Tbaytel's Accessibility Plan

2023

General

Tbaytel prepared this accessibility plan in accordance with the Accessible Canada Act (A.C.A.) and supporting regulations including the Canadian Radio-television and Telecommunications Commission (C.R.T.C) Accessibility Reporting Regulations. Our accessibility program considers requirements under the Employment Equity Act and the Accessibility for Ontarians with Disabilities Act. It also respects subsections of the Telecommunications and Broadcasting Acts.

If you would like to review this plan or a description of our accessibility feedback process in an accessible format that is better for you, you may request it using any of our feedback methods. We will provide it to you in print, large print, or an electronic format within 15 days of your request. If you require Braille or an audio format, we will provide it to you within 45 days of your request.

You can find accessibility information and learn how to give your feedback on the accessibility services page of our website. It is Level AA compliant with version 2.0 of the Web Content Accessibility Guidelines (W.C.A.G.).

Accessibility Statement

Tbaytel is committed to helping realize the A.C.A.’s goal of a barrier-free Canada by 2040 through the identification, removal and prevention of barriers faced by persons with disabilities. We welcome opportunities for meaningful consultation with individuals and groups from various accessibility communities, our employees and with the greater public. We value any and all feedback that will assist us in our efforts.

Executive Summary

In 2022, Tbaytel’s executive management team appointed our first Accessibility Officer. The Accessibility Officer is responsible for receiving feedback on barriers facing persons with disabilities and on our accessibility plan. The Accessibility Officer is located at 1046 Lithium Drive, Thunder Bay, Ontario, P7B 6G3

If you would like to provide feedback on our plan or about accessibility at Tbaytel (anonymous or not), you can contact us in one of the following ways:

• Fill out the online form
• Call us at 807-623-4400 or 1-800-264-9501
• Email us at accessibility@tbaytel.com

Tbaytel has created an internal accessibility committee of employees. Each member is a subject matter expert in one of the priority areas under the A.C.A. Our committee worked with a project manager to develop this accessibility plan. The accessibility committee was divided into two sub-committees for consultation and auditing. The consultation committee took on the tasks of consulting with persons with disabilities and reviewing the information received. The audit committee evaluated existing accessibility policies and practices and considered the new barriers welearned about. Together, members of the committee worked to bring forward suggestions for action items and finish our accessibility plan.

The A.C.A. identifies the following priority areas where accessibility barriers exist that hinder a person’s full and equal participation in society:

• employment
• the built environment
• information and communication technologies (I.C.T.)
• communication, other than I.C.T.
• the procurement of goods, services, and facilities
• the design and delivery of programs and services
• transportation

This accessibility plan outlines barriers identified in each area and activities that we will undertake to remove and prevent them. These action items are organized by short-term activities and future items for our medium to long-term action plan.

Consultations

To prepare our accessibility plan, we conducted an anonymous employee survey in the summer of 2022. The survey was open to our entire employee base and asked for input about accessibility at Tbaytel and how we can work to remove barriers.

Our accessibility committee engaged several organizations representing persons with different disabilities in Thunder Bay and northwestern Ontario. We also consulted the City of Thunder Bay’s Municipal Accessibility Specialist who works directly with the City of Thunder Bay Accessibility Advisory Committee. None of the organizations we reached out to were able to participate due to timing and resource availability but we look forward to working with local and regional organizations in future consultations.

As a member of the Canadian Communication Systems Alliance (C.C.S.A.), Tbaytel used a toolkit prepared by the accessibility and transit consultant firm Left Turn Right Turn to guide members while creating our accessibility plans. Left Turn Right Turn conducted two consultations with people with disabilities. Around 10 people from across Canada attended each consultation. Participants included people with a variety of disabilities including blindness, deaf-blindness, attention-deficit/hyperactivity disorder (A.D.H.D.), depression, Tourette’s syndrome, cerebral palsy, and others.

Tbaytel also relied on views provided through consultations held by the Canadian Wireless Telecommunications Association (C.W.T.A.) in the summer of 2022. C.W.T.A.’s consultation included detailed surveys and accessible virtual sessions with persons with disabilities. C.W.T.A. worked with representatives from organizations within the Canadian disability sector. This work resulted in input from six groups representing the blind and vision loss community, nine from a broad range representing speech, language, cognitive, and intellectual disabilities and nine groups from the Deaf, Deaf-Blind, and Hard of Hearing communities.

Employment

Tbaytel is committed to working with our employees, and for them, to remove accessibility barriers in the workplace. We do this by consulting with employees, developing training programs, creating learning opportunities, and understanding how to put accommodations in place. We are also dedicated to continuous improvement in our hiring processes to support a culture of respect, equity, diversity, and inclusion for all.

Barriers Identified

• External job postings can include listed requirements that exclude persons with disabilities even though they may not be mandatory to perform the duties of the position.
• Misconceptions and internal biases about persons with disabilities can impact employees’ full participation in the workplace.
• More open communication and comfort should be fostered between persons with disabilities and the people they work with. This includes giving each employee the choice to disclose their disability to managers and co-workers or keep it confidential.

Short-Term Action Plan

• We will review all new job descriptions as they are created and current descriptions as changes are made to make sure that requirements are accurate.
• We will also add the ability to communicate in American Sign Language (A.S.L.) or Quebec Sign Language (L.S.Q.) as a preferred qualification on customer-facing job descriptions.

Medium to Long-Term Action Plan

• Tbaytel is planning a review of accessibility training materials (including communication training) to determine where improvements can be made.
• We will research available resources to assist with developing training programs, including local organizations representing persons with disabilities.
• We will continue to educate employees about our policies and procedures relating to accessibility, including how to request workplace accommodations for any accessibility needs.
• We ask employees and applicants if they identify as a person with a disability and responses remain strictly with Human Resources. We will more clearly communicate that their disclosure will not be shared and the choice is their own to disclose the information to managers or co-workers if they want.
• We plan to increase communication to our employees about the supports available for training and education opportunities, which could include A.S.L. and L.S.Q. classes.
• Our Human Resources department will continue with inclusion, diversity, and bias training rolled out through Tbaytel’s company-wide training program.

The Built Environment

Understanding how persons with disabilities use and interact with physical spaces is essential to removing barriers that prevent their full access and participation. This is true for Tbaytel employees at work, visitors to our buildings, and customers shopping for telecommunications services at our retail store.

Barriers Identified

• Additional or larger bathrooms on the main floor of Tbaytel’s corporate headquarters building would be beneficial for wheelchair users.
• Automatic door buttons should hold the door open longer for some doors.
• Lunchrooms could have more accessible appliances for wheelchair users.
• At Tbaytel’s main corporate location, it is difficult to access the security scanner in relation to where the automatic door buttons are located.
• Work stations at the retail store are spaced too closely together creating a barrier for persons with mobility disabilities and wheelchair users.
• Even though some customers prefer to stand or may be unable to sit down, not every desk in the retail store has a chair for customers to use if they need one.
• The accessible toilet in the men’s washroom at Tbaytel’s work center location has two pull doors. This creates a barrier for wheelchair users because it is difficult to get past both.
• Accessible parking spots in parking lots have been occupied by vehicles without accessible parking permits.
• People with certain disabilities are impacted more than others by environmental stimulants and can experience sensory issues or distractions in different environments or spaces.

Short-Term Action Plan

• Add parking violation/vehicle towing signage to deter wrongful parking without accessible parking permits.

Medium to Long-Term Action Plan

• We will ensure all doors have automatic openers in good working condition that are properly positioned for persons with mobility or dexterity disabilities and wheelchair users.
• We will determine who at Tbaytel will regularly monitor and enforce accessible parking and communicate reminders to employees about observing and reporting.
• Tbaytel will work with employees with autism, A.D.H.D., or other learning or developmental disabilities to introduce appropriate sensory stimulus controls as requested. Additional education to all employees about how to seek out the accommodations they need will also help remove barriers for these individuals.
• We will look for opportunities for more flexible function in customer and public facing spaces. The needs of all persons with disabilities are unique, even within a specific disability community, so we will consider adaptable options where possible.
• Our accessibility committee will work with Human Resources and Tbaytel’s Joint Health and Safety Committee to design more accessible work spaces and break areas as opportunities arise.

Information and Communication Technologies (I.C.T.)

With the constant evolution of digital communication, reducing barriers in information and communication technologies (I.C.T.) is essential to ensuring that persons with disabilities can fully and equally participate in society. Researching I.C.T. available, how it works, and how customers and employees with disabilities interact with various systems, websites, apps, and technologies are all important factors we need to consider.

