Accessibility Policy

Introduction

The Accessibility for Ontarians with Disabilities Act, 2005(“AODA”) seeks to provide a fully accessible Ontario by 2025. Consistent with this objective, various obligations have been placed on organizations, including Marketcircle Inc.(“Marketcircle”),to ensure that workplacesand services are fully accessible to the public and employees, including persons with disabilities.

The AODA requires every employer with less than 50 employees to create accessibility policies to help them achieve their accessibility goals, and to communicate their policies to employees and customers. This Accessibility Policy outlines Marketcircle’s strategy to prevent and remove barriers to accessibility and achieve our accessibility goals.

Statement of Commitment

Marketcircle is committed to providing a barrier-free environment for our customers, employees, job applicants, suppliers, visitors, and other stakeholders who access our information or use our services. Currently, we operate using a virtual office and are committed to making our remote workplace accessible. In the future, should our office operate in a physical space, we will be committed to making these premises accessible to others. As an organization, we respect and uphold the requirements set out in the AODA, and its associated standards and regulation.

Marketcircle understands that we have a responsibility to ensure a safe, dignified, and welcoming environment for everyone. We are committed to ensuring our organization's compliance by incorporating accessibility legislation into our policies, procedures, training, and best practices. We will review these policies and practices annually, as organizational changes occur, or in anticipation of compliance deadlines. In addition, we will strive to meet the needs of individuals with disabilities in a timely and effective manner.

Providing an accessible and barrier-free environment is a shared effort, and as an organization, Marketcircle is committed to working with the necessary parties to make accessibility for all a reality.

Accessibility Standards

This Accessibility Policy outlines the steps which Marketcircle is taking to meet applicable accessibility standards under the Integrated Accessibility Standards Regulation (“IASR”) of the AODA. In particular, it outlines our policies and initiatives to improve opportunities for people with disabilities in the areas of (i) customer service; (ii) information and communications; (iii) employment and (iv) the design of public spaces. Our Policy shows how Marketcircle will play its role in making Ontario an accessible province for all Ontarians.

Customer Service Standards

Marketcircle is committed to providing accessible customer service to people with disabilities. This means that we will provide goods and services to people with disabilities with the same high quality and timeliness as others. All goods and services provided by Marketcircle follow the principles of dignity, independence, integration and equal opportunity.

Provision of Goods, Services and Facilities to Persons with Disabilities

Marketcircle will make every reasonable effort to ensure that its policies, practices and procedures are consistent with the following core principles:

  • Our goods, services and facilities will be provided in a manner that respects the dignity and independence of persons with disabilities;
  • The provision of goods, services or facilities to persons with disabilities will be integrated with the provision of goods, services or facilities to others, unless an alternative measure is necessary, whether temporarily or on a permanent basis, to enable a person with a disability to obtain, use or benefit from our goods, services or facilities;
  • Persons with disabilities will be given an opportunity equal to that given to others to obtain, use and benefit from our goods, services or facilities; and
  • When communicating with a person with a disability, we will do so in a manner that takes into account the person’s disability.

Currently, Marketcircle operates as a remote workplace and does not have a physical office space or related facilities. However, any future office space and related facilities will be provided in accordance with the foregoing core principles.

Assistive Devices

Persons with a disability are permitted, where possible, to use their own assistive devices for the purposes of obtaining, using or benefiting from our goods, services and facilities. If it is not possible to use an assistive device while accessing our goods, services and facilities, Marketcircle will use its best efforts to provide an alternative means of assistance to the person with a disability. We will ensure that our staff is trained and familiar with various assistive devices that may be used by individuals with disabilities while accessing our goods, services and facilities. We will also permit the use of assistive devices by persons with disabilities, where possible, while on any premises which we operate in the future.

Service Animals

Should we operate from a physical office space in the future, a customer with a disability that is accompanied by a guide dog or other service animal will be allowed access to those parts of our premises that are open to the public, unless otherwise excluded by law. If a guide dog or other service animal is excluded from parts of our premises by law, staff at Marketcircle will accompany a person with a disability in the absence of their service animal. If it is not readily apparent that the animal is being used by a person for reasons relating to his or her disability, Marketcircle may request verification from that individual. Marketcircle welcomes suggestions with respect to other measures that we can make available to persons with disabilities in order to allow them to obtain, use and benefit from our goods, services and facilities.

