Purpose
Privacy Analytics is committed to fulfilling our requirements under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA). This Accessibility Plan has been developed to comply with the AODA and establishes accessibility standards for people with disabilities, including employees and members of the public. This policy details Privacy Analytics’ (PAI) commitment to using reasonable efforts to ensure it provides accessible customer service to people with various kinds of disabilities and respects the core principles of independence, dignity, integration and equal opportunity. This accessibility plan outlines the steps that PAI is taking to meet those requirements and to improve opportunities for people with disabilities.
This plan shows the role PAI plays in helping Ontario become an accessible province for all Ontarians. The plan is reviewed and updated at least once every 5 years.
Scope
The Accessibility Plan policy governs PAI’s commitments to employees and contractors, and provisions of goods and services to members of the public or other third parties including all clients. The standard applies to PAI’s employees and contractors
Policy
Definitions
“Assistive Device” any piece of equipment a person with a disability uses to help him or her with daily living. Personal assistive devices include, but are not limited to, wheelchairs, hearing aids, white canes or speech amplification devices.
“Disability” (a) 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 related appliance or device; (b) a condition of mental impairment or a developmental disability; (c) a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language; (d) a mental disorder; or (e) an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.
“Guide Dog” a dog trained as a guide for a blind person and having the qualifications prescribed by the regulations under the Blind Persons’ Rights Act.
“Service Animal” any animal used by a person with a disability where it is readily apparent that the animal is used by the person for reasons relating to their disability; or where the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to their disability.
“Support Person” a person who accompanies a person with a disability in order to help him or her with daily tasks, such as communication, mobility, personal care or medical needs or with access to goods or services. The support person may be a paid support worker, a volunteer, a friend or a family member; the support person does not need to have special training or qualifications.
Past Achievements
Customer Service
PAI launched its initial AODA compliance initiative in 2014 by addressing the requirement for Customer Service in accordance with the statute. Standards were defined with respect to approach, training, and handling customer feedback.
Information and Communications
In 2020, PAI invested significantly in updating its website to enable its use for persons with disabilities. The section entitled Website Accessibility describes the features of the website enabling its effective use for such persons.
Employment
PAI accommodates the requirements of employees, both prospective and current, with respect to any disabilities. This starts during the interview process where candidates are encouraged to indicate any specific requirements they might have due to disabilities. PAI then makes the appropriate arrangements to accommodate to ensure that the new hire is able to work efficiently, and feel that they are being treated with respect and dignity.
Training
Staff have been required to complete AODA training upon hiring since 2016. In 2019, and initiative was undertaken to ensure that all staff hired prior to 2016 completed this training and a 90% completion rate was achieved.
Core Principles and Purpose of Customer Service Standard
PAI will use reasonable efforts to ensure the provision of its goods and services are consistent with the principles of dignity, independence, integration and equal opportunity by:
- Providing goods and services in a manner that respects the dignity and independence of persons with disabilities;
- Providing goods and services so that persons with disabilities are able to fully benefit from the same services, in the same place, and in the same or similar way as persons without disabilities, unless an alternative measure is necessary to enable a person with a disability to obtain, use, or benefit from PAI’s goods and services; and
- Giving people with disabilities the same opportunity equal to that of persons without disabilities to obtain, use or benefit from PAI’s goods and services.
Use of Assistive Devices
PAI permits persons with disabilities to use their personal assistive devices while on PAI premises to obtain, use, or benefit from PAI’s goods and services.
Communication:
When communicating with a person with a disability, PAI will do so in a manner that takes into account the person’s disability.
Use of Service Animals and Support Persons
Service Animals: Persons with disabilities who are accompanied by guide dogs or other service animals will be permitted to enter PAI’s premises that are open to the public with the animal and will be allowed to keep the animal with them, unless the animal is otherwise excluded by law. If the service animal is excluded by law, PAI will use reasonable efforts to ensure that alternate means are available for persons with disabilities to obtain, use or benefit from PAI’s goods and services.
If it is not readily apparent that the animal is a service animal, PAI may ask the person with a disability for a letter from a physician or nurse confirming that the person requires the animal for reasons relating to their disability.
It is the responsibility of the person with a disability to ensure that their service animal is kept in control at all times.
