CAN-ASC-1.1 Standard on employment: Public Review Draft - 5. Structural support, policy, and leadership (systems, policies and practices)

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5.1 General space requirements

This clause establishes the requirement for an accessibility strategy with:

  1. measurable objectives;
  2. supporting policies; and,
  3. clear roles and responsibilities of the key workplace parties whose support is necessary for an inclusive and accessible employment system.

This clause emphasizes the importance of ensuring that the organization’s policies support accessibility and the inclusion of workers with disabilities.  It provides direction for the development and review of organizational policies and identifies policy domains that are essential components of the organization’s policy structure to promote an accessible and inclusive workplace.

This clause also requires the organization to identify, remove, and prevent barriers to accessing information and to allocate resources to provide information in accessible formats. This includes the identification, removal, and prevention of barriers to accessibility in existing IT tools, solutions, and equipment as well as in those that are newly acquired or deployed. Where a Human Resources Information System (HRIS) or an Applicant Tracking System (ATS) is used, the organization must identify and establish accessibility criteria to ensure that these systems support the organization’s accessibility objectives.

Finally, this clause identifies the need for emergency preparedness in the workplace by planning, preparing for, and responding to potential emergency situations. It requires the involvement of persons with disabilities in the development of the planned response to a specific emergency situation to ensure that emergency responses meet the needs of all workers, including workers with disabilities.

5.2 Development, implementation, and monitoring of an accessibility strategy

In the development, implementation, and subsequent monitoring of an organizational accessibility strategy, the organization shall:

  1. develop an accessibility strategy with measurable objectives and supporting policies;
  2. demonstrate accountability for implementing this strategy and honouring its commitments, including to the health and safety of workers with disabilities;
  3. publish the strategy, including an audit tool and commit to reviewing the strategy every three years;
  4. monitor progress on this strategy and update it as required based on feedback and suggestions for improvement to accessibility in the workplace; and
  5. communicate updates to the accessibility strategy to workers and interested parties on an annual basis.

5.3 Key components for a successful accessibility strategy

For the accessibility strategy to be successful, the organization shall:

  1. define and communicate the roles and responsibilities of all internal workplace parties required to support the inclusive and accessible employment system consistent with this Standard (refer to Clause 5.4 for further explanation of the inclusive and accessible employment system);
  2. provide workplace parties, with the necessary resources to effectively participate in the establishment, implementation, maintenance, and continual improvement of the inclusive and accessible employment system. Such resources include, but are not limited to:
    1. the premises,
    2. equipment,
    3. communication tools, and
    4. work time; and
  3. promote dialogue about inclusive employment issues between workplace parties, external experts, service providers, and programs administrators while respecting the worker’s right to privacy.

Note: The intention of the accessibility strategy of an organization under Canadian federal jurisdiction (as mentioned in this Standard) is that it would be a companion/component of the organization’s accessibility plan, as it is described in the Accessible Canada Act.

See Clause 6.4.2

5.4 Roles and responsibilities

This clause details the roles and responsibilities of key workplace parties, with a focus on their role in supporting inclusive and accessible employment policies, processes, programs, procedures, and practices (herein termed “the inclusive and accessible employment system”). The successful implementation of this Standard requires commitment from all levels and functions of the organization and by workers at all levels. Senior management shall demonstrate this commitment by allocating, in a timely and efficient manner, the financial, human, and material resources required to achieve its accessibility strategy and objectives and improve inclusive and accessible employment practices.

5.4.1 Role and responsibilities of senior management

Senior management shall develop, lead, and promote a culture of accessibility and inclusion within the organization by:

