10.1 Overview
This clause establishes the requirement for an employment accessibility strategy with:measurable objectives;supporting policies; clear roles and responsibilities of the key workplace parties whose support is necessary for an inclusive and accessible employment system; and,evaluation plans.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. See Clause 10.5.2 for more details and requirements regarding policy domains.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 information technology tools, solutions, and equipment, as well as in those that are newly acquired or deployed. Where a Human Resources Information System or an Applicant Tracking System 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.
,
10.2 Development, implementation, and monitoring of an employment accessibility strategy
In the development, implementation, and monitoring of an organizational employment accessibility strategy, the organization shall:develop an employment accessibility strategy with measurable objectives and supporting policies;demonstrate accountability for implementing the employment accessibility strategy and honouring its commitments, including the health and safety of all workers;publish the strategy;monitor progress of this strategy;review and update the strategy based on feedback and suggestions for improvement to accessibility in the workplace every three years; andcommunicate any updates to the employment accessibility strategy to workers and interested parties annually.
,
10.3 Key components for a successful employment accessibility strategy
For the employment accessibility strategy to be successful, the organization shall: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 10.4 for further explanation of the inclusive and accessible employment system);provide workplace parties with the necessary resources to effectively participate in establishing, implementing, maintaining, and continually improving the inclusive and accessible employment system. Such resources include, but are not limited to:the premises;equipment;communication tools; andwork time; andpromote dialogue about inclusive employment issues among workplace parties, including persons with disabilities and lived experience, external experts, service providers, and program administrators, while respecting the worker’s right to privacy.
,
10.4 Roles and responsibilities
This clause details the roles and responsibilities of key workplace parties in support of 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 employment accessibility strategy and objectives and improve inclusive and accessible employment practices.10.4.1 Role and responsibilities of senior management
Senior management shall develop, lead, and promote a culture of accessibility and inclusion within the organization by:communicating to all workers on an ongoing basis:the value of working together to address and innovate accessibility in the workplace; andthe value of ensuring equitable commitment to the Standard to benefit everyone;actively engaging workers (with and without disabilities) in dialogue on all aspects of accessible employment;providing anti-ableism training to reduce the impact of attitudinal barriers;establishing or supporting committee(s) that promote accessibility, anti-ableism, and inclusion;establishing a confidential complaints process;designating one or more neutral representatives who, irrespective of other responsibilities, have defined roles, responsibilities, accountability, and authority to establish, implement, maintain, and continually improve the organization’s confidential complaints process;protecting workers from reprisals when reporting incidents of discrimination based on disability;protecting workers from reprisals when identifying barriers to accessibility;supporting workers to demonstrate leadership in accessibility as it applies to roles and areas of responsibility;implementing this Standard to achieve its intended outcome(s);providing opportunities for confidential worker feedback and suggestions for improvement;measuring, evaluating, and reporting progress toward achieving accessibility objectives to demonstrate continual improvement;facilitating worker representative participation in the development, implementation, maintenance, and continual improvement of the inclusive and accessible employment system consistent with this Standard;encouraging participation of both internal and external interested parties in the development, implementation, maintenance, and continual improvement of the inclusive and accessible employment system consistent with this Standard;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;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; andincluding the leadership and implementation of an inclusive and accessible employment system in their performance management objectives.10.4.2 Role and responsibilities of managers, supervisors, and internal experts
The organization shall ensure that managers, supervisors, and internal experts:support the development, implementation, maintenance, and continual improvement of the organization’s inclusive and accessible employment system, considering the specific role they play within the system. This includes, but is not restricted to:policy development, implementation, maintenance, and continual improvement;proactive remediation of known and hidden systemic barriers and unconscious bias;development of an information system to support the evaluation of its effectiveness if no such system exists;oversight of day-to-day operational effectiveness;encouraging disclosure of accommodation needs as appropriate (excluding diagnosis and any non-relevant medical conditions);ensuring a process is in place for confidential disclosure of disability;ensuring accommodation plans are up-to-date; andpromoting and supporting good faith in the accommodation process;communicate policies, processes, programs, procedures, and practices for inclusive employment to workplace parties;support workers in navigating inclusive employment policies, processes, programs, procedures, and practices;ensure all workplace parties receive appropriate training for their role and responsibilities within the inclusive and accessible employment system;promote an inclusive culture where workers feel comfortable disclosing their need for accommodation without fear of reprisal or negative consequences;permit workers the time away from their work, as necessary, to contribute to the process of continually improving the inclusive and accessible employment system; andconsult with external experts, disability organizations, and persons with disabilities, as needed, to provide expertise on elements of the inclusive and accessible employment system to enhance effectiveness and impact.10.4.3 The role of an organization in a unionized workplace
The organization shall provide clear, understandable, and relevant information about the inclusive and accessible employment system and consult with union representative(s) on ways to promote a culture of accessibility and inclusion within the organization by encouraging:participation in developing, implementing, maintaining, and continually improving the inclusive and accessible employment system. This includes, but is not restricted to: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;working with management to identify outdated policies and recommend new ones;ensuring that the inclusive and accessible employment system complements the collective bargaining process and does not contravene negotiated contract language;negotiating workplace-specific worker protections through the collective bargaining process; andholding employer representatives accountable for their responsibilities within the inclusive and accessible employment system;promotion of work disability awareness and disability competency within the workplace;promotion of a work environment where reporting or disclosing issues are done in a respectful and supportive manner;support for workers throughout the accommodation process;representation of members as per union responsibilities (as needed or as requested); andpromotion of an inclusive culture where workers feel comfortable disclosing their need for accommodation without fear of reprisal or negative consequences.10.4.4 Worker Role
The organization shall support workers to promote a culture of accessibility and inclusion within the organization by:participating in developing, implementing, maintaining, and continually improving the organization’s inclusive and accessible employment system. This includes, but is not restricted to:identifying barriers to participation, communicating these barriers through the appropriate channels, and, where appropriate, working to remove and prevent these barriers;following the policies, processes, programs, procedures, and practices as outlined in the system; andproviding feedback on the effectiveness of the inclusive and accessible employment system;actively engaging in the accommodation process in good faith; andpromoting an inclusive culture where all workers feel comfortable disclosing their need for accommodation without fear of reprisal or negative consequences.
