We have developed and implemented policies and procedures for the protection of personal information. We readily make available upon request specific information about our policies and practices relating to the management of personal information.
Unless implied or otherwise inappropriate, we obtain your consent to the collection, use or disclosure of personal information.
- Individual Access
On request we will inform you, within a reasonable time and at minimal or no cost to you, of the existence, use, and disclosure of your personal information and give you access to that information.
Where any inaccuracy of personal information is found, we promptly amend the information as required.
- Identifying Purposes
At or before the time personal information is collected, we identify the purposes for which such information is collected. We collect only information which is necessary for the purposes that have been identified.
If we need to use your personal information for a purpose not previously identified by us, we obtain your consent before doing so, unless otherwise required by law.
We keep your personal information as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used, but we do not routinely update personal information, except to the extent necessary to fulfil the purposes for which the information was collected.
- Limiting Use, Disclosure, and Retention
We do not use or disclose personal information for purposes other than those for which it was collected, except with your consent or as required by law. We retain personal information only as long as necessary to fulfil those purposes or required by law.
We protect personal information using security safeguards appropriate to the sensitivity of the information, this includes protection against loss or theft, unauthorized access, disclosure, copying, use, or modification.
Upon request, we will readily make available specific information about our policies and practices relating to the management of personal information.
- Challenging Compliance
We have procedures in place to receive and respond to complaints or inquiries about our policies and practices relating to the handling of personal information, and on request, will inform you of the relevant complaint procedures.
We investigate all complaints. If a complaint is found to be justified, we take appropriate measures to rectify the matter.
MULTI-YEAR ACCESSIBILITY CUSTOMER SERVICE PLAN
Providing Goods and Services to People with Disabilities
SLF Inc. is committed to excellence in serving all customers including people with disabilities.
SLF Inc. is committed to treating all people in a way that allows them to maintain their dignity and independence. We believe in integration and equal opportunity. We are committed to meeting the needs of people with disabilities in a timely manner, and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the Accessibility for Ontarians with Disabilities Act.
ACCESSIBLE EMERGENCY INFORMATION
SLF Inc. is committed to providing the customers and clients with publicly available emergency information in an accessible way upon request. We will also provide employees with disabilities with individualized emergency response information when necessary.
We will ensure that our staff are trained and familiar with various assistive devices we have on site or that we provide that may be used by customers with disabilities while accessing our goods or services.
We will communicate with people with disabilities in ways that take into account their disability.
We welcome people with disabilities and their service animals. Service animals are allowed on the parts of our premises that are open to the public.
A person with a disability who is accompanied by a support person will be allowed to have that person accompany them on our premises.
Notice of temporary disruption
In the event of a planned or unexpected disruption to services or facilities for customers with disabilities i.e. no access to the elevators, SLF Inc. will notify customers promptly. This clearly posted notice 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 on our door. In situations where there are booked appointments the client will be notified via phone or email and alternate meeting arrangements will be made.
SLF Inc. will provide training to employees, volunteers and others who deal with the public or other third parties on our behalf on Ontario’s accessibility laws and on the Human Rights Code as it relates to people with disabilities. Training will be provided in a way that best suits the duties of employees, volunteers and other staff members.
Individuals in the following positions will be trained:
Office Clerk, Receptionist, Managers and Partners
This training will be provided to new staff within 2 weeks of hiring.
Training will include:
- An overview of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard
- SLF Inc.’s plan related to the customer service standard
- How to interact and communicate with people with various types of disabilities
- How to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person
- How to use the computer to accommodate those with visual impairments, opening double doors for accessibility and the boardrooms that are more wheelchair accessible
What to do if a person with a disability is having difficulty in accessing SLF Inc.’s goods and services
Staff will also be trained when changes are made to your accessible customer service plan. SLF Inc. will refresh training of staff on an annual basis.
SLF Inc. will take the following steps to ensure employees are provided with the training needed to meet Ontario’s accessible laws by January 1, 2015.
- SLF Inc. is committed to fair and accessible employment practices.
- We will take the necessary steps to notify the public and staff that, when requested, SLF Inc. will accommodate people with disabilities during the recruitment and assessment processes and when people are hired.
- SLF Inc. will take the necessary steps to develop and put in place a process for developing individual accommodation plans and return-to-work policies for employees that have been absent due to a disability.
- We will take the necessary steps to ensure the accessibility needs of employees with disabilities are taken into account.
- SLF Inc. will take the necessary steps to prevent and remove other accessibility barriers identified.
