice in advance of the admission costs for support persons so that persons with disabilities know what to expect
  • Must post signs at ticket booth and should also include this fact on website or posters

Considerations

  • Charging for support person may in effect mean person with disability has to pay twice 
  • However, since support person may be friend/spouse/family member, the expectation of free admission may be unfair to provider 
  • Must be a consistent policy that is consistently applied 

Requirement #8

Provide notice when facilities or services that people with disabilities rely on to access or use your goods or services are temporarily disrupted

Details

  • Examples include: ramp, elevator, automatic door, amplification systems, accessible washrooms, TTY system, staff member who knows sign language
  • As much advanced notice as possible
  • If all services are disrupted for all customers, requirement does not apply

Considerations

  • Notice of disruption must include: 
    • Reason for the disruption 
    • Anticipated duration
    • Description of alternative facilities or services (if any)
    • Should be in a conspicuous location (as well as on website)  

Requirement #9

Train staff, volunteers, contractors & any other people who interact with the public or other 3rd parties on your behalf

Details

Who must get trained?
  • Every person who deals with the public
  • Includes employees, volunteers, and agents
  • New staff must be trained as soon as it is “practicable”

Considerations

  • Format unspecified, may be in written brochure, classroom setting, on-the-floor training, etc. 
  • Documentation of training for businesses with 20+ employees 

Requirement #10

Train those involved in developing your policies, practices and procedures

Details

  • Board members
  • Executives who may not have regular contact with the public

Considerations

  • Encourage policy makers to review your company's level of accessibility on an ongoing basis and whenever a change occurs in the way you offer your good & services 

Requirement #11

Establish a process for people to provide feedback on how you provide goods or services to people with disabilities

Details

Establish a process for people to provide feedback on how you provide goods or services to people with disabilities:
  • In person
  • By telephone
  • In writing
  • By delivering a text or email

Considerations

  • Explain how you will respond to any feedback and take action on any complaints. Specify actions you are going to take if a complaint is received 
  • Standard does not require a response be provided to all feedback 
  • Don't say "we'll do whatever it takes..." since you may not be able to meet all requests