Support Persons: Persons with disabilities who are accompanied by a support person will be permitted to enter Privacy Analytics premises that are open to the public and will not be prevented from having access to the support person while on the premises.
PAI may require a person with a disability to be accompanied by a support person while on Privacy Analytics premises in situations where it is deemed necessary to protect the health and safety of the person with a disability and/or others.
When support persons are required for PAI sponsored meetings or events, the person with a disability will be required to provide their own support person. If there are fees associated with the meeting or event, the support person will be charged the regular fee unless otherwise specified by PAI. Advance notice of said fees will be provided if such circumstances exist.
Training
PAI will provide accessibility training to all staff upon hiring. Training will include:
- An overview of the Accessibility for Ontarians with Disabilities Act, 2005 • PAI’s approach to accommodating employees with disabilities
- How to interact and communicate to 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
- What to do if a person with a disability is having difficulty in accessing PAI’s goods and services.
Staff will also be trained when changes are made to the Accessibility Plan
Website Accessibility
Compliance status
PAI is committed to providing a website that is accessible to the widest possible audience, regardless of circumstance and ability.
To fulfill this, PAI adheres as strictly as possible to the World Wide Web Consortium’s (W3C) Web Content Accessibility Guidelines 2.1 (WCAG 2.1) at the AA level. These guidelines explain how to make web content accessible to people with a wide array of disabilities. Complying with those guidelines helps PAI ensure that the website is accessible to all people: blind people, people with motor impairments, visual impairment, cognitive disabilities, and more.
PAI’s website utilizes various technologies that are meant to make it as accessible as possible at all times. The website utilizes an accessibility interface that allows persons with specific disabilities to adjust the website’s UI (user interface) and design it to their personal needs.
Additionally, the website utilizes an AI-based application that runs in the background and optimizes its accessibility level constantly. This application remediates the website’s HTML, adapts its functionality and behavior for screen-readers used by blind users, and for keyboard functions used by individuals with motor impairments.
Screen-reader and keyboard navigation
Our website implements the ARIA attributes (Accessible Rich Internet Applications) technique, alongside various different behavioral changes, to ensure blind users visiting with screen-readers are able to read, comprehend, and enjoy the website’s functions. As soon as a user with a screen-reader enters your site, they immediately receive a prompt to enter the Screen-Reader Profile so they can browse and operate your site effectively. Here’s how the website covers some of the most important screen-reader requirements, alongside console screenshots of code examples:
- Screen-reader optimization: a background process is run that learns the website’s components from top to bottom, to ensure ongoing compliance even when updating the website. In this process, the website provides screen-readers with meaningful data using the ARIA set of attributes. For example, the following is provided: accurate form labels; descriptions for actionable icons (social media icons, search icons, cart icons, etc.); validation guidance for form inputs; element roles such as buttons, menus, modal dialogues (popups), and others.
Additionally, the background process scans all of the website’s images and provides an accurate and meaningful image-object-recognition-based description as an ALT (alternate text) tag for images that are not described. It will also extract texts that are embedded within the image, using an OCR (optical character recognition) technology. To turn on screen-reader adjustments at any time, users need only to press the Alt+1 keyboard combination. Screen-reader users also get automatic announcements to turn the Screen-reader mode on as soon as they enter the website.These adjustments are compatible with all popular screen readers, including JAWS and NVDA
- Keyboard navigation optimization: The background process also adjusts the website’s HTML, and adds various behaviors using JavaScript code to make the website operable by the keyboard. This includes the ability to navigate the website using the Tab and Shift+Tab keys, operate dropdowns with the arrow keys, close them with Esc, trigger buttons and links using the Enter key, navigate between radio and checkbox elements using the arrow keys, and fill them in with the Spacebar or Enter key.
Additionally, keyboard users will find quick navigation and content-skip menus, available at any time by clicking Alt+1, or as the first element of the site while navigating with the keyboard. The background process also handles triggered popups by moving the keyboard focus towards them as soon as they appear, and not allow the focus to drift outside of it.
Users can also use shortcuts such as “M” (menus), “H” (headings), “F” (forms), “B” (buttons), and “G” (graphics) to jump to specific elements.
Disability profiles supported on our website:
- Epilepsy Safe Profile: this profile enables people with epilepsy to use the website safely by eliminating the risk of seizures that result from flashing or blinking animations and risky color combinations.
