CMRRA

Canadian Musical Reproduction Rights Agency

Accessibility Policy

Statement of Commitment to Accessibility

Canadian Musical Reproduction Rights Agency Ltd. (CMRRA) is is committed to ensuring equal access and participation for people with disabilities. We are committed to treating people with
disabilities in a way that allows them to maintain their dignity and independence. We believe in integration and we are committed to meeting the needs of people with disabilities in a timely manner. We will do so by removing and preventing barriers to accessibility and meeting our accessibility requirements under the Accessibility for Ontarians with Disabilities Act and Ontario’s
accessibility laws.

CMRRA is committed to meeting its current and ongoing obligations under the Ontario Human Rights Code respecting non-discrimination.

CMRRA understands that obligations under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and its accessibility standards do not substitute or limit its obligations under the Ontario Human Rights Code or obligations to people with disabilities under any other law.

CMRRA is committed to excellence in serving and providing goods, services or facilities to all customers including people with disabilities.

Our accessible customer service policies are consistent with the principles of independence, dignity, integration and equality of opportunity for people with disabilities.

Scope

This Policy applies to all staff personnel (employees and other applicable third parties).

Communicating with People with Disabilities, in person or over the phone

CMRRA shall take reasonable steps to communicate with persons with disabilities in ways that consider their disability and accessibility needs or as otherwise may be required for CMRRA to meet its obligations under the Code.

CMRRA shall also ensure that all staff and other individuals dealing with the public on behalf of CMRRA are properly trained in how to communicate with visitors with various types of disabilities.

CMRRA shall ensure the availability of in office accessible formats and communication supports in public areas and, upon request, provide or arrange for the provision of in office accessible formats and ensure that the processes for receiving and responding to feedback are accessible to persons with disabilities by providing or arranging for the provision of in office accessible formats and communications supports, upon request.

Assistive devices

CMRRA is committed to serving people with disabilities, who use assistive devices to obtain, use, or benefit from its services.

People with disabilities may use their personal assistive devices when accessing our goods, services or facilities.

In cases where the assistive device presents a significant and unavoidable health or safety concern or may not be permitted for other reasons, other measures will be used to ensure the person with a disability can access our goods, services or facilities.

We 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, services or facilities. We communicate with people with disabilities in ways that take into account their disability.

We will work with the person with disabilities to determine what method of communication works for them.

Service Animals

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 and third parties.

When we cannot easily identify that an animal is a service animal, our staff may ask for documentation (template, letter or form) from a regulated health professional that confirms the person needs the service animal for reasons relating to their disability.

A service animal can be easily identified through visual indicators, such as when it wears a harness or a vest, or when it helps the person perform certain tasks.

A regulated health professional is defined as a member of one of the following colleges:
• College of Audiologists and Speech-Language Pathologists of Ontario
• College of Chiropractors of Ontario
• College of Nurses of Ontario
• College of Occupational Therapists of Ontario
• College of Optometrists of Ontario
• College of Physicians and Surgeons of Ontario
• College of Physiotherapists of Ontario
• College of Psychologists of Ontario
• College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario

If service animals are prohibited by another law, we will do the following to ensure people with disabilities can access our goods, services or facilities:
• explain why the animal is excluded
• discuss with the customer another way of providing goods, services or facilities

Support Persons

A person with a disability who is accompanied by a support person will be allowed to have that person accompany them on our premises.

Support persons’ roles may vary depending on the type of disability a person has. Some of the things support persons can assist with are:

  • Communication;
  • Mobility;
  • Accessibility;
  • Daily living needs; and
  • Medical care.

In certain cases, this organization might require a person with a disability to be accompanied by a support person for the health or safety reasons of:
• the person with a disability
• others on the premises
Before making a decision, this organization name will:
• consult with the person with a disability to understand their needs
• consider health or safety reasons based on available evidence
• determine if there is no other reasonable way to protect the health or safety of the person or others on the premises

For further information consult: https://www.aoda.ca/support-persons-roles-what-do-they-do-and-who-needs-one/. If a support person accompanies a visiting person with a disability, CMRRA shall ensure that the person with a disability is not prevented from having access to that support person at all times.

Training for Staff

We are committed to training all staff and volunteers in accessible customer service, other Ontario’s accessibility standards and aspects of the Ontario Human Rights Code that relate to persons with disabilities.
In addition, we will train:
a) all persons who participate in developing the organization’s policies; and
b) all other persons who provide goods, services or facilities on behalf of the organization

Training of our employees and volunteers on accessibility relates to their specific roles.