,
10.5 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.10.5.1 Policy development
The organization shall:review existing policies, including but not limited to the accessibility policy (refer to Clause 10.5.3) and the anti-ableism policy (refer to Annex E), to ensure they are consistent with accessibility objectives;develop policies that facilitate the achievement of these objectives and are compatible with the requirements of this Standard;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;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; andconsult with workers representing diverse disabilities and unions in developing and modifying the organization’s employment policies and practices.10.5.2 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:anti-discrimination (includes anti-ableism);pre-employment (e.g. recruitment, screening, interviewing, assessing, hiring, onboarding);retention, career development, job exit;individual accommodation (e.g. including devices and equipment);performance management;pay equity (see clause 13.5 compensation)individual and organizational training, learning, and development;internal communications, accessible communications, communications support;workplace emergency response; service persons;support persons;guide dogs and service dogs;procurement; and,maintenancepreventative maintenance; andcleaning.10.5.3 Accessibility policy
10.5.3.1 Contents of accessibility policy
The organization shall develop an accessibility policy suitable to its purpose, size, and context that:includes a commitment to providing an accessible workplace by identifying, preventing, and removing barriers to accessibility;provides a framework for setting its accessibility objectives;commits to fulfilling legal requirements and other requirements related to accessibility; andidentifies a process for measuring, monitoring, enforcing, and evaluating progress toward achieving accessibility objectives.10.5.3.2 Development and publication of accessibility policy
The organization shall:encourage the participation of workers and their representatives in the development of an accessibility policy;document the policy; andmake it available to workers, communicate it within the organization, and publish it to communicate with the public (see Clause 10.6 item c).
,
10.6 Access to information
The organization shall identify, remove, and prevent barriers to accessing information by:ensuring there is accountability and resources for producing accessible format materials;ensuring in-house workers or competent contracted external providers or both, can provide internal and external communications in plain language, signed languages, and accessible formatting;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);maximizing full access by using universal design principles to deliver accessible communications;documenting the process for requesting individualized accessible formats and communicating it to all workers;providing job applicants and prospective workers with the same accessible communication formats offered to current workers;providing information on work opportunities in accessible formats;making digital information retrievable in the requested format by any worker; andproviding accessible document storage and archiving platforms.10.6.1 Accessibility of communications
The organizations shall monitor and improve the accessibility of communications by:designating those responsible for managing requests for accessible formats;establishing a timeline for responding promptly to requests for accessible formats;monitoring requests for accessible formats and the time taken to respond;obtaining worker feedback and providing it to the continual improvement process on an annual basis; andproviding electronic communications in a format that meets CAN/ASC - EN 301 549:2024 Accessibility requirements for information and communications technology (ICT) products and services.
,
10.7 Information technology
Information technology 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 information technology 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:identify, remove, and prevent barriers to accessibility in existing information technology tools, solutions, and equipment;prioritize identifying, preventing, and removing accessibility barriers when acquiring and deploying new information technology tools, solutions, and equipment;integrate accessibility in the lifecycle management process for existing information technology solutions, tools, and equipment, including web content.enable the accessibility features of tools and equipment to support the highest level of accessibility provided by information technology solutions;follow and meet the requirements of CAN/ASC - EN 301 549:2024;make accessibility a priority when acquiring or developing internal and public-facing information technology solutions, tools, and equipment to allow information technology to be useable by all; anddetermine if products, services, and technology used in, or purchased for the workplace result in accessibility limitations for persons with disabilities.Note: Such products, services, and technologies may include but are not limited to:audiovisual content;websites;web applications;mobile apps;software; andkiosks.10.7.1 Human Resource Information System
A Human Resource Information System is a software solution that maintains, manages, and processes detailed worker information and human resources-related policies and procedures.The organization shall:identify and establish accessibility criteria that support its accessibility objectives, in selecting a new Human Resource Information System; andreview and assess any existing Human Resource Information System 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.
https://accessible.canada.ca/creating-accessibility-standards/canasc-112024-employment/10-structural-support-policy-and