Barriers Identified

• When customers call in, all of their directional answers should be given in a verbal format.
• Digital communication like newsletters or email marketing could incorporate A.S.L. or L.S.Q. content to be more inclusive for persons in the Deaf, Deaf-Blind and Hard of Hearing communities.
• Websites can be difficult to navigate or use even when they are designed to accepted accessibility standards. Every person’s lived experience with a disability is different. Using a website is the best way to get information for many people with a disability but it can still be challenging.
• Tbaytel does not offer a chat function to communicate with customers.
• English is actually the second language of some people with certain disabilities. Even using an online chat function requires use of simple, plain language. Short replies may be needed to participate fully in the conversation.

Short-Term Action Plan

• We are currently working to reintroduce our online chat tool for technical support.
• Newly hired technicians will also be trained to provide this support for customers who prefer using the chat tool to communicate with us.
• We will continue to build and design any new pages or sections of our website to current W.C.A.G. standards.

Medium to Long-Term Action Plan

• We will review automatic responses programmed into our chat tool to ensure that plain language and simple responses are used.
• Example-based training will also be introduced to technicians communicating with the chat tool. This will ensure they are comfortable using accessible language when helping customers with disabilities.
• Automatic voice recognition is available as part of Tbaytel’s customer contact solution. We have launched a project to introduce automatic voice recognition service.
• Further review of options available to incorporate accessible content into Tbaytel’s email marketing program will also be completed.

Communication, other than I.C.T

Tbaytel’s consultation process identified improvements we can make so information we share with customers is more accessible. One of our key takeaways about communication is that persons with different disabilities have varying communication needs and language requirements. It is not just about alternative formats. We also need to consider interpersonal interactions, how we can be flexible and how choice matters to persons with disabilities in this area.

Barriers Identified

• Tbaytel’s product information does not recognize sensory disabilities. Leave-behind literature (such as brochures, newsletters, and pamphlets) for some service offerings is geared toward able-bodied individuals, not persons with disabilities or senior citizens.
• For in-person interactions, sales associates communicate with customers who are Deaf, Hard of Hearing, or have significant hearing loss by writing notes back and forth (either using a notepad or typing into a mobile device). A more effective way to communicate would be to use A.S.L. or L.S.Q.
• Tbaytel does not have a dedicated accessibility center or support line with A.S.L. or L.S.Q. translators available to assist customers from the Deaf, Deaf-Blind, and Hard of Hearing communities.

Short-Term Action Plan

• Our accessibility committee has developed a communication plan to support Tbaytel’s accessibility plan. We created opportunities to raise awareness about the goals of the A.C.A. and what we are doing with staff and the public. We presented at an all-staff meeting and organized question and answer sessions at huddles with our field staff. Employees learned where to direct customers to learn more and how to provide feedback that will reach our Accessibility Officer
• We are currently exploring options for an on-demand video relay service (V.R.S.) solution for our retail store location.

Medium to Long-Term Action Plan

• We will look to offer additional accessibility training opportunities on accessible communication for customer-facing staff including at our retail store, for technicians visiting customer premises, and for those answering calls in our customer contact center.
• We will review work instructions for customer-facing staff about assistive technologies and existing accessibility services used when serving customers.
• We will investigate options for other communication channels dedicated to serving persons with disabilities for product and service inquiries. This includes accessible options for self-service as part of Tbaytel’s planned self-service enhancement project.
• Creating templates or guidelines for accessible documents, presentations and materials will make communication more accessible. We will look at how they can be made widely available for all departments to use.

The Procurement of Goods, Services, and Facilities

Achieving the highest degree of accessibility possible involves considering how to remove barriers at every level of an organization. It also involves sharing this goal outside of the organization. As a best practice, when sourcing equipment, materials, goods, and services we will look to incorporate accessibility functions and requirements into our decision making and selection criteria.

Barriers Identified

• The majority of customer equipment uses lights to help determine whether it is working properly. Equipment does not have audible feedback or cannot provide voice descriptions so tactile markers should be added.
• Most in-home devices like telephones do not have audible feedback on the keypads. Devices like remote controls and set top boxes are not accessible for persons with blindness or low vision.
• Small print on television remotes and set top boxes are not accessible for persons with low sight or vision loss.
• Small buttons may be difficult to manipulate for people facing dexterity-related barriers.