Training will include:

  • purpose of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the Customer Service Standards
  • our policies related to the Customer Service Standards
  • 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 equipment or devices available on-site or otherwise that may help with providing goods, services or facilities to people with disabilities.
  • what to do if a person with a disability is having difficulty in accessing our organization’s goods, services or facilities.

We train every person as soon as practicable after being hired and provide training in respect of any changes to the policies.

We maintain records of the training provided including the dates on which the training was provided and the number of individuals to whom it was provided.

Employment Policy

We notify employees, job applicants and the public that accommodations can be made during recruitment and hiring. We notify job applicants when they are individually selected to participate in an assessment or selection process that accommodations are available upon request. We consult with the applicants and provide or arrange for suitable accommodation.

We notify successful applicants of policies for accommodating employees with disabilities when making offers of employment. We notify staff that supports are available for those with disabilities as soon as practicable after they begin their employment. We provide updated information to employees whenever there is a change to existing policies on the provision of job accommodation
that take into account an employee’s accessibility needs due to a disability.

We will consult with employees when arranging for the provision of suitable accommodation in a manner that takes into account the accessibility needs due to disability. We will consult with the person making the request in determining the suitability of an accessible format or communication supports specifically for:
a) information that is needed in order to perform the employee’s job; and
b) information that is generally available to employees in the workplace

Where needed, we will also provide customized emergency information to help an employee with a disability during an emergency. With the employee’s consent, we will provide workplace emergency information to a designated person who is providing assistance to that employee during an emergency.

We will provide the information as soon as practicable after we become aware of the need for accommodation due to the employee’s disability.

We will review the individualized workplace emergency response information:
a) when the employee moves to a different location in the organization;
b) when the employee’s overall accommodations needs or plans are reviewed; and
c) when the employer reviews its general emergency response policies.

We have a written process to develop individual accommodation plans for employees. We have a written process for employees who have been absent from work due to a disability and require disability-related accommodations in order to return to work.

Our performance management, career development and redeployment processes take into account the accessibility needs of all employees.

Notification of Office Closure or Temporary Disruption

In the event of a planned or unexpected disruption to services or facilities for customers with disabilities, CMRRA 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.

CMRRA will make reasonable efforts to provide notice on its phone system, website, and through social media in the event of a planned or unplanned disruption of services that may affect people with disabilities.

Feedback Process

In ensuring that CMRRA maintains the highest level of service, CMRRA welcomes and appreciates all feedback. Customer feedback will help us identify barriers and respond to concerns. Individuals who wish to provide feedback on the way CMRRA provides services to people with disabilities can provide feedback in the following ways:

In person at CMRRA’s office at
320 – 56 Wellesley Street West,
Toronto, ON M5S 2S3

By phone at 416-926-1966

By filling out the Contact Us form at https://www.cmrra.ca/contact-us/ Subject: Accessibility Feedback.

Feedback will be directed to our People and Culture Team and customers can expect to hear back with two business days.

Information and Communications

We have a process for receiving and responding to feedback and the process is accessible to persons with disabilities upon request.
We communicate with people with disabilities in ways that take into account their disability. When asked, we will provide information about our organization and its services, including public safety information, in accessible formats or with communication supports:
a) in a timely manner, taking into account the person’s accessibility needs due to disability; and
b) at a cost that is no more than the regular cost charged to other persons.

We will consult with the person making the request in determining the suitability of an accessible format or communication support. If the organization determines that information or communications are nonconvertible, the organization shall provide the requestor with:
a) an explanation as to why the information or communications are nonconvertible; and
b) a summary of the nonconvertible information or communications.

We will also meet internationally-recognized Web Content Accessibility Guidelines (WCAG) 2.0 Level AA website requirements in accordance with Ontario’s accessibility laws.

Web Accessibility

CMRRA is committed to making its website usable by all people by meeting or exceeding the requirements of the Web Content Accessibility Guidelines 2.0 Level AA (“WCAG 2.0 AA”).

Please be aware that our efforts are ongoing as our current website provider implements the relevant improvements to meet WCAG 2.0 AA guidelines over time. If you need assistance in using the site or have specific questions or concerns about the accessibility of this site, please contact us at [email protected].

If you do encounter an accessibility issue, please be sure to specify the page, URL, and details so that we may review and address any non-compliance. We will make all reasonable efforts to make that page accessible.

Individual Accommodation Plan Process

CMRRA is committed to accommodating people with disabilities and will use the following process to identify and meet employee accommodation needs.

