Approval Date: May 13, 2021
PRA Group Canada Inc. (PRA or the “Company”) is fully committed to adhering to all applicable legislation and regulations relating to accessibility standards for persons with disabilities. It is part of the Company’s core beliefs that all persons, regardless of ability are treated ethically, fairly and with respect. PRA will arrange to fulfill accommodation requests from customers, business partners, Employees, or prospective Employees, as outlined in this Policy.
This document applies specifically to all Employees and Contractors of PRA Group Canada Inc. including any employee contracted for temporary assignment and any worker contracted through an agency, with the expectation of compliance to the requirements, guidelines and standards listed in this policy.
1.2 Policy Statement
This policy outlines PRA Group Canada Inc.’s practices in support of individuals with disabilities. PRA is committed to excellence in servicing all customers including those with disabilities. This Policy is designed to meet the requirements of Accessibility Standards for Customer Service, Ontario Regulation 429/07 under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA). It applies to the provision of goods and services to the public or other third parties, not to the goods themselves. All goods and services provided by PRA will follow the principles of dignity, independence, integration, and equal opportunity.
PRA Group Canada Inc. (PRA) 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.
PRA is committed to providing a work environment whereby all organization members receive an equal employment opportunity and accommodation where required, in accordance with the requirements under the AODA and the Integrated Accessibility Standards Regulation (191/11) (“IASR”). Decisions regarding employment with the Company shall not be based on a person’s disability, or lack thereof, but will be based on the person’s qualifications.
It is Management’s expectation that Employees read and comply with this Policy’s parameters. Non-adherence to this policy and associated procedures may result in corrective action up to and including termination of employment with cause and without pay in lieu of notice.
- Accessibility: The term accessibility means giving people of all abilities opportunities to participate fully in everyday life. It is used to describe how widely a service, product, device, or environment is available to as many people as possible. Accessibility can be seen as the ability to access and benefit from a system, service, product, or environment.
Accommodation Plan: A plan tailored to the needs of an individual to ensure that their rights to dignity, independence, integration, and equal opportunity are respected.
- 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 customers 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: Barriers are obstacles that limit access and prevent people with disabilities from fully participating in society. Most barriers are not intentional. Barriers usually arise because the needs of people with disabilities are not considered from the beginning.
- 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.
- Employee: All personnel regardless of position or location, including any Employees contracted for temporary assignment.
- 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 Disruption: This may include but is not limited to: the temporary loss of access to the Company’s physical location, temporary connectivity issues for telephones, internet, fax, or other communication instruments, or any other critical business requirements.
- 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 regulated health professional.
- Support Animal: for the purposes of this document, Support Animal includes the definitions of Guide Dog, Service Animal or Service Dog, as listed above.
- 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 goods and services.
2. Accessibility Standards
In accordance with the Accessibility Standards for Customer Service, Ontario Regulation 429/07, this Policy addresses the following:
- The Use of Assistive Devices
- The Use of Guide Dogs, Service Animals and Service Dogs
- The Use of Support Persons
- Information and Communication
- Notice of Service Disruptions
- Customer Feedback
2.1 Assistive Devices
We will ensure our staff is trained and familiar with various assistive devices that may be used by customers with disabilities while accessing our goods or services. Persons with disabilities may use their own Assistive Devices as required when accessing goods or services provided by PRA. 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 PRA services.
It is the responsibility of the individual with a disability to ensure that his or her Assistive Device is in working order and is operated in a safe and controlled manner at all times.
2.2 Support Animals
PRA welcomes people with disabilities and their Support Animals. All customers, Employees and visitors who are accompanied by a Support Animal will have access to premises as outlined in the Physical Security Policy, the exception being a dog that is excluded by law. ‘No pet’ policies do not apply to Support Animals.
If PRA cannot easily identify that an animal is a Support Animal, our staff may ask a person to provide documentation from a regulated health professional that confirms the person needs the Support Animal for reasons relating to their disability. PRA will maintain the confidentiality of all medical documentation provided by all persons.
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 pit bulls) 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.
If a health and safety concern presents itself, for example, in the form of a severe allergy to the animal, PRA will make all reasonable efforts to meet the needs of all individuals. The person that is accompanied by a Support Animal is responsible for maintaining care and control of the animal at all times.
2.3 Support Persons
A person with a disability who is accompanied by a Support Person will be allowed to have that person accompany them on our premises, subject to PRA’s Physical Security Policy. If a customer with a disability is accompanied by a Support Person, PRA will ensure that both persons are able to enter the premises together and that the customer is not prevented from having access to the Support Person.