Support Persons

An individual with a disability may have access to a support person while obtaining, using or benefiting from our goods, services and facilities. Should we operate from a physical office space in the future, Marketcircle may require a person with a disability to be accompanied by a support person where it is necessary to protect the health and safety of the person with a disability or the health or safety of others on the premises. Before making a decision to require a support person, Marketcircle will:

  • consult with the person with a disability to understand their needs;
  • consider health or safety reasons based on the available evidence; and
  • determine if there is any other reasonable way to protect the health or safety of the person or others on the premises.

In situations where confidential information might be discussed with a customer with a disability, the customer’s consent will be required to discuss confidential matters in the presence of their support person prior to initiating the conversation.

Notice of Temporary Disruptions

Service disruptions may occur due to reasons that may or may not be within the control or knowledge of Marketcircle. For instance, there may be times when we experience technical difficulties with our internet, website or phone lines, or when we have trouble connecting to our data center. In the event of any temporary disruption to facilities or services that individuals with disabilities rely upon to access or use Marketcircle’s goods, services or facilities, reasonable efforts will be made to provide advance notice of the disruption. In some circumstances, such as unplanned temporary disruptions, advance notice may not be possible.

A notice of disruption will include information about the reason for the disruption, its anticipated length of time, and a description of alternative facilities or services, if available. Marketcircle will provide notice by:

  • posting notices in visible places on its website or through messages on our phonelines;
  • contacting individuals who have virtual appointments scheduled (e.g. by phone or email);
  • verbally notifying individuals when they are making a virtual appointment; or
  • by any other method that may be reasonable in the circumstances.

Initiatives

The following measures have been implemented by Marketcircle to ensure compliance with the customer service accessibility standard:

  • Our Business Operations Team oversees our accessibility practices and procedures;
  • This Policy is available to our customers upon request, in an accessible format;
  • We review our Accessibility Policy annually and revise it as necessary to improve accessibility;
  • Notice will be provided on our website, over the phone, and/or in writing when possible, when a service disruption occurs and will be done as quickly as possible if the disruption is unexpected;
  • We have designated an internal officer who is responsible for developing and coordinating appropriate accessibility training of our employees, volunteers and other persons who provide goods, services and facilities on Marketcircle’s behalf;
  • Training session(s) on accessibility have been provided to all employees, volunteers and other persons who provide goods, services and facilities on Marketcircle’s behalf;
  • Training on accessibility will be provided to new employees and volunteers at Marketcircle as part of their orientation;
  • Training is provided in respect of any changes to Marketcircle’s accessibility policies on an ongoing basis;
  • Training is tracked and recorded upon completion;
  • Comments relating to the accessibility of our customer service are welcomed and appreciated. A process has been established to encourage feedback regarding the way in which Marketcircle provides goods and services to people with disabilities. This feedback can be made: by phone, by e-mail, through our customer service surveys or otherwise in writing. All feedback will be directed to our Business Operations Team;
  • A process is in place to ensure that all feedback collected from customers, staff or the general public is reviewed and analyzed to identify potential gaps in customer services, and to ensure appropriate actions are taken.

Information and Communications Standards

Marketcircle is committed to meeting the communication needs of people with disabilities. We will consult with people with disabilities to determine their information and communication needs. We want to achieve the most effective and efficient access to information for all users.

Marketcircle has undertaken the following initiatives to ensure compliance with this standard:

Accessible Emergency Information

Should Marketcircle operate a physical premises in the future, we will provide our employees and customers with publicly available emergency information in an accessible way upon request. We will develop an Emergency Response Plan, which will be made available in an accessible format upon request.

Marketcircle will also provide employees with disabilities with individualized emergency response information when necessary, and as soon as practically possible. If an employee who receives individualized workplace emergency response information requires assistance, with the employee’s consent, the workplace emergency response information will be given to the designated employee providing the assistance.

Marketcircle will create a process for documenting issues of accessibility and recording and providing accommodation for individuals requiring individualized emergency response plans. Marketcircle will review the individualized emergency response plans when necessary, such as when the location of the employee changes.

Website and Content

Marketcircle’s website and the content on that site conform to World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, Level A. Marketcircle commits to conform to WCAG 2.0, Level AA by January 1, 2021. Compliance with AODA will be included as one of the criteria in selecting technology vendors for new website development initiatives.