Recognize the need for accommodation

Accommodation can be:

  • requested by the employee
  • identified by the employee’s manager or hiring manager

Gather relevant information and assess individual needs

The employee is an active participant in this step:

  • Information will be collected on the employee’s functional abilities, not the nature of the employee’s disability
    • The employee’s personal information, including medical information, is kept secure and dealt with in a confidential manner. It will only be disclosed to individuals who need it to perform the accommodation
  • The employee and his/her manager will work together to find the most appropriate accommodation
    • A medical or other expert may be engaged (at the company’s expense) to help determine if/how the employee’s needs can be accommodated
    • The employee may ask a bargaining agent or other workplace representative to participate in the process

Write an individual Accommodation Plan

After identifying the most appropriate accommodation(s), the details will be documented in a written plan, including:

  • What accommodation(s) will be provided
  • How to make information accessible to the employee, including accessible formats and communication supports
  • Employee emergency information and/or emergency response plan (if applicable)
  • When the plan will be reviewed and updated

The manager will give the employee in an accessible format (if required), a copy of the individual accommodation plan, or written reasons for denying accommodation.

Implement, monitor and update the plan

After implementing the accommodation plan, the employee and his/her manager will monitor and review the plan to ensure that it is effective. Formal reviews and updates will take place on the mutually agreed upon, predetermined schedule in the employee’s accommodation plan. If the accommodation is no longer appropriate, the employee and the manager will reassess the situation (step 2) and update the plan.

The accommodation plan will also be reviewed and updated if:

  • the employee’s work location or position changes
  • the nature of the employee’s disability changes

Modified Duties

In accordance with our Fair Employment Practice Policies, we will not discriminate on the basis of disability provided an employee can perform the essential duties of the position and can be accommodated short of imposing an undue hardship on CMRRA.

Where an employee is injured or disabled, to assist in the rehabilitation or accommodation process, CMRRA, in accordance with the Ontario Human Rights Code, will attempt to find compatible modified duties, provided that doing so does not cause undue hardship.

An employee is required to participate in the accommodation process by providing CMRRA with information necessary to facilitate an appropriate accommodation and accepting reasonable accommodation offered by the Company. An employee’s failure to cooperate in the accommodation process may result in the request for accommodation being denied.

In the attempt to find suitable modified work, the following procedures will apply:

  • Your health care professional must provide a written description of the applicable restrictions as they relate to fulfilling your job responsibilities and returning to work.
  • CMRRA may provide the treating health care professional with a description of the position and/or a mental/physical demands analysis.
  • With your consent, your health care professional may prefer to contact People & Culture to discuss the modified duty by telephone.
  • Upon receipt of your health care professional’s report, People & Culture will consult with your Manager/Supervisor and you about modifying your pre-injury job and discuss the availability of appropriate modified duties.
  • If you are assigned to modified duties and aggravate the injury or disability from which you are recovering, it is your responsibility to notify and discuss your concerns with People & Culture. People & Culture will consult with the Manager/Supervisor who assigned you the work in these cases. If an agreement cannot be reached, People & Culture will contact your health care professional to discuss the suitability of the duties.
  • If appropriate modified duties cannot be found and if applicable, you can apply for Short Term Disability as determined by CMRRA’s policies.
  • Employees are expected to cooperate with the CMRRA’s efforts to accommodate.
  • The above procedures may be modified as appropriate depending on the circumstances of a particular situation.

Return to Work Process

CMRRA is committed to supporting employees who have been absent from work due to a disability. We will use the following process to help employees who require accommodation to return to work.

Step 1. Initiate the leave and stay in contact with the employee

If an employee needs to take a disability leave, s/he will inform his/her manager and People and Culture. The employee and manager will maintain regular contact, with the employee’s consent, to address any problems that may arise and facilitate the return to work process.

Step 2. Gather relevant information and assess individual needs

The employee and manager will work together to share information and find the most appropriate accommodation, for example:
Manager
• Provides the employee with return to work information
• Helps resolve any problems with treatment if requested to do so by the employee
• Maintains regular contact with the employee
• Ensures work practices are safe for returning employee
• Assists with identifying accommodations
• Assists with analyzing the demands of each job task Employee
• Gets and follows the appropriate medical treatment
• Provides updates about their progress, including information about his/her functional ability to perform the job
• Provides his/her health care provider with the return to work information Health care provider(s), union/workplace representative(s) and health and safety professional(s) may also participate in the process, if needed.

