Toronto Eaton Centre
Accessible Customer Service Policy
January 1, 2012
TABLE OF CONTENTS
Section Page
Executive Summary………………………………………………………………….3
1.0 Policy – Purpose and Scope………………………………………………………...4
2.0 Definitions……………………………………………………………………………...4
3.0 Toronto Eaton Centre Commitment to Accessibility.……...……………………...5
4.0 Communicating with People with Disabilities ….………………………………….5
5.0 Assistive Devices …………………………………………………………………….6
6.0 Service Animals……………………………………………………………………….7
7.0 Support Persons…………………………………...………………………………....8
8.0 Notifications of Disruptions in Service………………………………………….......8
9.0 Training………………………………………………………………………………..12
10.0 Customer Service Feedback Process……………………………………………..13
11.0 Emergency Preparedness…………………………………………………………..14
12.0 Communication Plan and Availability of this Policy………………………………14
13.0 Review Process………………………………………………………………………15
Appendix and Supporting Documentation …………………………………………………16
Executive Summary
The Accessibility for Ontarians with Disabilities Act, 2005 (AODA) is a law passed by the Ontario legislature that is intended to facilitate full accessibility throughout the Province of Ontario for persons with disabilities by 2025.
The AODA will achieve this aim by developing, implementing and regulating Accessibility Standards that will guide the principles and requirements of creating accessibility in the following areas:
· customer service
· information and communications
· transportation
· built environment
· employment
Accessibility Standards will be established by regulation under the Act and will be coordinated with staggering deadlines. It is important to note that 2025 is a proposed end date and obligated organizations will be required to meet accessibility requirements with much earlier timelines.
The first regulated accessibility standard established under the authority of AODA is the Accessibility Standards for Customer Service, Ontario Regulation 429/07, which came into effect on January 1, 2008 and requires compliance by January 1, 2012. In summary, the Regulation requires the creation of an accessible customer service policy and training of all staff, agents and volunteers who provide goods and services on behalf of the Toronto Eaton Centre.
Stretching two full city blocks, The Toronto Eaton Centre is a historical landmark, and today one of Canada’s best-known retail shopping destinations, attracting approximately millions of visitors annually. In addition to our retail component, the TEC is also composed of three Commercial Office Towers (20 Queen, 250 Yonge & 1Dundas) The Toronto Eaton Centre prides itself on the delivery of the “customer experience” to all visitors. This document outlines The Toronto Eaton Centre’s commitment as well as procedures and practices in ensuring an accessible “customer experience” to persons with disabilities.
Toronto Eaton Centre
Accessible Customer Service Policy
1.0 Policy – Purpose and Scope
The Toronto Eaton Centre is committed to providing excellent customer service to all its customers. This Accessible Customer Service Policy sets out the responsibilities of all persons in the employ of the Toronto Eaton Centre, its contractors, agents, volunteers and any individuals serving the company in an appointed capacity.
2.0 Definitions
“Disability” means:
(a) 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 coordination, 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,
(b) a condition of mental impairment or a developmental disability,
(c) a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,
(d) a mental disorder, or
(e) an injury or disability for which benefits were claimed or received under the
insurance plan established under the Workplace Safety and Insurance Act, 1997.
The above includes disabilities of different severity, visible as well as non-visible disabilities, and disabilities the effects of which may come and go.
Information about any person’s disability is personal and private and must be treated confidentially.
3.0 Toronto Eaton Centre Commitment to Accessibility
In fulfilling our mission, The Toronto Eaton Centre strives at all times to provide its goods and services in a way that respects the dignity and independence of people with disabilities. The Toronto Eaton Centre is committed to giving people with disabilities the same opportunity or reasonable alternative to access our goods and services and allowing them to benefit from the same or similar services, in the same place and in a similar way as other visitors.
It is the policy of The Toronto Eaton Centre to promote accessibility for people with disabilities based upon the core principles of dignity, independence, inclusion, integration, responsiveness and equality of opportunity.
