Accessibility at Grebel

Effective: April 2018
Replaces: New
Review Date: With UW Reviews
Responsible Department: Administrative Executive
Approval Body: Board

Conrad Grebel University College wishes to foster an accessible campus environment for persons with disabilities and is committed to achieving accessibility and the requirements established under the Accessibility for Ontarians with Disabilities Act.

The College follows University of Waterloo’s “Policy 58 – Accessibility,” which may be amended from time to time, and co-operates with the University in implementing the provisions of this policy, as is produced below.

University of Waterloo Policy 58 – Accessibility

The policies found on the website of the Secretariat are compulsory rules for the University community. The authoritative copies of the policies are held by the Secretariat and bear the seal of the University. The online version accessible through the website of the Secretariat is available for information purposes only. In case of discrepancy between the online version and the authoritative copy held by the Secretariat, the authoritative copy shall prevail.

Please contact the Secretariat for assistance if necessary.

Established: [Insert date of final approval in accordance with Policy1.]
Revised: N/A
Mandatory Review Date: [If a new policy, insert the second anniversary of the
Establishment date.  If revised, insert the fifth anniversary after the date when last revised.]
Supersedes: N/A
Class: G
Responsible/Originating Department: Human Resources
Executive Contact: Marilyn Thompson, Associate Provost, Human Resources

Related Policies, Guidelines and Procedures:

Policy 11 – University Risk Management

Policy 17 – Quotations and Tenders

Policy 18 – Staff Employment

Policy 22 – Regulations Governing the Installation of Equipment in University Buildings

Policy 32 – Animals on University Property

Policy 33 – Ethical Behaviour

Policy 34 – Health, Safety, and Environment

Policy 46 – Information Management

Policy 60 – University of Waterloo Emergency Response

Policy 65 – Equality in Employment

1. Statement of Commitment

The University of Waterloo is committed to achieving accessibility and its requirements established under the Accessibility for Ontarians with Disabilities Act (AODA). The University is committed to fostering an accessible campus environment for persons with disabilities.

2. Scope

The provisions of this policy apply to all University employees, students, visitors, volunteers, applicants, and clients. It also applies to any other party that provides goods, services, and/or facilities on behalf of the University.

Nothing in this policy shall be interpreted in any way as limiting the rights and privileges conferred under the Memorandum of Agreement between the Faculty Association of the University of Waterloo and the University of Waterloo, the University of Waterloo Staff Association and University of Waterloo Memorandum of Agreement, and the Collective Agreement between the University of Waterloo and CUPE Local 793 (collectively the “Agreements”). In case of a conflict, precedence shall be given first to those Agreements, then to University policies, procedures and guidelines.

[See Appendix B.]

3. Legal Framework

The policy will be construed in accordance with applicable law, in particular, the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11 (AODA) and its regulations. Other applicable law includes:

• Ontario Human Rights Code, R.S.O 1990, c. H. 19
• Building Code Act, 1992, S.O. 1992, c. 23
• Workplace Safety and Insurance Act, 1997, S.O. 1997, c.16
• Health Protection and Promotion Act, R.S.O. 1990, c. H.7
• Employment Standards Act, 2000, S.O. 2000, c. 4;1
• Occupational Health and Safety Act, R.S.O. 1990, c. O.1.
• Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c. F.31

If any of these legal provisions are modified, abrogated, superseded, or added to, the policy will be interpreted in accordance with the new legal framework.

[See Appendix A.]

4. Purpose

This policy is intended to be read in conjunction with, and support the development of policies, practices and procedures that contribute to accessibility to, and Equal Opportunity for, use of goods, services and facilities within the University community. This policy will function as the principle policy for the requirements under the AODA.

5. Principles

The University demonstrates the concept of accessibility by fostering an environment that treats persons with Disabilities with respect, guided by the following principles:

• Dignity: providing service in a way that ensures self-respect and the respect of others by maintaining the Independence and free participation of persons with disabilities.
• Independence: ability to engage with the environment on their own, without unnecessary help or interference from others
• Integration: providing service or goods in a way that allows the person to fully benefit from the same services, in the same place, and in the same or similar ways as other persons
• Equal Opportunity: having the same chances, options, and benefits to achieve the same results as others. In the case of services, it means that the individual has the same opportunity as others to benefit from the services provided, without needing significantly more effort to access or obtain services, nor accept lesser quality.

The University is committed to treating people with Disabilities in a way that allows them to maintain their Dignity, and Independence. The University believes in Integration and is committed to meeting the needs of people with Disabilities in a timely manner, by taking steps to identify, eliminate, minimize or prevent Barriers to accessibility. The University recognizes that Barriers include physical, environmental, attitudinal, communication and technological components that may prevent the full participation of and Equal Opportunity for persons with Disabilities in the University community.

6. Confidentiality and Privacy

The University recognizes that the privacy of the individuals contemplated under the scope in this policy is of the utmost importance. Confidentiality is to be ensured and information is to be managed as prescribed under legislation (see FIPPA and Policy 46).

7. Information and Communication

The University will communicate with people with disabilities in ways that take into account their Disability. When asked, information about the University and its services, including public safety information, will be provided in accessible formats or with communication supports.

The University will meet Web Content Accessibility Guidelines (WCAG) 2.0 Level AA for all Public Websites, in accordance with AODA. The University recognizes that certain public web content are considered special collections archival materials, and/or educational material that may be exempt from meeting WCAG 2.0 guidelines. In such instances, the University will provide the information in an accessible or Conversion Ready format, upon request.

8. Temporary Service Disruption

The University will disseminate information regarding a temporary disruption in services including building entrances, elevators, washroom facilities, and access to technology. The University will post notices of estimated timelines, reasons for disruption, alternate access, and will make every effort to ensure the University Community and the public is notified in advance if and when feasible.

9. Assistive Devices

The University makes every effort to ensure that persons with disabilities can use their own personal assistive devices to access goods and use services. If the University is unable to accommodate the use of personal assistive devices, the University will work with the person to provide a reasonable solution.

10. Support Persons and Service Animals

The University permits persons with Disabilities to bring a Support Person while accessing goods or services. Individuals who require the presence of a Support Person are asked to identify their need in advance so that notice can be provided ahead of time on what admission, if any, is charged for a Support Person. Where admission fees are charged, the University shall waive all fees for a Support Person of a person with Disabilities.

The University allows persons with Disabilities to be accompanied by their Service Animal in areas that are open to the public, unless the animal is excluded by law. For certain areas in which a Service Animal may be excluded by law, such as food service preparation areas, the University will provide alternate measures that promote access to services by the person with a Disability.  The Service Animal must be with their owner and under full control at all times.      If the Service Animal is not with their owner, the animal ceases to provide “service”, and will be treated as an Animal, and will be subject to the guidelines outlined in Policy 32 – Animals on University Property. Employment Employees, potential hires, and the public are notified that Accommodations can be made during the recruitment and hiring process, and throughout the full employment life cycle. The University will put in place a process to develop individual Accommodation plans for employees. Where needed, the University will also provide customized emergency information to help an employee with a Disability during an emergency. The University’s performance management, career development and redeployment processes will take into account the accessibility needs of all employees.

The University of Waterloo is committed to equitable employment and encourages applications from all qualified candidates. The University will work with its employee groups to determine the need for additional policies, standards and/or guidelines that address accessibility and accommodation within the workplace.

[See Appendix B.]

11. Education

The University is committed to meeting its requirements for accessible education. The University will create an accessible educational environment where students with disabilities can participate in a way that is appropriate.

12. Training

The University will provide accessibility training to all employees, volunteers, and any individual who provides goods, services, or facilities on behalf of the organization. The University will provide ongoing training to all employees and volunteers on any changes to this policy in a timely manner. The University will provide additional training to employees and volunteers as it relates to their specific role when required.

13. Public Spaces

The University will meet accessibility laws for any newly constructed or redeveloped Public Spaces owned by the University. The University will put procedures in place to prevent service disruptions to our accessible parts of our Public Spaces. The University will consult with the public and persons with Disabilities on matters related to said Public Spaces, and will meet the intent of the Ontario Building Code where applicable.

14. Procurement and Self-Service Kiosks

The University is committed to accessible procurement processes. The University will incorporate accessibility features/ consider accessibility for people with disabilities when designing, procuring or acquiring self-service kiosks.

15. Feedback and Complaint Process

The University will facilitate mechanisms for receiving feedback and filing complaints for accessibility related matters on University property and the University website, including use of the Accessibility Committee as a central source for receiving feedback and addressing concerns.

16. Accessibility Committee

In order to demonstrate the University’s ongoing commitment to accessibility for persons with Disabilities, the Accessibility Committee will meet regularly to provide a forum for consultation on accessibility initiatives campus-wide, and advise University leadership on opportunities for accessibility practices for persons with Disabilities. Advisory to the Associate Provost, Human Resources, this Committee's mandate includes developing and maintaining a multi-year accessibility plan and ensuring the University’s ongoing legislative compliance. The committee shall consist of representatives from each of the employee and student groups, as well as University departments identified to have influence and/or involvement with accessibility issues.

Appendix A

Definitions

In this policy, the following terms shall have the following meanings:

“Accommodation”, per Ontario Human Rights Commission’s guidelines, means the individualized process whereby the organization will remove Barriers for persons with disabilities to allow for Equal Opportunity in accessing the same level of service, performance, or enjoy the same level of benefits and privileges enjoyed by others. At the University, this applies to all students, employees, and visitors.

“Barrier”, per AODA, means anything that prevents a person with a Disability from fully participating in all aspects of society because of his or her Disability, including a physical, architectural, informational or communicative, attitudinal, technological, or through policy or practice. This applies to all goods, services, and facilities provided on behalf of the University that is within the University’s control.

“Conversion Ready”, as per AODA, means an electronic or digital format that facilitates conversion into an accessible format.

“Dignity”, as per Ontario Human Rights Commission’s guidelines, refers to providing service in a way that ensures self-respect and the respect of others by maintaining the Independence and free participation of persons with disabilities.

“Disability”, per OHRC, means one or more of the following:

1. any degree of physical Disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness,
2. a condition of mental impairment or a developmental Disability,
3. a learning Disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,
4. a mental disorder,
5. an injury or Disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997; (“handicap”)

“Equal Opportunity”, as per Ontario Human Rights Commission’s guidelines, means having the same chances, options, and benefits as others. In the case of services, it means that the individual has the same opportunity as others to benefit from the services provided, without needing significantly more effort to access or obtain services, nor accept lesser quality.

“Independence”, as per Ontario Human Rights Commission’s guidelines, means a person is able to engage with the environment on their own, without unnecessary help or interference from others

“Integration”, as per Ontario Human Rights Commission’s guidelines, means providing service or goods in a way that allows the individual to fully benefit from the same services, in the same place, and in the same or similar ways as other individuals

“Public Spaces”, as per AODA, include:

• Recreational trails/beach access routes
• Outdoor public eating areas
• Outdoor play spaces
• Outdoor paths of travel
• Accessible off-street parking
• Accessible on-street parking
• Service-related elements including service counters, fixed queuing lines and waiting areas

“Public Websites” means internet website, as defined by the AODA, that is “accessible to the public”. For the University, this also includes any newly developed website that is accessible to all University students, beyond the definition outlined in the AODA.

“Service Animal”, as defined by the AODA, is an animal that services a person with Disability and can be

1. readily identified as one that is being used by the person for reasons relating to the person’s Disability, as a result of visual indicators such as the vest or harness worn by the animal; or
2. the person provides documentation from one of the nine regulated health professionals named within the AODA, confirming that the person requires the animal for reasons relating to the Disability.

“Support Person”, per AODA, means, in relation to a person with a Disability, another person who accompanies them in order to help with communication, mobility, personal care or medical needs or with access to goods, services or facilities.

Appendix B

This policy will be complemented by a separate FS-class policy concerning accessibility for University of Waterloo faculty and staff. When that policy comes into effect, (1) it shall override portions of this policy that concern employment conditions, (2) in the case of any conflict between the new FS policy and Policy 58, the FS policy shall prevail, and (3) this appendix will be removed from Policy 58.

Approved by AE – January 11, 2018

Approved by CC – January 12, 2018

Approved by Board – April 24, 2018

This document is available in accessible formats upon request.

Message from the President

This is Grebel’s first Multiyear accessibility plan (2021). While Grebel priorities are driven largely by the standards set within the Accessibility for Ontarians with Disabilities Act (AODA), we have been hard at work upgrading our spaces in the last three years to address many of the accessibility challenges our users face.

As we highlight and celebrate our achievements over the last year, we will continue to build momentum and consider accessibility in everything that we do. We will not be complacent in our efforts, and recognize that this past year has been a catapult start to our journey of becoming an accessibility champion, and not the end of a goal achieved.

Marcus Shantz
President

Territorial Acknowledgement

Conrad Grebel University College is situated on the traditional territory of the Attawandaron (Neutral), Anishinaabeg and Haudenosaunee peoples. The College, and the University of Waterloo, was built on the Haldimand Tract, the land granted in 1784 to the Six Nations that includes 10 kilometres on each side of the Grand River from its source in Dundalk to its mouth at Lake Erie.

The Mennonites were the first permanent white settlers in the area we know today as Waterloo Region. In the early 19th century, the initial settlers were led to the Grand River, with its surrounding fertile soil and forests by a guide from the Mississauga of the Anishinaabe peoples who lived here and understood the land. In 1805 Mennonites from Pennsylvania purchased 60,000 acres of land – Block 2 of the Haldimand Tract – in present-day Kitchener-Waterloo.

Mennonites now live, and continue to settle, on the full length of the Haldimand Tract. The land was granted to support the Six Nations in perpetuity, but this did not happen. Our work at reconciliation with Indigenous peoples includes decolonizing our historical narratives, our minds, and our hearts. This is an ongoing process, and we have a long way to go.  We do this in humility and gratitude to our Indigenous neighbours, past and present.

Introduction

Conrad Grebel University College is committed to fostering an inclusive and accessible environment for staff, faculty and students with visible and non-visible disabilities. This commitment extends to the physical and virtual spaces Conrad Grebel holds, and ensures equal treatment of all patrons using our services and facilities, or partaking in our programs. The College is committed to achieving accessibility and the requirements established under the Accessibility for Ontarians with Disabilities Act (AODA). In accordance with AODA requirements, Conrad Grebel will outline in this document a Multi-Year Accessibility Plan which will communicate accessibility accomplishments to date and goals for adapting and expanding accessibility measures over the next five years.

The plan outlined in this document is intended to complement and coordinate with accessibility commitments of the University of Waterloo. The College follows the framework outlined in University of Waterloo’s Policy 58 – Accessibility and has adopted this same policy as our own Policy 22 - Accessibility. As an affiliated college of the University of Waterloo, Conrad Grebel understands the responsibility associated with upholding a standard of accessibility so that it is consistent across the entire institution. Conrad Grebel supports and shares in the policies and procedures defined by Waterloo’s Accessibility Committee. While aligning with Waterloo protocols, Conrad Grebel will aim to take an approach to improve accessibility that focuses on ensuring the wellbeing and accommodation of all our stakeholders. The College will continue to focus its planning processes on establishing measurable outcomes of improvement.

Recent Accomplishments: 

Academic Accommodations

In the past four academic terms, Grebel courses have moved to online instruction. The Academic Program at Grebel has encouraged faculty and adjunct instructors to adopt the University-wide Web Accessibility standards. Faculty at Grebel are obligated to meet Web Content Accessibility Guidelines WCAG 2.0 Level AA for all public websites, in accordance with AODA legislation as outlined in Policy 22 - Accessibility. Grebel faculty complies with these standards by building course sites in the Waterloo Content Management System or UWaterloo Scholar. Grebel instructors have also been provided with resources for their own review and references, including the Web Content Accessibility Guidelines 2.0, Council of Ontario Universities Toolkit (for Section 14) and Library Accessibility Services AODA Toolkit.

Systems have been put in place in Grebel academics to ensure course materials follow a standard accessible format that is consistent across departments. At the beginning of each term course syllabi requests are sent to all faculty and adjunct instructors with attached templates and samples so that faculty members are able to ensure their course syllabi are in an accessible format. This format ensures that e-readers are able to properly read these documents for those who are visually impaired. Once syllabi are submitted, the Administrative Assistant to the Academic Program reviews all syllabi and course schedules, checking them and fixing any accessibility errors. Once syllabi are confirmed accessible, they are sent back to instructors for their own distribution and a copy is kept for Grebel Academics archives. This process takes place at the beginning of every new academic term.

Conrad Grebel oversees the administration and instruction of the Conflict Resolution Certificate program. Workshop delivery changes are available in conjunction with requests to accommodate. This includes availability of large print manuals, alternate media forms of workshop content for those with hearing impairment, and accommodating the presence of support people. Any less typical requests are completed in consultation with the University of Waterloo Accessibility Office.

Assistive Technology

In conjunction with the University of Waterloo Accessibility Services, Grebel Students are now able to access Kurzweil software assistive technology on any computer at Waterloo. This will allow students to access digital material in a format that is most conducive to their needs anywhere on campus - not limited by one particular computer lab or area of campus.

Student Services

Student Services at Conrad Grebel is committed to ensuring all students studying, visiting or living at Grebel have access to support services and any necessary accommodations. Recent accessibility accomplishments include:

• Gender neutral programming and residence spaces that are inclusive of cis-gendered, transgender, non-binary and genderfluid individuals.
• Mental health programming throughout academic terms and central to in-residence events in order to foster an environment of support where all students feel safe.
• Alternative text is now available for online images on the Student Services website.

Facility

Grebel’s facility structure has undergone extensive renovations in the past year in order to improve accessibility infrastructure. Improvements made include:

• Power door operators (approximately 16) have been added throughout the facility so that all public areas are now more easily accessed.
• Electric door hold opens have been added in at least three locations to allow for easier travel through the facility.
• An elevator has been added to improve public access to the dining room and chapel.
• Light levels have been increased in many public spaces.
• Four new private, gender-neutral, accessible washrooms have been added (in addition to the one in the library which was created in 2014).  Our facility now has accessible washrooms on every floor.
• Outdoor ramps have been added which improve access to the main floor (level 2) of the building.
• All paths and walkways around the College have been repaved, some of them have been made wider and in one location, a railing added to assist with navigating the steep slope of the path.
• Additional projectors and public address speakers have been added to improve the video and audio experience in the dining room.
• The circle of garden swings, we intentionally left a couple of sections empty so that people could join the circle without having to sit on a swing.

If accessible parts of the facility are not working or available, notices will be publicly posted with alternate plans for people requiring those facilities. The accessible parts of our public outdoor eating area (empty space at a table so that an individual using a wheelchair can use the table) will be maintained through regular visual inspection of tables, ground around the tables and space around the tables by maintenance personnel. Accessible service counters will be maintained through regular inspection and cleaning by food services staff.

Library

The Milton Good Library at Conrad Grebel takes the lead from the University of Waterloo Library on the Customer Service Standard. The UW library provides training materials, etc. Our students, as University of Waterloo students, can access the Library Accessibility Services provided by the University of Waterloo Library.

In accordance with the Information and Communications Standard, Milton Good Library has implemented use of UW-provided content management systems and scanning procedures (for course reserves) that are compliant.

In accordance with the Public Space Design Standard, the library has implemented a universal washroom, an accessible elevator, appropriate table heights, and spacing in the study, stacks and exhibit areas that allow for minimum 3’ passageways and 5’ turning radii.

Food Services

Grebel’s Food Services has recently implemented a number of new accessible infrastructure elements to their operations, this includes:

• A barrier-free washroom for staff has been added.
• Better, brighter lighting in the main kitchen and cafeteria serving area for improved visibility.
• Two adjustable height workstations have been added to accommodate staff of different heights and staff who need to sit.
• The kitchen has been made directly accessible from an outdoor ramp.
• Aisles in the main kitchen and cafeteria serving area are significantly wider for improved mobility.
• Improved lighting has been added to the dining room.
• Soup counter has been lowered so that an individual in a wheelchair can serve themselves.

In addition to the creation of accessible infrastructure, Grebel Food Services can now accommodate a variety of special diets as needed. This includes gluten-free, vegan, dairy-free, and any combination of these options.

Student Access Van

The Student Access Van is a shuttle service offered through Waterloo’s Accessibility Services that is supported through University funding and student auxiliary fees. The service is for students with a temporary or permanent disability requiring transportation support between main campus buildings, including Grebel.

Communications

The Communications department at Grebel works to ensure that all content, events and messaging prepared by Grebel staff is made with accessible formats that can be accessed by those who need them. This includes ensuring that Grebel’s website is part of the Waterloo Content Management System, which is designed to be WCAG 2.0 Level AA. In addition, captions are offered on all Grebel Youtube videos which are created and reviewed manually. The Grebel viewbook is created in the format of an accessible PDF and alt tags are used on all images on the Grebel website and e-newsletters.

Training

Grebel Staff access the University of Waterloo's employee accessibility training. This training was revised in December 2019 to include updates to both our own accessibility initiatives and the Accessibility for Ontarians with Disabilities Act (AODA). All University of Waterloo employees, whether full-time, part-time, or contract are required to complete the accessibility training and it must be up-to-date.  Training is available through the University of Waterloo’s LEARN website.

Actions for 2021-2026:

Conrad Grebel sets forth a five-year plan that will focus on bringing accessibility and inclusion to the forefront of the College’s operations while ensuring compliance with the AODA. The following initiatives have been identified as priorities and will be accomplished as per Policy 22 - Accessibility.

Policy and Procedures

Grebel will continue to remain up to date on new goals and objectives communicated by the Accessibility for Ontarians with Disabilities Act, as well as changes in provincial and federal legislation with regards to accessibility. The Operations department at Grebel will lead oversight of policy changes and communication of updates.

Grebel is committed to continually updating and reviewing its accessibility policy for students, staff and faculty. The renewal of policy extends to staff training and onboarding to ensure compliance with AODA mandates. The College will continue to work on creating policies that remove bias which could hinder the experience of Grebel for people who are differently abled.

Grebel will review and update Policy 22 and any associated policies.

Student Services

Grebel will continue to look for new and better ways to provide our students with the best experience possible. In the next five years, Student Services is planning a number of initiatives that will work to improve their accessibility to students. This will include:

• A traffic flow study to determine if the location of Student Services is optimal from an accessibility standpoint.
• The addition of an automatic door entry to the Student Services office.
• The implementation of greater and on-going training for online accessibility practices.
• A passage-ways study to determine accessibility into the gym, study rooms, music practice rooms, etc.
• The implementation of greater and on-going mental health programming and supports.
• The addition of emotional support animals.
• A study of whether or not residence rooms could be made barrier free with current furniture, room dimensions and doorways.
• The implementation of greater accessibility training for dons and student leaders.

Communications

The Information and Communication Standard within the AODA is focused on ensuring persons with disabilities are able to access information. Grebel’s communication’s department will continue to work with this in mind and ensure that content created comes in accessible formats. This will include:

• Ensuring all promotional material PDFs are accessible.
• Manually going over the last year of closed captioning on Grebel’s Youtube channel to ensure the quality of captioning.
• Pursuing having a sign language interpreter at large events.
• On all event registration forms, asking if accommodations are needed so that we are better prepared to meet those needs.

Operations

Operations has spent a considerable amount of energy in the last three years focused on the kitchen and dining room renovation and ensuring those spaces are brought up to standard. The next five years should be focused on:

• Lighting improvements in exterior and interior spaces, especially in the older spaces of the building
• Improvements to classroom technology to allow for more online classes and various levels of online/in-person student engagement

Procedures for maintenance of and notification of disruptions to accessible elements