Accessible Formats and Communication Supports

Marketcircle provides accessible formats and communications supports to persons with disabilities. Requests for accessible formats and communications supports are dealt with in a timely manner. Marketcircle takes into account the person’s accessibility needs due to a disability by consulting with persons making the request to determine the suitability of the accessible format or communications support. As well, we will provide accessible formats and communications supports to persons with disabilities at a cost that is no more than the regular cost charged to other persons.

Feedback Process

Individuals who wish to provide feedback on the way that Marketcircle provides goods and services to people with disabilities can contact our Business Operations Team. Feedback may be provided by telephone (905-480-5555), electronically (info@marketcircle.com), or through our customer service surveys or by other available methods.

All feedback will be directed to our Business Operations Team. Individuals who provide feedback can expect to hear back from us within seven (7) days. Complaints will be addressed in accordance with Marketcircle’s regular complaints procedure.

We ensure that existing and new processes for receiving and responding to feedback are accessible to persons with disabilities by providing or arranging to provide accessible formats and communications supports, upon request.

Employment Standards

Marketcircle is committed to fair and accessible employment practices. We have taken the following steps to make employment at Marketcircle more accessible to persons with disabilities:

Recruitment

Marketcircle notifies its employees and the public about the availability of accommodation for applicants with disabilities during the recruitment processes, including in its job postings and on the “Careers” page of its website.

In addition, we will notify job applicants (either by phone or in writing) when they are individually selected to participate in an assessment or selection process, that accommodations are available upon request in relation to the materials or processes to be used.

Marketcircle will consult with selected applicants if accommodation is requested by them. We will provide or arrange to provide suitable accommodation to selected applicants in a manner that takes into account their accessibility needs due to a disability.

When making offers of employment, Marketcircle will notify successful applicants of our policies for accommodating employees with disabilities. Marketcircle will review and modify its existing recruitment policies, procedures and processes, as necessary to ensure accessibility in its recruitment process.

Supports for Employees

Marketcircle informs all employees of its policies that support employees with disabilities including, but not limited to, policies on the provision of job accommodations that take into account an employee’s accessibility needs due to disability. We have developed an Accommodation Policy and Return to Work Policy to support employees with disabilities. Information about our policies supporting employees with disabilities is provided as soon as practicable after a new hire begins employment, and whenever accommodation is requested by an employee.

As well, Marketcircle keeps employees updated on changes to existing policies on the provision of job accommodations that take into account an employee’s accessibility needs due to disability.

Where an employee with a disability so requests it, Marketcircle will consult with the employee to provide or arrange to provide suitable accessible formats and communications supports for information that is needed in order to perform the employee’s job or that is generally available to employees in the workplace.

Individual Accommodation Plans/Return to Work Process

Marketcircle has created and implemented an Accommodation Policy and process to assist it in developing individual accommodation plans for employees with disabilities. We have also developed and put in place an Return to Work Policy and program for employees who have been absent due to a disability.

Marketcircle’s process for the development of documented individual accommodation plans includes the following elements:

  • The manner in which the employee requesting accommodation can participate in the development of the plan;
  • The means by which the employee is assessed on an individual basis;
  • The manner in which Marketcircle can request an evaluation by an outside medical or other expert, at our expense, to assist us in determining if and how accommodation can be achieved;
  • The manner in which the employee can request participation of a representative from the workplace;
  • The steps in place to protect the privacy of the employee’s personal information;
  • The frequency with which individual accommodation plans will be reviewed and updated and the manner in which this will be done;
  • The manner in which reasons will be provided in the event that an individual accommodation plan is denied; and
  • The means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs due to disability.

Marketcircle’s Return to Work Policy outlines the program that we will undertake to facilitate the employee’s return to work after a disability-related absence, and will use documented individual accommodation plans as part of the process. For further details on the Accommodation Policy and Return to Work Policy, employees can contact Human Resources.

Performance Management, Career Development and Redeployment

Marketcircle takes the accessibility needs of employees with disabilities and, as applicable, their individualized accommodation plans, into account when assessing performance, managing career development and advancement, and reassignment is required. For further details on Performance Management, Career Development & Redeployment, employees can contact Human Resources.

Design of Public Spaces Standard

Marketcircle will meet applicable accessibility standards when building or making major modifications to service-related elements.

For More Information

This Accessibility Policy, and information about Marketcircle’s related policies and procedures, is made available to members of the public upon request. We will provide this information in an accessible format or with communication support, upon request. For more information on this Policy, or to obtain this Policy in an accessible format, please contact:

Name: Asim Baksh, Operations Manager

Phone: 416.897.2746

Email: asim@marketcircle.com