- SLF Inc. will take the required steps to make sure all publicly available information is made accessible upon request by January 1, 2016.
Modifications to this or other policies
- Any policy of SLF Inc. that does not respect and promote the dignity and independence of people with disabilities will be modified or removed.
- This document is available in alternative formats upon request, such as: print; electronic or large font.
ACCESSIBILITY STANDARDS FOR CUSTOMER SERVICE POLICY
PURPOSE AND POLICY STATEMENT
The goal of the Accessibility for Ontarians with Disabilities Act, 2005 (the “Act”) is to create a more accessible Ontario, by identifying, and to the extent possible, preventing, and eliminating barriers experienced by persons with a disability.
The Accessibility Standards for Customer Service (“the Standard”) has been established under the Act to ensure goods and services are, where at all possible, equally accessible to every member of the public.
We at SLF Inc. or “the Firm”) strive to make our goods and services accessible to people with disabilities. The objective of this policy (the “Policy”) is to ensure we meet the requirements of the Standard and promote its underlying core principles, described below.
The Policy applies to all persons who, on behalf of SLF Inc. deal with members of the public or other third parties. This includes our employees, volunteers, agents and contractors.
The Policy also applies to all persons responsible for the development, implementation or oversight of SLF Inc. policies, practices and procedures.
- Accessibility Report – The report required to be filed pursuant to section 14 of the Act.
- Assistive Device – Any device used to assist a person in performing a particular task or tasks or to aid that person in activities of daily living.
- Disability – Has the same definition as is provided under the Act and Human Rights Code, R.S.O. 1990, c. H.19.
- 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.
- Support Person – A person who accompanies a person with a disability to assist with communication, mobility, personal care or medical needs or with access to goods or services.
- “We”, “Our” and “Staff” means SLF Inc. and its employees, volunteers, agents and contractors.
CORE PRINCIPLES OF THE POLICY
We endeavor to ensure that the Policy and related practices, policies and procedures are consistent with the following four (4) core principles:
- Dignity – Persons with a disability must be treated as valued customers as deserving of service as any other customer.
- Equality of Opportunity – Persons with a disability should be given an opportunity equal to that given to others to obtain, use and benefit from our goods and services.
- Integration – Wherever possible, persons with a disability should benefit from our goods and services in the same place and in the same or similar manner as any other customer. In circumstances where integration does not serve the needs of the person with a disability, goods and services will, to the extent possible, be provided in another way that takes into account the person’s individual needs.
- Independence – Goods and services should, where possible, be provided in a way that respects the independence of persons with a disability. To this end, we will be willing to assist a person with a disability but will not do so without the express permission of the person.
PROVIDING GOODS AND SERVICES TO PEOPLE WITH DISABILITIES
Policies, Practices and Procedures
SLF Inc. shall make all reasonable efforts to ensure that its policies, practices and procedures which impact the delivery of its goods and services to the public or to other third parties (“Customer Service Related Policies”) are consistent with the principles of dignity, equality of opportunity, integration and independence as defined above.
If SLF Inc. changes any of its practices we will include a description of these amendments on our website.
SLF Inc. strives to communicate with persons with a disability in a manner that takes into account the disabilities.
Communicating with Persons with a Disability
Our staff communicate with clients and their representatives and others in a variety of ways, including face to face interactions, letters, telephone calls and electronic communications ie emails. In determining the appropriate method and form of communication, we will take into account accessibility needs resulting from disabilities.
Clients and their representatives and others are encouraged to identify accessibility needs in communicating and interacting with SLF Inc.
Clients, their representatives and other individuals are permitted, where possible, to use their own Assistive Device when on our premises for the purposes of obtaining, using or benefiting from our goods and services.
If there is a physical, technological or other type of barrier that prevents the use of an Assistive Device on our premises we will first endeavour to remove that barrier. If we are not able to remove the barrier we will ask the person how he/she can be accommodated and what alternative methods of service would be more accessible to him/her. We will make best efforts to provide an alternative means of assistance to the person with a disability.
To the extent required, the Firm will ensure that our staff are trained and familiar with various assistive devices that may be used by individuals when accessing our services and any assistive devices made available by the Firm.
Accessibility at Our Premises
We offer the following facilities and services at SLF Inc. to which the Policy applies to enable persons with a disability to obtain, use or benefit from our goods and services:
- Financial Statements and documents formatted with larger print
- Brochures or handouts in larger print (upon request)
- Improved lighting in certain areas for individuals with vision disability
- Boardrooms that are easily accessible to those in wheelchairs
All persons to whom this Policy applies will receive training on how to use facilities or services made available on SLF Inc. premises to assist persons with a disability to obtain, use or benefit from SLF Inc.goods and services.