  1. communicating to all workers on an ongoing basis:
    1. the importance of accessibility in the work environment, and
    2. the importance of organizational commitment to this Standard;
  2. actively engaging workers (with and without disabilities) in dialogue on all aspects of accessible employment;
  3. providing anti-ableism training to reduce the impact of attitudinal barriers;
  4. establishing and supporting committee(s) that promote accessibility, anti-ableism, and inclusion;
  5. protecting workers from reprisals when reporting incidents of discrimination based on disability;
  6. protecting workers from reprisals when identifying barriers to accessibility;
  7. supporting workers to demonstrate leadership in accessibility as it applies to roles and areas of responsibility;
  8. implementing this Standard to achieve its intended outcome(s);
  9. providing opportunities for confidential worker feedback and suggestions for improvement;
  10. establishing an accessibility ombudsperson and a confidential complaints process;
  11. measuring and evaluating progress toward achieving accessibility objectives to demonstrate continual improvement;
  12. facilitating worker and labour representative participation in the development, implementation, maintenance, and continual improvement of the inclusive and accessible employment system consistent with this Standard;
  13. encouraging internal and external stakeholder participation in the development, implementation, maintenance, and continual improvement of the inclusive and accessible employment system consistent with this Standard;
  14. ensuring that persons with disabilities are consulted/included in the development, implementation, maintenance and continual improvement of the organization’s inclusive and accessible employment system;
  15. establishing a mechanism for regular reporting to senior management on the performance of the inclusive and accessible employment system, using this feedback to support continual improvement; and
  16. designating one or more representatives who, irrespective of other responsibilities, have defined roles, responsibilities, accountability, and authority to establish, implement, maintain, and continually improve the organization’s inclusive and accessible employment system to ensure they are consistent with this Standard.

5.4.2 Role and responsibilities of managers, supervisors, and internal experts

Managers, supervisors, and internal experts shall:

  1. support the development, implementation, maintenance, and continual improvement of the organization’s inclusive and accessible employment system, with consideration of the specific role they play within the system. This includes, but is not restricted to:
    1. policy development, implementation, maintenance, and continual improvement,
    2. proactive remediation of known and hidden systemic barriers and unconscious bias,
    3. development of an information system to support the evaluation of its effectiveness,
    4. oversight of day-to-day operational effectiveness,
    5. encouraging disclosure of accommodation needs as appropriate (excluding diagnosis and any non-relevant medical conditions),
    6. ensuring a process is in place for confidential disclosure of disability,
    7.  ensuring accommodation plans are up-to-date, and
    8. promoting and supporting good faith in the accommodation process;
  2. communicate policies, processes, programs, procedures and practices related to inclusive employment to workplace parties;
  3. support workers with navigating inclusive employment policies, processes, programs, procedures, and practices;
  4. ensure all workplace parties receive appropriate training for their role and responsibilities within the inclusive and accessible employment system;
  5. promote an inclusive culture where workers feel comfortable disclosing their need for accommodation without fear of reprisal or negative consequences;
  6. permit workers reasonable time away from their work, as necessary, to participate in the continual improvement of the inclusive and accessible employment system; and
  7. consult with external experts, as needed, to provide expertise on elements of the inclusive and accessible employment system to enhance effectiveness and impact.

5.4.3 Labour and Union Role

Labour and Unions shall develop, lead, and promote a culture of accessibility and inclusion within the organization by:

  1. participating in the development, implementation, maintenance, and continual improvement of the inclusive and accessible employment system. This includes, but is not restricted to:
    1. participating in meetings with management to ensure the various stages of the inclusive and accessible employment system are collaborative and meet the needs of the workers,
    2. working with management to identify outdated policies and recommend new ones,
    3. ensuring that the inclusive and accessible employment system complements the collective bargaining process and does not contravene negotiated contract language,
    4. negotiating workplace-specific worker protections through the collective bargaining process, and
    5. holding employer representatives accountable for their responsibilities within the inclusive and accessible employment system;
  2. promoting work disability awareness and competency within the workplace;
  3. promoting a work environment where reporting or disclosing issues is done in a respectful and supportive manner;
  4. supporting workers throughout the accommodation process;
  5. representing members as per union responsibilities (as needed or as requested); and
  6. promoting an inclusive culture where workers feel comfortable disclosing their need for accommodation without fear of reprisal or negative consequences.