In certain cases, PRA might require a person with a disability to be accompanied by a Support Person for the health and safety reasons of:
- the person with a disability
- others on the premises
Before making a decision, PRA will:
- consult with the person with a disability to understand their needs
- consider health or safety reasons based on available evidence
- determine if there is no other reasonable way to protect the health or safety of the person or others on the premises
2.4 Information and Communication
All Employees of PRA will communicate with people with disabilities in ways that take into account their disability, and promote the principals of dignity, independence, integration and equal opportunity. This may include fully accessible:
- phone calls
- Skype and video conference
- face to face communications
When asked, we will provide information about our organization and its services, including public safety information, in accessible formats or with communication supports. We will also meet internationally-recognized Web Content Accessibility Guidelines (WCAG) 2.0 Level AA website requirements in accordance with Ontario’s accessibility laws.
2.5 Notice of Service Disruption
Service Disruptions may occur due to reasons that may or may not be within the control or knowledge of PRA. In the event of any temporary Service Disruptions to facilities or services that customers with disabilities rely on to access or use PRA’s goods or services, notice will be provided.
This notice will include information about the reason for the disruption, its anticipated duration, and a description of alternatives for services if available.
In the event of a planned or unexpected disruption to services or facilities for customers with disabilities, we will notify our customers through a notice posted on our website, voicemail and on our premises.
PRA welcomes feedback regarding accessibility for people with disabilities, and how we provide accessible customer service. Feedback from all sources will help PRA identify barriers and respond to concerns.
Customers who wish to provide feedback on the way PRA provides services to people with disabilities are encouraged to submit their feedback to our Compliance Department via email at: firstname.lastname@example.org; phone at (519)432-0075, ext. 25177; or through our website www.pra-group.ca
If a complaint is made about PRA’s customer service or accessibility, PRA will investigate the complaint and make sure that all aspects of our business comply with the Accessibility for Ontarians with Disabilities Act, 2005. PRA will provide accessible feedback upon request.
PRA will provide training to all permanent and contract Employees, and volunteers. Employees will receive training as soon as practicable after the onboarding process. Third parties that act on behalf of PRA are contractually obligated to be legislatively compliant, including AODA legislation. Training will include:
- the purpose of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard
- PRA’s policies related to the customer service standard
- 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
This Policy is made available to all staff via the PRA Group Canada Policy Vault, located on the Company Intranet. All policies found in the Vault must be reviewed and acknowledged annually by all Employees. The Annual Policy Committee is responsible for ensuring that this process is completed on an annual basis, and that any critical changes to processes, or policies are communicated specifically to Employees, prior to the annual acknowledgement.
A hard copy of this Policy is located in the lunchrooms of the London, Newmarket and Montreal offices.
PRA is committed to reviewing this policy on a regular basis and ensuring that it remains compliant with AODA standards.
All Company policies will be reviewed to ensure that they respect and promote the principles of dignity, integration and equal opportunity for people with disabilities. Any PRA policy will be modified to include these provisions or will otherwise be removed or altered.
PRA Group Canada’s London Ontario office is owned by BlueStone Properties Inc. Concerns regarding the accessibility of the building’s premises should be addressed with Bluestone. PRA will work in conjunction with BlueStone to address the accessibility requirements for the office space leased by PRA.
PRA Group Canada’s Newmarket Ontario office is owned by Tricap Properties. Concerns regarding the accessibility of the building’s premises should be addressed with Tricap. PRA will work in conjunction with Tricap to address the accessibility requirements for the office space leased by PRA.
3. Employment Standards
PRA Group Canada is an equal opportunity employer and strives for excellence in all departments. It is PRA’s belief that applicants from all backgrounds can provide the Company with opportunities for growth and improvement, regardless of an individual’s disability.
PRA will notify its Employees and external applicants about the availability of accommodation for applicants with disabilities during the recruitment process. Candidates will be asked to identify any special requirements for accommodation to ensure they can fully participate in the selection process. The following will be included on all internal or external job postings:
“We are compliant with AODA legislation. Accommodations will be provided upon request.”
3.2 Assessment or Selection Process
PRA will ensure that job applicants are notified when they are individually selected to participate in the assessment or selection process and that accommodation for disabilities are made available upon request in relation to the materials or processes to be used. PRA will consult with individuals who request accommodations and will provide appropriate accommodations. When presenting offers of employment, PRA will notify the successful applicant of its policies for accommodating employees with disabilities.
3.3 Informing Employees of Supports
PRA will ensure that Employees are informed of all accessibility policies (and any updates to those policies) used to support Employees with disabilities, including policies on the provision of job accommodations that take into account an Employee’s accessibility needs due to disability. This information will be provided to new Employees as soon as practicable after commencing employment.
3.4 Accessible Formats and Communication Supports for Employees:
Upon request of an Employee with a disability, PRA will consult with the Employee to provide, or arrange for accessible formats and communication supports for information that is needed to perform his/her job, and information that is available to other Employees. In order to determine the suitability of an accessible format or communication support, PRA will consult with the Employee making the request. Accessible formats and communications supports regarding general workplace information will also be provided to Employees with disabilities. Individual Accommodation Plans will be required in a format that meets the needs of the individual.