- Vision Impaired Profile: this profile adjusts the website so that it is accessible to the majority of visual impairments such as Degrading Eyesight, Tunnel Vision, Cataract, Glaucoma, and others.
- Cognitive Disability Profile: this profile provides various assistive features to help users with cognitive disabilities such as Autism, Dyslexia, CVA, and others, to focus on the essential elements more easily.
- ADHD Friendly Profile: this profile significantly reduces distractions and noise, to help people with ADHD and Neurodevelopmental disorders browse, read, and focus on the essential elements more easily.
- Blind Users Profile (Screen-readers): this profile adjusts the website to be compatible with screen-readers such as JAWS, NVDA, VoiceOver, and TalkBack. A screen-reader is installed on the blind user’s computer, and this site is compatible with it.
- Keyboard Navigation Profile (Motor-Impaired): this profile enables motor-impaired persons to operate the website using the keyboard Tab, Shift+Tab, and the Enter keys. Users can also use shortcuts such as “M” (menus), “H” (headings), “F” (forms), “B” (buttons), and “G” (graphics) to jump to specific elements
Additional UI, design, and readability adjustments
- Font adjustments – users can increase and decrease its size, change its family (type), adjust the spacing, alignment, line height, and more.
- Color adjustments – users can select various color contrast profiles such as light, dark, inverted, and monochrome. Additionally, users can swap color schemes of titles, texts, and backgrounds, with over 7 different coloring options.
- Animations – epileptic users can stop all running animations with the click of a button. Animations controlled by the interface include videos, GIFs, and CSS flashing transitions.
- Content highlighting – users can choose to emphasize important elements such as links and titles. They can also choose to highlight focused or hovered elements only.
- Audio muting – users with hearing devices may experience headaches or other issues due to automatic audio playing. This option lets users mute the entire website instantly.
- Cognitive disorders – the search engine is linked to Wikipedia and Wiktionary, allowing people with cognitive disorders to decipher meanings of phrases, initials, slang, and others.
- Additional functions – users are provided with the option to change cursor color and size, use a printing mode, enable a virtual keyboard, and many other functions.
Assistive technology and browser compatibility
The website supports the widest array of browsers and assistive technologies as possible, so users can choose the best fitting tools for them, with as few limitations as possible. Therefore, significant effort has been expended to be able to support all major systems that comprise over 95% of the user market share including Google Chrome, Mozilla Firefox, Apple Safari, Opera and Microsoft Edge, JAWS, and NVDA
(screen readers), both for Windows and for MAC users.
Comments and concerns
Despite the efforts to allow anybody to adjust the website to their needs, there may still be pages or sections that are not fully accessible, are in the process of becoming accessible, or are lacking an adequate technological solution to make them accessible. Still, PAI s continually improving the accessibility, adding, updating, and improving its options and features, and developing and adopting new technologies. All this is meant to reach the optimal level of accessibility, following technological
advancements. If have any concerns about the website with respect to accessibility, please follow the Feedback Process described below.
Feedback Process
PAI is committed to providing high quality goods and services to all members of the public that it serves, including customers with disabilities. Comments on how well PAI achieves this goal are welcomed and appreciated.
Feedback from members of the public regarding the way PAI provides goods and services to people with disabilities can be made by telephone, in person, in writing, in electronic format (e.g. e-mail) or through other relevant methods.
All feedback will be directed to the company at:
251 Laurier Avenue, Suite 200
Ottawa, Ontario K1P 5J6
Tel: 1-613-369-4313
legal@privacy-analytics.com
Privacy will be respected and all feedback will be reviewed for possible action that can be taken to improve PAI services. In most cases, a response to the feedback will be provided within 30 working days. Feedback and/or responses will be delivered in a format that is accessible to the complainant.
Complaints will be addressed according to PAI’s regular complaint management procedures.
Strategies and Action Plan
Over the next 2 years, PAI commits to the follow enhancements to the Accessibility Plan.
- Communicate Accessibility Plan on the website – although our website was made accessible as mentioned above, PAI’s Accessibility Plan was not publicly available. The Accessibility Plan will be published on the PAI website in 2022.
- Augment information made available on our website about accessibility during our recruitment processes for candidates seeking employment opportunities
Exceptions
No exception may be made to this policy without the documented consent of the Head of Privacy Analytics.