Step 3. Develop a return to work plan

After identifying the most appropriate accommodation, safety considerations and any transitional measures, capture the details in a written plan.
Depending on circumstances, the employee may:
• return to the original position
• return to the original position with accommodation(s) on a temporary or permanent basis
• return to an alternate position on a temporary or permanent basis
The return to work plan should be attached to the employee’s individual accommodation plan.

Step 4. Implement, monitor and update the plan

After implementing the return to work plan, the employee and manager will monitor and review the plan regularly to ensure that it remains effective. If the accommodation is no longer appropriate, they will reassess the situation (step 2) and update the plan.

CMRRA Inclusion Statement

CMRRA is committed to fostering an environment where our employees, clients, and partners feel valued and supported. As leaders in the music industry, we recognize that building a diverse, equitable, and inclusive organization is vital. Every day we aspire to do better than the day before because we wholeheartedly believe that there is strength in diversity and that we are stronger together.

CMRRA strives to provide an atmosphere free from barriers in order to promote equity and diversity. We celebrate and welcome the diversity of all employees, stakeholders, and external personnel. It is the policy of CMRRA to foster an environment that respects people’s dignity, ideas, and beliefs thereby ensuring equity and diversity in employment. We demonstrate our commitment to this by providing a supportive work environment and a corporate culture that welcomes and encourages equity of opportunities for all employees. “Equity” refers to the quality of being fair and impartial.

“Diversity” means the existence of variations of different characteristics in a group of people. These characteristics could be everything that makes us unique, such as our cognitive skills and personality traits, along with the things that shape our identity (e.g., race, age, gender, religion, sexual orientation, cultural background).

Guidelines

CMRRA has specific policies in place to prevent any discrimination on the basis of the protected grounds of the Ontario Human Rights Code (“the Code”). As such, CMRRA is dedicated to promoting diversity within the workplace.

All personnel actions regarding hiring, compensation, promotion, benefits, job assignments, transfers, lay-offs, return from lay-offs, company sponsored programs or events, etc. will be performed in a non-discriminatory manner in accordance with the requirements of the Code.

CMRRA will ensure that appropriate accommodations are made for individuals who require them as may be required by the Code.

An employee is required to participate in the accommodation process by providing CMRRA with information necessary to facilitate an appropriate accommodation and accepting reasonable accommodation offered by the Company. An employee’s failure to cooperate in the accommodation process may result in the request for accommodation being denied.

An employee who believes they have been discriminated against or denied accommodation contrary to this Policy should report this concern to the People & Culture, without fear of reprisal.

Cultural Competence

CMRRA will ensure that employees and stakeholders are culturally competent and may use various training initiatives to foster these competencies.

These training initiatives may include:

  • Allowing awareness of one’s own cultural view;
  • Encouraging positive attitudes towards cultural differences;
  • Obtaining knowledge of differing cultural practices and views; and
  • Teaching cross-cultural skills.

Hiring Practices

CMRRA is dedicated to recruiting and retaining a qualified workforce. In doing so, CMRRA is committed to hiring practices that are barrier-free and inclusive to attract a diverse, qualified talent pool.

CMRRA abides by and respects the principles set forth in the Code and the Accessibility for Ontarians with Disabilities Act as amended from time to time (the “AODA”).

In all cases, each applicant for employment is recruited, hired, and assigned on the basis of merit without discrimination based on race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex, sexual orientation, gender identity, gender expression, age, marital status, record of offences, family status, disability or any other protected ground under the Code.

Consistent with its obligations under the AODA, CMRRA will provide any necessary accommodation during the recruitment and selection process to an employee or applicant with a disability.

Notice of Availability of Documents:

Documents related to accessible customer service are available below and upon request by contacting CMRRA by phone, email or in person. CMRRA will provide these documents in an accessible format or with communication support, on request. We will consult with the person making the request to determine the suitability of the format or communication support. We will provide the accessible format in a timely manner and, at no additional cost.

2023 Accessibility Compliance Report

AODA Multi-Year Accessibility Plan

Sample Process – Individual Accommodation Plan

Sample Process – Return to Work

Changes to Existing Policies

Any policies of this organization that do not respect and promote the principles of dignity, independence, integration and equal opportunity for people with disabilities will be modified or removed.

This document is publicly available. Accessible formats are available upon request.

References:

Accessibility for Ontarians with Disabilities Act (AODA), www.aoda.ca

Accessible Customer Service Policy, https://www.ontario.ca/page/accessible-customer-service-policy