3.5 Workplace Emergency Response Information:
PRA provides Employees with known and/or documented disabilities individualized workplace emergency response information when the Employee’s disability is such that the information is required, and PRA has been informed of the need to accommodate the Employee’s disability. Individual Accommodation Plans regarding Emergency Response will be communicated to the Employee(s) responsible to action these plans to ensure the safety of all Employees.
3.6 Return to Work Process:
PRA will maintain a documented Return to Work Process for Employees who have been absent from work due to a disability and who require disability-related accommodations and support in order to return to work. The above stated Return to Work Process will not replace, hinder or override any other Return to Work Process created by or under any other statute. This process will be in accordance with the attached template referenced in Appendix A.
3.7 Performance Management, Career Development, Advancement and Redeployment:
PRA will continue to consider the accessibility needs of Employees with disabilities as well as individual Accommodation Plans, when conducting performance management reviews, providing career development and advancement to Employees and when redeploying Employees.
4. Accommodation Plans
Accommodation Plans are an important part of the integration of people with disabilities. PRA will make every effort to accommodate persons with disabilities in ways that take into account the individual’s needs, and the principles of dignity, independence, integration and equal opportunity. PRA will provide a respectful environment to all Employees, regardless of ability. PRA takes measures to ensure that other options are available for people with disabilities. These options may not be suitable for all individuals, given the needs of their specific situations. In these cases, PRA will openly discuss with the individual an Accommodation Plan to meet their specific needs.
4.1 Employee Accommodation Plans
PRA currently does and will continue to accommodate the needs of persons with disabilities as required under the Ontario Human Rights Code. PRA will develop individualized Accommodation Plans for its Employees with disabilities, as the Company is made aware. All Accommodation Plans will be documented in compliance with the Accommodation Plan Process. This process will be in accordance with the attached template referenced in Appendix B. Implementation of Accommodations will be addressed on an individual basis, depending on the nature of the requirements.
PRA promotes and requests the Employee’s involvement in the creation, implementation and review of their individual Accommodation Plan. Employee participation ensures that Employees are comfortable with their Accommodation Plan and that it meets the needs of their specific situation. Accommodation Plans will be reviewed with the Employee on an annual basis unless other factors require a more frequent review. Such factors could include but are not limited to material changes to the nature or severity of the Employee’s disability; changes to the office space; or changes to the Employee’s job responsibilities. Accommodation Plans will be documented in the Employee’s confidential file and will not be shared with any other party unless required to do so to fulfill the Accommodation Plan, or if requested to do so by the Employee.
Employees with disabilities have the right to request a representative from the workforce to participate in the development of their Accommodation Plan. Employees who are assisting in the development of an Accommodation Plan will be required to sign a Confidentiality Agreement related to the Accommodation Plan. PRA reserves the right to seek assistance or advice from an outside expert at no cost to the Employee. The identity of the Employee will not be disclosed to the outside expert unless written authorization has been obtained by the Employee.
Employees will be provided with their formalized Accommodation Plan as soon as practicable. Due to the varied nature of the Plans, Employees may expect a slight delay, no greater than 15 business days to implement all requirements of the individual Accommodation Plan. Employees will be notified of any changes that may delay the implementation of their Accommodation Plan. All Accommodation Plans with expected delays greater than three (3) business days shall include an interim solution appropriate to their situation.
If an Employee has proposed an Accommodation Plan, which is not possible due to internal or external limitations, or if the Employee’s Accommodation Plan is declined, PRA will notify the Employee of the reason(s) their Accommodation Plan has been declined. PRA will provide this information in writing to the individual, and work with him/her to create an alternate Accommodation Plan, as necessary.
4.2 External Accommodation Requests
PRA will handle all customer accommodation requests on an individual basis and will ensure that the customer’s rights are respected at all times. Customers will be provided with all communications in a format that is accessible to them. All PRA Group Canada Employees are trained on acceptable customer service practices for people with disabilities.
The Company occasionally receives visitors, such as auditors, trainers, or other third party service providers. It is the responsibility of the visitor to notify PRA of any accessibility requirements needed to complete their function at PRA.
PRA will handle these requests on an individual basis, and with the utmost respect and care. PRA will keep confidential the nature of the visitor’s disability when necessary. If Accommodations are expected to be delayed, visitors will be notified as soon as practicable of the delay, and when the accommodation can be expected.
Appendices A and B
PRA Group Canada utilizes the sample templates as suggested on the ‘Accessible Workplaces / Ontario’ Website. That site details ‘Accommodation Plans’ and the ‘Return to Work Process.’ Those sections include the following templates: