Accessibility Policy

Last updated May 1, 2024

Policy Statement

This policy describes how Health Loyalty companies will ensure that they take all reasonable measures to provide accessible service to both customers and employees with disabilities. Health Loyalty is committed to preventing, identifying and removing barriers that impede the ability of people with disabilities to access services or join our team.

People with disabilities will be given an equal opportunity to both work for Health Loyalty, and to obtain, use and benefit from Health Loyalty’ products and services in a way that is respectful of the dignity and independence of people with disabilities and in a manner which takes into account the person’s disability.

Purpose

The Americans with Disabilities Act, 1990 (“the ADA”) and the Accessibility for Ontarians with Disabilities Act, 2005 (“the AODA”) are U.S. and Canadian (Ontario) acts with the purpose of developing, implementing and mandating accessibility standards in order to achieve accessibility for persons with disabilities, with respect to goods, services, facilities, accommodation, employment, buildings, structures and premises. The regulations under these acts establish accessibility standards specific to employment and customer service for private sector organizations that provide goods and services to members of the public or other third parties.

The objective of this policy is to identify what the equal treatment provisions of these acts require with respect to employment and service delivery to persons with disabilities and addresses the following:

The Employment of Persons with Disabilities
The Provision of Goods and Services to Persons with Disabilities
The Use of Assistive Devices
The Use of Guide Dogs and Service Animals
The Use of Support Persons
Notice of Service Disruptions
Customer Feedback
Training
Notice of Availability and Format of Required Documents

Accountabilities

The Health Loyalty Executive Committee is accountable to and responsible for:

The governance of the policy

Compliance with legislative requirements, including fiscal responsibility, human costs and human rights issues
Supporting and promoting the policy in their area of direct reporting and throughout the organization
Driving the culture to a high level of understanding regarding disability and accommodation

Health Loyalty Directors and Managers are accountable to and responsible for:

Fostering open and constructive communication

Demonstrating sensitivity to and respect confidentiality of information
Raising awareness to facilitate understanding of the policy
Participating and co-operating to facilitate workplace accommodation

Health Loyalty Employees are accountable to and responsible for:

Participating and cooperating with all parties to facilitate workplace accommodation.

Health Loyalty Human Resources is accountable to and responsible for:

Participating and cooperating with all parties
Acting as a resource for all parties and participants
Supporting and educating managers in their obligations under the policy

Procedure

Health Loyalty is committed to ensuring all participants have equal access to employment in our organization, and access to the services we provide. We will do this by:

Establishing policies, procedures and practices that describe how our employment practices will be designed to meet the needs of employees and job applicants with disabilities
Using reasonable effort to ensure our participant policies are consistent with the principles of dignity, independence, integration of services, and equal of opportunity
Dealing with the use of assistive devices for people with disabilities in our policies
Welcoming people accompanied by guide dogs, service animals or support people and providing information about access
Providing clear, complete, timely and prominent notice of temporary disruption of any of our facilities used by people with disabilities to help them access our services
Providing timely and ongoing training to our staff, who deal with participants, to ensure their understanding of and ability to implement our policies regarding service to people with disabilities
Implementing and communicating our processes for receiving and responding to feedback and handling complaints about how we provide services to people with disabilities
Complying with documentation standard, including availability and format of documents.

Accessible Workplaces

Hiring

Health Loyalty is committed to provide an accessible workplace by eliminating barriers in all our employment policies, procedures, and practices. Health Loyalty welcomes and encourages applications from people with disabilities, as well as provides employees with disabilities the same opportunities and services as other employees. All job applicants and the public will be notified that accommodations are available on request for candidates with disabilities that are taking part in all aspects of the selection process. This notification will be included in all job postings of Health Loyalty.

Workplace information

All general information that is available to all employees at work (i.e.: emergency and public safety information, feedback processes for employees and other public information) and any information that the employee needs to perform the job will be provided upon request to the employee.

Customer Service Policy, Practice and Procedure

The Provision of Goods and Services to Persons with Disabilities

Health Loyalty 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
Communicating in a manner that takes into account the customer’s disability
Health Loyalty employees and representatives will be encouraged to be pro-active in seeking solutions and removing barriers, as well as alerting all customers to the range of accommodations that are available.

The term “persons with disabilities” will be the norm, and if a specific condition must be referenced, the condition will be referenced last (e.g., person with low vision). The following are some general tips that may help make communication and interaction with or about people with all types of disabilities more successful:

Remember to put people first. It is proper to say person with a disability, rather than disabled person or the disabled.
It is best to wait until an individual describes his or her situation to you, rather than to make your own assumptions. Many types of disabilities have similar characteristics and assumptions may be wrong.

When Health Loyalty bills for services, it should demonstrate a commitment to providing accessible invoices to all customers. This means that invoices should be provided in alternate formats upon request (e.g., hard copy, large print, email) and that staffs are prepared to answer questions customers may have about the content of the invoice.

Notice of Disruptions in Service

Service disruptions may occur due to reasons that may or may not be within Health Loyalty’ control or knowledge. In the event of any temporary disruptions to facilities or services that are relied upon by customers with disabilities, Health Loyalty will provide advance notice of the disruption where possible.

Notification Information

In the event of a temporary disruption, notification of the disruption will include the following information:

Goods or services that are disrupted or unavailable
Reason for the disruption
Anticipated duration
A description of alternative services or options

Posting of Notifications

When temporary disruptions occur, Health Loyalty will provide notice by:

Posting notices in conspicuous places on the premises and/or on the Health Loyalty website
Contacting customers with appointments scheduled during the disruption
Verbally notifying customers when they are making a reservation or appointment
Or any other methods that may be reasonable under the circumstances

Workplace Emergency Response Information

In addition to providing customers with disabilities full accessibility to goods and services at all times in a way that respects their dignity and independence, Health Loyalty is committed to providing employees with disabilities with the same opportunities as other employees. With this in mind, Health Loyalty will provide individualized workplace emergency response information to all employees with a visible or non-visible disability, if the individual so requires. This information can also be provided to the employee who is designated to assist the employee with disabilities.

Feedback process

Health Loyalty shall provide customers with the opportunity to provide feedback on the goods and services provided to customers with disabilities.

Customers who wish to provide feedback may do so by emailing accessibility@healthloyalty.com. Customers may additionally provide their feedback to any Health Loyalty employee, or by contacting our Accessibility Officer at (905) 477-3100.