Intent
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
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
Act, 2005;
- 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.
Review
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.
Websites
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.
