Purpose

Liberty is committed to fostering a positive customer service environment in serving all customers, including those with disabilities.  Liberty will strive to provide services in a manner consistent with the principles of dignity, independence, integration and equal opportunity.

 

SCOPE

1. This policy applies to employees, agents and/or contractors who deal with the public or other third parties that act on behalf of Liberty.
2. The section of this policy that addresses the use of guide dogs, service animals and service dogs only applies to the provision of goods and services that take place at premises owned and operated by Liberty.  
3. This policy shall also apply to all persons who participate in the development of Liberty policies, practices and procedures governing the provision of goods and services to members of the public or third parties.

 

DEFINITIONS

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.

 

Disability – the term 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;
• an injury or disability for which benefits were claimed or received under an insurance plan established pursuant to applicable law; or
• such other conditions or disabilities as may be defined in applicable laws or standards (for example, accessibility or similar legislation or human rights codes).

 

Guide Dog– is a highly-trained working dog that has been in accordance with any applicable requirements, to provide mobility, safety and increased independence for people who are blind.

                                                                                                 

Service Animal – 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 Dog  – 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 physician or nurse confirming that the person requires a service dog.

 

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.

 

PRINCIPLES

A. The Provision of Goods and Services to Persons with Disabilities

Liberty will make every reasonable effort to ensure that its policies, practices and procedures are consistent with the principles of dignity, independence, integration and equal opportunity by:

• ensuring that all customers receive the same value and quality;
• allowing customers with disabilities to do things in their own ways, at their own pace when accessing goods and services as long as this does not present a safety risk;
• using alternative methods when possible to ensure that customers with disabilities have access to the same services, in the same place and in a similar manner;
• taking into account individual needs when providing goods and services; and
• communicating in a manner that takes into account the customer's disability.

B. The Use of Assistive Devices

Persons with disabilities may use their own assistive devices as required when accessing goods or services provided by Liberty. 

 

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 goods and services.  For example, open flames and oxygen tanks cannot be near one another.  Therefore, the accommodation of a customer with an oxygen tank may involve ensuring the customer is in a location that would be considered safe for both the customer and Liberty and its employees, agents and contractors.  Or, where elevators are not present and where an individual requires assistive devices for the purposes of mobility, service will be provided in a location that meets the needs of the customer.

C. The Use of Service Animals, Guide Dogs and Service Dogs

People with disabilities and accompanied by their service animals will be welcomed onto Liberty premises.

 

There may be rare circumstances where, for reasons of health and safety of another person, allowing a person with a disability to enter the premise accompanied by a service animal needs to be considered.  An example of such a situation may include where a person is allergic to animals and adversely affected if they are in close proximity to a service animal. If necessary, a risk assessment will be conducted by Liberty.

 

The person accompanied by a service animal is responsible for maintaining care and control of the service animal at all times, including ensuring the safety and clean-up of the service animal.

D. The Use of Support Persons

A person with a disability who is accompanied by a support person will be allowed to have that person accompany them on Liberty premises.

In situations where confidential information might be discussed, consent will be obtained from the customer, prior to any such conversation. 

E. Notice of Service Disruptions

In the event of a planned or unexpected disruption to services or facilities for customers with disabilities, for example, wheel chair accessibility, reasonable efforts will be made for customers to be notified promptly or with advance notice.

 

Notifications will be clearly posted and will include information about the reason for the disruption, its anticipated length of time, and a description of alternative facilities or services, if available.

 

The notice will be placed in conspicuous places including at the point of disruption and entrances to the building as well as on the Liberty website.

F. Customer Feedback

Liberty will provide customers the opportunity to give feedback on the provision of goods and services to people with disabilities.  Feedback forms along with alternate methods of providing feedback such as verbally (in person or by telephone) or written (hand written or email) will be available upon request. 

 

All feedback will be directed to Human Resources as well as a representative from the appropriate department.

 

Where possible, feedback will be addressed immediately.  In some cases, feedback may require more review before an action is taken and Liberty will respond as soon as possible in such circumstances.

G. Training

Liberty will provide training to all employees and those involved in the development and approval of customer service policies, practices and procedures.

 

All Individuals will be trained including:  Executives, Management and Non-Management employees and training will be provided to new employees within the first three months of their employment.

 

Training will include:

• A review of the purpose of any applicable accessibility or similar legislation and the requirements thereof;
• Liberty policy and to provide accessible service to people with disabilities;
• Instructions on how to interact and communicate with people with various types of disabilities; and
• How to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person

 

Employees will also be trained when changes are made to this policy.

H. Notice of Availability

Liberty will notify the public that accessibility policies are available upon request by visiting the Liberty website or requesting a copy from the Human Resources department through your local Customer Care representative in a format that takes into account the person’s disability.