The Toronto Eaton Centre is committed to excellence in serving all customers, including people with disabilities, and shall carry out its functions and responsibilities in the following areas in compliance with AODA’s Accessibility Standards for Customer Service:
4.0 Communicating with People with Disabilities
The Toronto Eaton Centre shall take reasonable steps to communicate with persons with disabilities in ways that take into account their disability and accessibility needs.
The Toronto Eaton Centre shall also ensure that all staff, volunteers and others dealing with the public on behalf of The Toronto Eaton Centre are properly trained in how to communicate with visitors with various types of disabilities.
5.0 Assistive Devices
The Toronto Eaton Centre is committed to serving people with disabilities who use assistive devices to obtain, use or benefit from its goods and services.
People with disabilities are permitted and encouraged to use their own personal assistive devices to access our facilities and goods and services. Assistive devices such as communication aids, cognition aids, personal mobility aids and medical aids are allowed to be used at all of our facilities where access is possible at the venue.
The Toronto Eaton Centre will ensure the public is informed of any and all assistive devices that are available for their use while at the Toronto Eaton Centre including wheelchairs.
The Toronto Eaton Centre will also ensure the public is informed of accessibility features available for their use while at the Toronto Eaton Centre including elevator and accessible washroom locations.
The Toronto Eaton Centre shall also ensure that staff knows how to use assistive devices that are available to customers of the Toronto Eaton Centre and where to locate elevators and accessible washrooms within the facility.
The Toronto Eaton Centre shall also ensure that all staff and agents serving the public on behalf of the Toronto Eaton Centre are properly trained and familiar with various assistive devices that may be used by customers with disabilities while accessing its goods and services.
6.0 Service Animals
For the purposes of this policy a:
“Guide Dog” means:
A guide dog as defined in section 1 of the Blind Persons Rights’ Act.
“Service Animal” means:
An animal that is of service to a person with a disability where it is readily apparent that the animal is used by the person for reasons relating to his or her disability. Verification of a service animal’s status can be provided by way of government certification or by a letter from a physician or nurse confirming the animal is required for reasons relating to the disability. It is “readily apparent” that an animal is a service animal when it is obvious by its appearance or by what it is doing. For example, it may be readily apparent that an animal is a service animal if it is wearing a harness, saddles bags, a sign that identifies it as a service animal or has a certificate or identification card from a service animal training school or an identification card from the Attorney General of Ontario. It may also be readily apparent if a person is using the animal to assist him or her in doing things, such as opening doors or retrieving items.
A visitor to the Toronto Eaton Centre is permitted to be accompanied by his or her guide dog or other service animal within all areas of the Toronto Eaton Centre except where areas are restricted to employees or prohibited by law.
Ontario Regulation 562 under the Health Protection and Promotion Act states that animals are not allowed in places where food is manufactured, prepared, processed, handled, served, displayed, stored, sold or offered for sale. It does make an exception for service dogs to allow them to go where food is normally served, sold or offered for sale.
There may be rare circumstances where, for the reasons of health and safety of another person, allowing a person with a disability to enter a premises and be accompanied by their service animal needs to be considered. In the rare situation where another person’s health and safety could be seriously impacted by the presence of a service animal on premises open to the public, The Security Supervisor shall be immediately notified. The Security Supervisor shall fully analyze all options for safely allowing the service animal and must consider all relevant factors and options in trying to find a solution that meets the needs of both individuals.
7.0 Support Persons
For the purposes of this policy a:
“Support Person” means:
Any one person who accompanies a person with a disability in order to help that individual with communication, mobility, personal care or medical needs or with access to goods or services.
A support person may assist a person with a disability in using the washroom or change room or assist a person with speech impairment to facilitate communication. A support person may be a paid professional, a volunteer, a family member or friend of the person with a disability.
A visitor to the Toronto Eaton Centre is permitted to be accompanied by his or her support person in order to access our goods and services. At no time shall a person with a disability who is accompanied by a support person be prevented from having access to his or her support person while on The Toronto Eaton Centre premises.