5.4.4 Worker Role

Workers shall promote a culture of accessibility and inclusion within the organization by:

  1. participating in the development, implementation, maintenance, and continual improvement of the organization’s inclusive and accessible employment system. This includes, but is not restricted to:
  1. identifying barriers to participation, communicating these barriers through the appropriate channels, and, where appropriate, working to remove and prevent these barriers,
  2. following the policies, processes, programs, procedures, and practices as outlined in the system, and 
  3. providing feedback on the effectiveness of the inclusive and accessible employment system;
  1. engaging in the accommodation process in good faith; and
  2. promoting an inclusive culture where all workers feel comfortable disclosing their need for accommodation without fear of reprisal or negative consequences.

5.5 Organizational policies

Policies reflect the organization’s commitment and intention. Achieving a barrier-free workplace for all requires that the organization’s policies support accessibility and the inclusion of workers with disabilities.

5.5.1 Policy development

The organization shall:

  1. review any and all policies already in place, including but not limited to the accommodation policy (refer to Clause 9.3.2), accessibility policy (refer to Clause 5.5.3), and the anti-ableism policy (refer to Annex E), to ensure they are consistent with accessibility objectives; Note: Please see Annex F for a list of additional policies.
  2. develop policies that facilitate the achievement of these objectives and are compatible with the requirements of this Standard;
  3. reflect its commitment and intention to achieve a barrier-free workplace, and support accessibility and inclusion of workers with disabilities in its policies and practices;
  4. review and assess policies using an intersectional accessibility lens (see Annex D) to identify policies that create or sustain barriers to the employment of workers with disabilities, and revise policies as required; and
  5. consult with workers with disabilities and unions in the development and modification of the organization’s employment policies and practices.

5.5.2 Policy domains 

Policy domains are essential components of the organization’s policy structure that shall be present to promote an accessible and inclusive workplace.

The organization shall ensure that its policies address accessibility through the identification, removal, and prevention of barriers in the following policy domains:

  1. anti-discrimination (includes anti-ableism);
  2. pre-employment (e.g. sourcing, recruitment, screening, interviewing and selection, hiring, onboarding);
  3. retention, career development;
  4. individual accommodation (e.g. including devices and equipment);
  5. return to work;
  6. performance management;
  7. pay equity;
  8. individual and organizational training, learning, and development;
  9. internal communications, accessible communications, communications support;
  10. workplace emergency response; and,
  11. service animals.

5.5.3 Accessibility policy

5.5.3.1 Contents of accessibility policy

The organization shall develop an accessibility policy suitable to its purpose, size, and context that:

  1. includes a commitment to providing an accessible workplace by identifying, preventing and removing barriers to accessibility;
  2. provides a framework for setting its accessibility objectives;
  3. commits to fulfilling legal requirements and other requirements related to accessibility; and
  4. identifies a process for measuring and evaluating progress toward achieving accessibility objectives.

5.5.3.2 Development and publication of accessibility policy

The organization shall:

  1. encourage the participation of workers and their representatives in the development of an accessibility policy;
  2. document the policy; and
  3. make it available to workers, communicate it within the organization, and publish it on a digital platform (or a radio or television broadcast, public service announcement, recorded message) used to communicate with the public (see Clause 5.6 item c)).

5.6 Access to information

The organizations shall identify, remove, and prevent barriers to accessing information by:

  1. ensuring there is accountability and resources for producing accessible format materials;
  2. ensuring in-house workers and/or competent contracted external providers are able to cover internal and external communications in plain language, signed languages, and accessible formatting;
  3. planning and creating communication (continuous or temporary) with accessible formats (e.g. large print) and languages (e.g. Braille, signed languages, Protactile Sign Language, plain language);
  4. maximizing full access by delivering accessible communications and reducing the need for individualized accessible formats;
  5. documenting this process and communicating it to all workers at the time of implementation and during onboarding;
  6. providing job applicants and prospective workers with the same accessible communication formats provided to current workers;
  7. providing information on work opportunities in accessible formats;
  8. making information in the requested format retrievable by all workers on any existing intranet website; and
  9. providing access to stored documents and access points for archived materials.

5.6.1 Accessibility of communications

The organizations shall monitor and improve the accessibility of communications by:

  1. designating those responsible for managing requests for information;
  2. establishing a timeline for responding promptly to requests for information;
  3. monitoring requests for information and the time taken to respond;
  4. obtaining worker feedback and providing it to the continual improvement process on an annual basis; and
  5. providing electronic communications in a format that meets current requirements for level AA conformance set out in the Web Content Accessibility Guidelines, published by the World Wide Web Consortium. You can find an example on the Canadian Radio-television and Telecommunications Commission website.

