The Accessibility for Ontarians with Disabilities Act, 20015 (AODA) is a Provincial Act with the purpose of developing, implementing and enforcing accessibility standards in order to achieve accessibility for people with disabilities and others with accessibility needs.  

The AODA mandates five standards in the following areas:

  • Customer Service
  • Employment
  • Information and Communications
  • Design of Public Spaces
  • Transportation

This plan outlines the policies and actions that GroupBy Inc. (“GroupBy”) will put in place to improve opportunities for people with disabilities in accordance with the requirements communicated under the Integrated Accessibility Standards, Ontario Regulation 191/11.

Statement of Commitment

GroupBy exists to solve the tough problems in e-commerce: we work with the biggest players in the industry and take on their more complex challenges. We’ve built a cloud-based, data-driven e-commerce platform for product data enrichment, intelligent search, personalization, analytics, and other building blocks of a great online shopping experience. We solve these problems by surrounding ourselves with people who love what they do and are given the freedom to excel at it. Our team is comprised of passionate, innovative thinkers who work together to create groundbreaking products. We like working with awesome people and we like helping these people become even better.

At GroupBy treating our employees and our clients in a way that respects dignity and independence is crucial to our success. We know that over 15% of the population has a disability and even more people have accessibility needs. Disabilities can be sensory, physical or cognitive, visible or invisible.  No matter what the need, GroupBy is committed to serving our clients and treating our employees in the best and most inclusive way possible. We endeavor to communicate and provide our services in a manner that is inclusive to everyone and which takes peoples’ accessibility needs into account in all of our activities.

GroupBy believes in equal opportunity and is committed to providing a barrier-free environment that allows all people to maintain their independence and dignity. As an organization, we respect and uphold the requirements set forth under the Accessibility for Ontarians with Disabilities Act (2005) and its associated Regulations and strive to meet the needs of individuals with disabilities in a timely and effective manner. Any policy of GroupBy that does not respect and promote the dignity and independence of people with disabilities will be modified or removed.

General Definitions:

Accessible Formats: include, but are not limited to accessible electronic formats, Braille, text transcripts, large print, recorded audio, colour contrasts, and other formats accessible to persons with disabilities.

Assistive Device: 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 people 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.

Barrier: as defined by the Ontarians with Disabilities Act, 2001, anything that prevents a person with a disability from fully participating in all aspects of society because of his/her disability. This includes:

  • Physical barriers,
  • Architectural barriers,
  • Informational or communications barriers,
  • Attitudinal barriers,
  • Policy, practice or procedure barriers

Communication Supports: include but are not limited to sign language, plain language, closed captioning and other communication supports that facilitate effective communications.

Disability: a key feature of the AODA is its definition of "disability". Under the AODA, the definition of "disability" is the same as the definition in the Ontario Human Rights Code [2]:

Any degree of physical disability, infirmity, malformation or disfigurement including, but not limited to:

  • Diabetes mellitus;
  • Epilepsy;
  • A brain injury;
  • Any degree of paralysis;
  • Amputation;
  • Lack of physical coordination;
  • Blindness or visual impediment;
  • Deafness or hearing impediment;
  • Muteness or speech impediment; or
  • Physical reliance of 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.
  • An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety & Insurance Act, 1997.

Support Persons: any person, whether a paid professional, volunteer, family member of friend, who accompanies a person with a disability to help with communications, mobility, personal care or medical needs while accessing our goods and services.

GroupBy’s Plan to Meet Requirements

I) Best Practices

One of GroupBy’s values is empowerment so we know first-hand how important it is to ensure we provide an inclusive environment and every opportunity to evolve together and lift each other up. We understand that the AODA standards represent the minimum requirements for all public and private sector organizations in Ontario and as such, we take the requirement in section 4 of the IASR to examine how we can prevent and remove barriers for people with disabilities very seriously.  GroupBy commits to examining best practices in the areas of information and communication and incorporating those best practices into our business where appropriate. By using principles of universal design wherever possible, we will be able to deliver on consistent high-quality services to our employees and clients alike.

II) Training

We know that training provides people the tools and resources they need to serve our customers effectively as well as helping our employees develop their skills. GroupBy commits to ensuring all employees are aware of their rights and responsibilities in creating an inclusive environment for people with accessibility needs.

GroupBy’s training meets all requirements of the AODA in the areas of Customer Service, the Integrated Accessibility Standards Regulation and the Ontario Human Rights Code.  Training has been delivered to all employees who deal with clients, the public or third parties on our behalf as well as to people involved in the development of policies, plans, practices and procedures related to the provision of our goods and services.

Training is a requirement for all new hires as part of onboarding when they join GroupBy and will be refreshed on a regular basis.

GroupBy’s AODA training covers:

  • An overview of the AODA and its regulations
  • All requirements of the Customer Service Standard including:
    • 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 a support person
    • What to do if a person with a disability is having difficulty accessing GroupBy’s goods and services
  • Requirements related to information and communications including:
    • The elements of accessible websites
    • Types of accessible formats
    • Colour contract and accessibility
    • Developing accessible documents
  • Requirements of the Employment Standard and GroupBy’s policy, including:
    • Recruitment, assessment and selection 
    • Accessible formats and communications
    • Workplace emergency response information 
    • Documented individual accommodation plans 
    • Return to work
    • Performance management 
    • Career development and advancement 
    • Redeployment 
  • An overview of the Design of Public Spaces and Transportation Standards recognizing that GroupBy’s customers can come from any sector
  • The Ontario Human Rights Code as it relates to people with disabilities
  • Similarities and differences between the AODA and the Ontario Human Rights Code

III) Procurement

GroupBy will endeavor to incorporate accessibility provisions as required into our procurement practices. We understand that when accessibility is used as one of the criteria for purchasing decisions, the outcome will be products and services that that are universally accessible to everyone. Where applicable, our procurement practices may outline the desired accessibility elements to be met.  Examples where accessible procurement may be relevant may include new computer purchases, new software programs, new office equipment, and leasing space.

GroupBy’s Customer Service Policy

GroupBy is committed to excellence in serving all customers including people with disabilities.  GroupBy is committed to providing people with disabilities the same opportunity to access our goods and services in a similar way as other clients. For the purposes of this customer service policy, employee means every person who deals with clients or members of the public on behalf of GroupBy whether the person does so an employee, volunteer, agent or intern.

The Provision of Goods and Services to Persons with Disabilities 

GroupBy commits to ensuring 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 customers receive the same value and quality;
  • Allowing customers with disabilities to do things in their own ways, at their own pace when accessing goods and services, as long as this does not present a health and safety risk;
  • Using alternative methods when possible to ensure that customers with disabilities have access to the same services, in the same place and in a similar manner;
  • Taking into account individual accommodation needs when providing goods and services; and
  • Communicating in a manner that takes into account the customer’s disability.


Training will be provided to: 

  • Every employee of or a volunteer with GroupBy;
  • Every person who participates in developing the policies of GroupBy; and
  • Every other person who provides goods, services, or facilities on behalf of GroupBy

Regardless of the format, employee training will cover the following: 

  • A review of the purpose of the Accessibility for Ontarians with Disabilities Act2005;
  • A review of the requirements of the customer service standards;
  • 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 or other service animal; or
    • Require the use of a support person (including the handling of admission fees);
  • Instructions on how to use equipment or devices that are available at our premises or that we provide that may help people with disabilities;
  • Instructions on what to do if a person with a disability is having difficulty accessing our services; and
  • Policies, procedures, and practices of the company pertaining to providing accessible customer service to customers with disabilities.

The Use of Assistive Devices 

Persons with disabilities may use their own assistive devices as required when accessing goods or services provided by the company. 

In cases where the assistive device presents a health and safety concern or where accessibility might be an issue, other reasonable measures will be used to ensure the access of goods and services, up to the point of undue hardship. 

Alternatively, where elevators are not present and where a customer requires assistive devices for the purposes of mobility, service will be provided in a location that meets the needs of the customer. 

Guide Dogs and Service Animals 

GroupBy welcomes all persons with a disability who is accompanied by a guide dog or service animal on all parts of our premises unless otherwise prohibited by law.

The Use of Support Persons 

If a customer with a disability is accompanied by a support person, GroupBy will ensure that both persons may enter the premises together and that the customer is not prevented from having access to the support person. 

There may be times where seating and availability prevent the customer and support person from sitting beside each other. In these situations, GroupBy will make every reasonable attempt to resolve the issue. 

In situations where confidential information might be discussed, consent will be obtained from the customer before any potentially confidential information is mentioned. 

Notice of temporary disruption

In the event of a planned or unexpected disruption to services or facilities for customers with disabilities including elevator access to second floor offices and accessible washroom facilities, GroupBy will notify customers promptly. This clearly posted notice will include information about the reason for the disruption, its anticipated length of time, and a description of alternative facilities or services, if available.

The notice will be placed at the main reception area.

Notice of Availability and Format of Documents to Customers 

GroupBy shall notify customers that the documents related to the customer service standards are available upon request and in a format that takes into account the customer’s disability. Notification will be given by posting the information in a conspicuous place owned and operated by GroupBy, the website of GroupBy, and any other reasonable method. 

Accessible meetings

Ensuring that our clients are able to participate effectively in meetings is key to our success.  GroupBy commits to ensuring that we provide for high levels of accessibility both in terms of meeting space as well as in the content and proceedings of meetings. 

Feedback process

Our goal is to surpass the expectations of our clients. Comments on how our services are met are appreciated.  Customers who wish to provide feedback on how GroupBy provides 

goods and services to people with disabilities can do so by email or verbally by telephone. 

All feedback, including complaints, will be directed to the Head of People and Culture, Julia Cartwright ([email protected] or 647-880-0334).

Customers can expect to hear back within 10 business days.

GroupBy’s Employment Policy

GroupBy is committed to an accessible and inclusive workplace where all employees are encouraged to excel without being hampered by barriers. For the purpose of the Employment Policy, employees include all paid employees, whether full-time, part-time or seasonal.  Volunteers or other unpaid persons are not covered by the employment standard.

GroupBy recognizes that both Ontario Human Rights Code policies and the AODA have specific requirements related to employment accommodation.  While there is close alignment between the two pieces of legislation, they are not the same.  This policy is specific to AODA Employment Standard requirements

Recruitment, Assessment and Selection 

GroupBy notifies all employees and the public about the availability of accommodation for job applicants who have disabilities. Applicants are informed that these accommodations are available, upon request, for the interview process and for other candidate selection methods. Where an accommodation is requested, the company will consult with the applicant and provide or arrange for suitable accommodations in a manner that takes into account the applicant’s accessibility needs due to disability. 

Successful applicants will be made aware of the company’s policies and supports for accommodating people with disabilities. 

Accessible Formats and Communication Supports for Employees 

GroupBy ensures that employees are aware of policies for employees with disabilities and any changes to these policies as they occur. The company will provide the information required to new employees as soon as practicable after they begin their employment. 

If an employee with a disability requests it, the company will provide or arrange for the provision of accessible formats and communication supports for the following: 

  • Information needed in order to perform their job; and
  • Information that is generally available to all employees in the workplace.

The company will consult with the employee making the request to determine the best way to provide the accessible format or communication support. 

Workplace Emergency Response Information 

Where required, GroupBy will create individualized workplace emergency response plans for employees with disabilities. This information will be created in consultation with the employee 

and take into account the unique challenges created by the individual’s disability and the physical nature of the workplace. 

This information will be reviewed when: 

  • The employee moves to a different physical location in the organization;
  • The employee’s overall accommodation needs or plans are reviewed; or
  • The company reviews general emergency response policies.

Documented Individual Accommodation Plans 

GroupBy will develop and have in place written processes for documenting individual accommodation plans for employees with disabilities. The development process for these plans will include: 

  • The ways in which the employee can participate in the development of the plan;
  • The means by which the employee is assessed individually;
  • The ways that an employer can request an evaluation by an outside medical expert, or other experts (at the employer’s expense) to determine whether accommodation can be achieved, or how it can be achieved;
  • The ways that an employee can request the participation of a representative from their bargaining agent or other representative from the workplace (if the employee is not represented by a bargaining agent) for the creation of the accommodation plan;
  • The steps taken to protect the privacy of the employee’s personal information;
  • The frequency with which the individual accommodation plan should be reviewed or updated and how it should be done;
  • The way in which the reasons for the denial of an individual accommodation plan will be provided to the employee; and
  • The means of providing the accommodation plan in an accessible format, based on the employee’s accessibility needs.

The individual accommodation should also include information regarding accessible formats, communication supports (upon request), individualized workplace emergency response information, and any other accommodation provided. 

Return to Work 

GroupBy will develop and implement return-to-work processes for employees who are absent from work due to a disability and require disability-related accommodations in order to return to work. 

This process will outline the steps the company will take to enable a smooth return to work for the employee. All steps and individual accommodation plans will be documented and created in consultation with the employee. 

Performance Management and Career Changes 

GroupBy will consider the accessibility needs, including documented individual accommodation plans, of employees with disabilities during the company’s performance management process. These will also be considered in the event of redeployment, or when offering career development or advancement opportunities. 


This policy will be reviewed regularly to ensure that it reflects current practices of GroupBy as well as legislative requirements. 

Procedure for an employee requesting an accommodation

The purpose of accommodation is to allow a person to perform the essential duties of the job and to allow for equal participation in the workplace.  The accommodation process will respect confidentiality and privacy.  The accommodation will be collaborative and will involve the requestor.

Requests for accommodation will be formalized according to the following process:

1.01 Employees who wish to raise a potential accommodation issue shall do so by submitting a request for accommodation, preferably in writing, to their immediate manager. The request shall describe, in detail, the accommodation sought to address limitations in performing the essential duties of the job. 

1.02 When necessary to facilitate the assessment and determination of the accommodation, the employee may be required to participate in the development of the accommodation plan and provide relevant medical information to GroupBy such as a functional capacity evaluation. Medical professionals are not required to submit a diagnosis.  The purpose of any medical documentation is to determine the type of accommodation required. Employees seeking accommodation are expected to provide their fullest cooperation in providing any information or medical assessments relevant to determination of the accommodation request. 

1.03 The Head of People and Culture and COO will assess the accommodation issue in light of the information provided and the individual needs of the employee. During the assessment phase, GroupBy reserves the right to require further information, including relevant medical information or opinions that will assist GroupBy to determine if accommodation can be achieved and how it can be achieved. GroupBy further reserves the right to require the employee to participate in a formal needs-assessment by a qualified medical practitioner or other trained professional in order to assist in determining what accommodation is needed, how much it will cost, and how it can be provided.  The costs of any assessment required by GroupBy will be covered by GroupBy.  The employee may request the participation of an employee representative in the development of the accommodation plan.

1.04 The Head of People and Culture and COO will jointly finalize a decision regarding the 

accommodation issue. The manager shall notify the employee in writing or other format as required by the employee’s disability, the decision and the reason(s) for the decision.

1.05 If the employee is not satisfied with the written decision regarding the request for accommodation, the employee may appeal the decision to the Head of People and Culture for further review. The decision of the Head of People and Culture shall be final and binding upon the parties.

1.06 GroupBy shall ensure that the employee’s personal information shall be kept confidential and only disclosed to those necessary in the assessment and development of the accommodation in accordance with SPP 5.07.ON – Personal Information Protection.

1.07 All complaints regarding GroupBy’s accessibility and accommodation plan will be brought to the Head of People and Culture at GroupBy. Each complaint will be addressed individually and followed up on in writing within seven business days.

GroupBy’s Information and Communications Policy

Alternate Formats

At GroupBy, we will ensure that we provide information and communications to our customers and the public in alternate formats upon request and in a timely manner.  Depending on the situation this may include, and is not limited to:

  • Large print
  • Braille 
  • Audio 
  • Closed captioning, 
  • High colour contrast 
  • American Sign Language
  • Text transcription of audio or visual information
  • Information written in plain language
  • An electronic format formatted to be accessible for use with a careen reader

In determining an appropriate format, we commit to consulting with the requestor.

This policy does not apply to information that is not controlled directly by GroupBy, or information or communications that cannot be converted.


GroupBy is committed to achieving the Worldwide Consortium Accessible Guidelines (WCAG) as outlined in section 14 of the Integrated Accessibility Standards Regulation.  Accessible websites will ensure that all of our clients and the public will have access to our groundbreaking work and thought leadership.

Emergency Information

GroupBy will work with building management to ensure that accessibility is considered in emergency procedures and that alternate formats are provided upon request.

GroupBy’s Design of Public Spaces

GroupBy is not an organization generally open to the public.  Areas when our clients or others may visit are our reception area, common space and meeting rooms. We will strive to ensure that we meet principles of universal design all of our meeting or reception areas and implement the AODA design requirements for any planned renovations to relevant areas.  

In order to serve our clients effectively, we will endeavor to make them aware of universal design and accessible features when planning events.