8.0 Notification of Disruptions in Service
Persons with disabilities often rely on specific facilities and services at the Toronto Eaton Centre and as such, disruption in their operations may negatively affect the customer experience while visiting the Centre. Elevators, Personal Elevating Devices, Perimeter Access, Barrier Free Washrooms, Water, and Heating & Air-conditioning are among those services and as such; disruption in their operations must be communicated appropriately.
All Toronto Eaton Centre administration staff, customer service and building operations personnel will be informed immediately upon identifying that one of the above facility services are disrupted.
8.1 Notice of a Planned Service Disruption to Base Building Accessibility Services
1) Internal Department heads (Office – Manager Tenant Relations / Sr. Retail Property manager) for the Toronto Eaton Centre shall notify the Client Contacts of any planned or future disruptions in advance of 7 days.
2) The Manager of Tenant Relations / Sr. Retail Property Manager shall notify Tenants by way of e-mail and / or written memorandum of the disruption.
3) The tenant communication shall contain the following information;
i) How long the disruption is expected to last;
ii) What alternative facilities or services exist.
4) Individual tenants will communicate internally to its staff and advise staff to contact stakeholders and clients scheduled for appointments about the service disruption as applicable.
5) As a general rule, planned disruptions shall be communicated to affected tenants in advance of seven days. Tenant contacts are responsible for their respective internal communications.
6) Upon restoration of the service, Toronto Eaton Centre Management shall notify the tenant contacts via Client Communication Memo and advise that the service disruption has ended.
7) The Toronto Eaton Centre shall notify the public in advance of any planned service disruptions, by way of posting on the property’s website any planned or future work that may affect these services and posting signage at the entrances closest to facility affected by the planned disruption. Notice should include:
i) the reason for the disruption
ii) its anticipated duration
iii) a description of alternative facilities or services, if available.
8.2 Notice of an Unplanned (Unexpected or Emergency) Disruption to Base Building Accessibility Services
Once an unplanned disruption of base building services has been identified, notice should be provided as soon as possible to ensure timely notification to Tenant Contacts.
1) The Toronto Eaton Centre Internal Department Heads are to notify The Manager of Tenant Relations / Sr. Retail Property Manager of any unplanned disruptions.
2) The Manager of Tenant Relations / Sr. Retail Property Manager / Toronto Eaton Centre Security Dispatch shall notify Tenant Contacts by way of Client Communications / MIR3 Mass notification system.
3) The tenant communication and / or Emergency Notification System message shall contain the following information;
iii) How long the disruption is expected to last;
iv) What alternative facilities or services exist.
4) Individual tenants will communicate internally to its staff and advise staff to contact stakeholders and clients about the service disruption as applicable.
5) Upon restoration of the service disruption, Manager of Tenant Relations / Sr. Retail Property Manager / Toronto Eaton Centre Security Dispatch shall notify the tenant contacts via the Client Communications / MIR3 Mass notification system, and advise that the service disruption has ended.
8.3 Tenant Service Disruption – Isolated to specific Tenant / Floor
1) The Toronto Eaton Centre tenant or applicable representative to notify The Manager of Tenant relations / Sr. Retail Property Manager / Toronto Eaton Centre Security Dispatch of the service disruption.
2) The Security Supervisor / Operations Manager to begin investigation to determine if the service disruption is isolated or building wide.
3) If the disruption is identified as being isolated, tenant notifications shall be made to the affected areas by way of Client Communications or MIR3 Mass Notification System.
4) The tenant communication and / or Emergency Notification System message shall contain the following information;
v) How long the disruption is expected to last;
vi) What alternative facilities or services exist.
5) If the disruption affects the tenant’s capability of conducting business, Manager of Tenant Relations shall also provide notification within the lobby of the affected building with the intent of notifying visitors of the disruption prior to attending the tenant suite.
6) Individual tenants will communicate internally to its staff and advise staff to contact stakeholders and clients scheduled for appointments about the service disruption as applicable.
7) Upon restoration of the service disruption, The Manager of Tenant Relations / Sr. Retail Property Manager shall notify the tenant contacts via Client Communication Memo and advise that the service disruption has ended. All applicable signage shall be removed at such time.
8) The Toronto Eaton Centre will inform members of the public who are on-site of any unplanned disruptions in the following ways:
· Signage
· Concierge Staff
· Guest Services Staff
9.0 Training
In maintaining the Toronto Eaton Centre commitment in ensuring the “customer experience” to all visitors, a training program will be initiated for all customer service and security personnel. The training program is internet based and provides information on providing assistance to persons with various disabilities.
Topics reviewed within the program include:
- Review of the purposes of the AODA and requirements of the customer service standard;
- Information on how persons with disabilities may communicate / interact such as sign language, gestures, boards with symbols, computers, etc.
- Information on how to interact with people with disabilities who use assistive devices or require the assistance of a guide dog, other service animal or a support person.
- Information on inappropriate ways of interacting with persons with disabilities.
- Information on how to use equipment or devices available at the Toronto Eaton Centre, that may help people with disabilities access our tenants services, such as : wheelchairs, rescue chairs, elevators, escalators, automatic door openers.
- Instruction on procedures for what to do if a person with a disability is having difficulty accessing the Toronto Eaton Centre or one of its many tenants.
- Information contained within this document.
Training records for the above training will be kept at Cadillac Fairview Organizational Development office at 20 Queen Street West, 5th Floor, Toronto, ON M5H 3R4.
Training records contain the names of Toronto Eaton Centre personnel and the dates in which the training was completed.
The Toronto Eaton Centre will maintain ongoing training with all employees on an as needed basis.
10.0 Customer Service Feedback Process
In ensuring the Toronto Eaton Centre maintains the highest level of service to visitors; a process of receiving customer service feedback has been established.
Upon receipt of any complaint, the employee receiving the complaint shall immediately forward it to the Manager, Tenant Relations / Supervisor, Guest Services. An initial response will be made as soon as possible, normally within three business days acknowledging receipt and that the complaint is being reviewed. The Toronto Eaton Centre will take into account a person’s accessibility needs when communicating, receiving and/or responding to the complaint.
All inquiries, customer feedback and complaints may be submitted in one of the following ways:
In person (Orally): Toronto Eaton Centre
220 Yonge St. M5B 2H1
Monday – Friday (09:00 – 17:00)
By telephone: Toronto Eaton Centre Management Office
416-598-8700
In writing: Toronto Eaton Centre
220 Yonge St. M5B 2H1 (Box 511)
Electronic Mail: tecaccessibility@cadillacfairview.com
11.0 Emergency Preparedness
Management of incidents involving persons with disabilities is covered in the respective property Emergency Response Plan, and in case of fire, under the specific Fire Response Plan. These plans describe the operational and personnel requirements for assisting persons with disabilities and their support parties or animals.
In addition to the existing plans, it is prudent to maintain some basic equipment on site that may be of use to persons needing assistance because of disabilities.
Equipment that may be of use includes:
For High Rise or Multiple Levels Buildings
a) Wheelchairs, Rescue Chairs or Manual Lifting Devices
b) Predetermined Waiting Areas on Each Floor
For All Properties
a) Wheelchairs and personal walking canes
b) Batteries
c) Writing board and writing materials
2.0 Communication Plan and Availability of this Policy
The Toronto Eaton Centre shall notify the public of the availability these policies and procedures and of our compliance with the AODA’s Accessibility Standards for Customer Service. Therefore, if any person requests a copy of this policy we will provide a copy taking into account the person’s accessibility needs. This may include, but is not limited to, using the following formats:
- Audio format such as cassettes or digital audio format;
- Easy-read, simplified summaries of materials
The Toronto Eaton Centre has its own provider for alternate formats. To arrange for alternate formats for this policy for people with disabilities upon request, please contact:
Patrick Murray, Manager Fire & Life Safety
Tel: 416-598-8512-
Email: patrick.murray@cadillacfairview.com
13.0 Review Process
At minimum, this policy will be reviewed annually by appropriate Toronto Eaton Centre staff. However, the review process may be affected by AODA Regulations as they are announced. Therefore, this policy will also be reviewed upon announcement of any new Accessibility Standards of the AODA, 2005 to ensure integration and consistency with this policy. The policy may be modified to ensure full compliance with the AODA, 2005.