5.7 Information technology

Information technology (IT) is the use of any computers, storage, networking and other physical devices, infrastructure, and processes to create, process, store, secure, and exchange all forms of electronic data. The commercial use of IT encompasses both computer technology and telecommunications.

Everyone within the organization who designs, develops, deploys, recommends, procures, or manages electronic equipment and information technology has responsibilities to include accessibility of software and hardware throughout their use in the workplace.

The organization shall:

  1. identify, remove, and prevent barriers to accessibility in existing IT tools, solutions, and equipment;
  2. prioritize the identification, prevention, and removal of accessibility barriers when acquiring and deploying new IT tools, solutions, and equipment;
  3. account for accessibility in the lifecycle management process for existing IT solutions, tools, and equipment, including web content;
  4. support the highest level of accessibility provided by IT solutions by enabling the accessibility features of tools and equipment;
  5. follow and meet the current requirements for Level AA conformance to the Web Content Accessibility Guidelines, published by the World Wide Web Consortium (You can find an example on the Canadian Radio-television and Telecommunications Commission website);
  6. make accessibility a priority in the acquisition or development of internal and public-facing information technology solutions, tools, and equipment to allow IT to be useable by all;
  7. determine if products, services, and technology used in, or purchased for the workplace result in accessibility limitations for people with disabilities. Such products, services, and technologies may include but are not limited to:
    1. audiovisual content,
    2. websites,
    3. web applications,
    4. mobile apps,
    5. software; and
    6. kiosks.

5.7.1 Human Resource Information System (HRIS)

An HRIS is a software solution that maintains, manages, and processes detailed worker information and human resources-related policies and procedures.

The organization shall:

  1. identify and establish accessibility criteria for selecting an HRIS to support its accessibility objectives; and
  2. review and assess an HRIS using accessibility criteria to identify, remove, and prevent barriers to employment for workers with disabilities.

Note: A Human Resource Information System may be used as part of a Human Resource Management System.

5.7.2 Applicant Tracking Systems (ATS) and Artificial Intelligence (AI)

Organizations shall implement the following ATS and AI requirements in conjunction with Clause 7 of this Standard.

Note: Where the organization uses an ATS or other AI for job candidate recruitment, screening, and hiring, compliance with anti-discrimination legislation is required under the Canadian Human Rights Act demonstrating that the selection criteria of any hiring assessment tools are job-related and consistent with business necessity, and do not systemically disadvantage members of employment equity groups.

Where the organization uses an ATS or other AI for job candidate recruitment, screening and hiring, the organization shall:

  1. ensure that ATS and AI screen applicants for bona fide occupational requirements; Note: The Supreme Court of Canada outlined a three-step test to determine a bona fide occupational requirement. The employer is to establish that the requirement:
    1. Was adopted for a purpose or goal that is rationally connected to the function being performed;
    2. Was adopted in good faith, in the belief that it is necessary to fulfill the purpose or goal; and
    3. Is reasonably necessary to accomplish its purpose or goal, in the sense that it is impossible to accommodate the worker without undue hardship.
  2. take reasonable steps to demonstrate the AI or ATS is not discriminatory, by:
    1. routinely and regularly utilizing the following indicators of acceptable practice for ATS and AI systems to remove bias in the hiring process, by:
      1. telling candidates if AI is being used as part of the process,
      2. allowing every candidate to request accommodation,
      3. ensuring accommodations are delivered in non-stigmatizing manner, and
      4. requiring employers to produce and make public evidence that they have required suppliers to demonstrate they have taken reasonable steps to involve persons with disabilities to make sure their products are not discriminatory to candidates with disabilities; and,
  3. implement reasonable and effective accommodations and adjust the screening process to fairly and equitably assess each candidate.

Where the organization utilizes a third party to conduct screening and evaluation, it shall ensure that external AI hiring tools have been programmed and implemented with a diverse data set that includes people with disabilities.

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