Persons with a disability may enter premises owned and/or operated by RioCan Management accompanied by a Service Animal, and keep the Service Animal with them, if the public has access to such premises and the Service Animal is not otherwise excluded by law.
If a service animal must be excluded by law, we explain to our customer why this is the case and explore alternative ways to meet the customer’s needs.
All persons to whom this Policy applies will receive training on how to interact with persons with a disability accompanied by a Service Animal.
A person with a disability may enter premises owned and/or operated by RioCan Management Incorporated with a Support Person and have access to the Support Person while on the premises.
SLF Inc. may require a person with a disability to be accompanied by a Support Person where it is necessary to protect the health or safety of the person with a disability or the health or safety of others on the premises.
All persons to whom this Policy applies will receive training on how to interact with persons with a disability who are accompanied by a Support Person.
Notice of Temporary Disruptions
SLF Inc. will notify customers if there is a planned or unexpected disruption of a facility or service persons with a disability use to access our goods and services.
The notice will be posted and/or communicated to individuals with disabilities in a manner that is reasonable in the circumstances.
The notice will include the following information:
- That a facility or service is unavailable.
- The anticipated duration of the disruption.
- The reason for the disruption.
- Alternative facilities or services, if available.
TRAINING AND RECORDS
SLF Inc. will provide training and ongoing training as required under the Standard, to all persons to whom this Policy applies. Training will be provided to staff who deal with clients and their representatives or other third parties, and those who are responsible for client service policy development, practice or procedures as required by applicable laws.
Content of Training
Such training will include the following components:
- An overview of applicable laws related to the provision of services to individuals with disabilities.
- An overview of the Policy and any other practices, policies or procedures developed by SLF with respect to the provision of services to individuals with disabilities.
- Information regarding how to interact and communicate with individuals with various types of disabilities, including interaction with individuals who use assistive devices, support persons and/or service animals.
- Instruction on how to use any equipment or assistive devices that the Firm may have available to assist individuals with disabilities to obtain, use of benefit from SLF Inc.’s goods and services.
- Instruction on what to do if an individual with a disability is having difficulty accessing SLF Inc. services.
Training will be provided to all persons to whom this Policy applies as soon as practicable after he or she is assigned the applicable duties.
Records of the training provided, including the training protocol, the dates on which the training is provided and the number of individuals to whom the training is provided shall be maintained in accordance the requirements of the Standard
The Firm is committed to improving our client service by listening to our clients and responding to their feedback. SLF Inc. welcomes and appreciates feedback regarding this policy and its implementation. Clients and their representatives and other third parties are encouraged to provide feedback on the way SLF Inc. provides services to individuals with disabilities.
Feedback can be directed by one of the following ways:
2300 Yonge Street, Suite 1500, Box 2434
Toronto, Ontario M4P 1E4
(mail or in person)
416-785-5353 ext. 2231 (telephone)
Responding to Feedback
Individuals can generally expect a response or preliminary response to their feedback within two (2) weeks of receipt by the Firm, if the nature of the feedback requires a response.
In responding to feedback, SLF Inc. will take such steps as are necessary to rectify any issues or concerns raised in a manner consistent with the Policy and our commitment to providing excellent and accessible client service. Depending on the circumstances, such steps may include requesting additional information from the individual providing the feedback, investigating specific complaints and/or providing documentation or communications in accessible formats. The Firm will advise the individual providing the feedback of the results of the feedback review process as appropriate in the circumstances.
In certain circumstances, we may be required to take more action to effectively address the complaint including but not limited to conducting an internal investigation and/or a review of SLF Inc.’s policies, practices and procedures. In such circumstances the customer will receive an acknowledgement that the complaint has been received within two (2) weeks and we will respond to the complaint as soon as is practicable thereafter.
DOCUMENTATION TO BE MADE AVAILABLE
This Policy, and related practices and protocols, shall be made available to any member of the public upon request.
Notification of same shall be posted on SLF Inc.’s website and at a conspicuous place at each premise to which this Policy applies.
FORMAT OF DOCUMENTS
SLF Inc. will provide documents, or the information contained in documents, required to be provided under the Standard, to a person with a disability in a format that takes the person’s disability into account.
QUESTIONS ABOUT THIS POLICY
For more information about the Policy or for questions regarding SLF Inc.’s policies, practices and procedures for accessible customer service please contact:
416-785-5353 ext. 2231