Short-Term Action Plan

• Our accessibility committee has advised Tbaytel’s Product Marketing department that product development initiatives should explore and consider accessibility solutions moving forward.
• Accessibility considerations to best meet the needs of persons with various disabilities will also be incorporated into all product roadmaps moving forward.
• We will introduce the requirement to do physical accessibility checks of facilities when planning events, especially when off-site. Company-wide communication reminding of this requirement will also be sent.

Medium to Long-Term Action Plan

• We will continue to review feedback provided to us about equipment and hardware used by customers in their homes and workplaces. We will use this feedback to seek out opportunities to build higher levels of accessibility into any upcoming plans for the replacement or upgrade of equipment.
• Where opportunities are identified, we will inquire about accessibility training, certifications, or standards for vendors, contractors and suppliers to ensure we are considering accessibility to the greatest degree possible.

The Design and Delivery of Programs and Services

When offering products and services to our customers, there is an opportunity to ensure that accessibility is being considered at every stage. This includes product development, process flow design, staff training, product and service information, service roll out, installation, and customer support. Our goal is to continue evaluating how we deliver our existing programs and services to remove barriers and design more accessible programs and services to prevent future barriers.

Barriers Identified

• It is not always clear that service representatives are aware that the customer they are interacting with has a disability like a speech or intellectual disability. There could be confusion about what they are hearing on the phone, or not recognizing what may be required during face-to-face interactions. Although persons with disabilities usually appreciate when effort is made to be patient or helpful, sometimes interactions are just frustrating or uncomfortable.
• Customer accounts should be marked to identify if the customer has self-identified as a person with a disability. This should be communicated to the service technicians visiting the customer’s home.
• When confirming installation and repair appointments, Tbaytel calls customers to verify the date and time, but this is a barrier for customers from Deaf, Deaf-Blind, or Hard of Hearing communities.

Short-Term Action Plan

• Our accessibility committee has advised Tbaytel’s Product Marketing department that product development initiatives should explore and consider accessibility solutions moving forward.
• The Committee has also advised Tbaytel’s Project Management Office to build accessibility considerations into different project phases as a standard practice.

Medium to Long-Term Action Plan

• We will provide customers with disabilities more opportunities to disclose their accessibility needs during interactions with us. We will train staff to ask more questions to reduce immediate barriers at the start of a customer’s transaction.
• We will explore functions available in our field service management system to better prepare technicians for service visits with persons with disabilities before appointments.
• We will also look for process improvements for end-to-end service delivery considering the customer’s journey with an accessibility lens. This might include adding automatic emails or Short Message Service (S.M.S.) messages to confirm appointments.
• We will consider if there are more opportunities to conduct user acceptance testing with persons with disabilities, especially for any new products, services, or features designed specifically to address accessibility needs.

Transportation

Tbaytel does not provide transportation services so this area does not apply.

Conclusion

The A.C.A. outlines seven key principles. We approached our accessibility plan by keeping those principles in mind. In keeping with the spirit of each principle, we are committed to making every effort we can to:

• treat all persons with dignity regardless of their disabilities;
• give all persons the same opportunity to make the lives that they are able and wish to have regardless of their disabilities;
• support barrier-free access to full and equal participation in society, regardless of disabilities;
• give all persons meaningful options so they are free to make their own choices, with support if they desire, regardless of their disabilities;
• design our policies, programs, services, and structures to account for the disabilities of persons, the different ways that persons interact with their environments, and the multiple and intersecting forms of marginalization and discrimination they face;
• involve persons with disabilities in the development and design of our policies, programs, services and structures; and
• aim to achieve the highest level of accessibility for persons with disabilities when developing and revising elements of our accessibility program.

Through our consultation activities, we have learned the meaning of “nothing without us.” We have learned that the best way to work towards a barrier-free Canada is to work with, and learn from, persons with lived experience to share.

In accordance with the A.C.A., we will continue our consultation work with persons with disabilities and consider all feedback provided to us. We will provide updates about the progress we make in the years that we do not publish a new plan. Our goal by the time we publish our next three-year plan is to have made significant progress in removing and preventing the barriers we identified. We will continue to aim for the most accessible Tbaytel achievable and put what we learn into the fabric of our corporate culture.