Accessibility Policy

Accessibility for Persons with Disabilities

1. Purpose

The purpose of this policy is to establish Random House of Canada Limited and Penguin Canada Books Inc.’s (Penguin Random House Canada) commitment to comply with the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and its accessibility standards. Policy attachments include Accessibility Guidelines relating to AODA accessibility standards that apply to the organization. Additional attachments will be added as applicable new accessibility standards come into effect.

2. Definitions


  • 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 service animal or on a wheelchair or other remedial appliance or device,
  • A condition of mental impairment or a developmental Disability,
  • A learning Disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,
  • A mental disorder, or
  • An injury or Disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.3.

3. The Policy

3.1.    Principles

In fulfilling of our mission, Penguin Random House Canada strives to provide its facilities, goods and services in a way that respects the dignity and independence of people with disabilities and facilitates their inclusion into all aspects of Penguin Random House Canada’s environment.

Penguin Random House Canada embraces the requirements of the AODA and is committed to expanding its access and support to all customers, employees and visitors with disabilities, by having as its goal a barrier-free environment to enable our customers access and our employees employment success.

To ensure AODA obligations are achieved Penguin Random House Canada complies with the Accessibility Guidelines in the attachments to this policy. Penguin Random House Canada uses reasonable efforts to ensure its policies, practices and procedures address the AODA standards in our daily operations and that they are consistent with the principles of independence, dignity, integration and equality opportunity.

3.2.    Scope

This Policy applies to all community members, and to all organizational activities, functions and premises.  The attached Accessibility Guidelines are consulted to determine the specific scope of application.

3.3.  Responsibilities

3.3.1.  Employees

Employees are required to comply with the accessibility standards established by the AODA, as set forth in the Accessibility Guidelines attached to this policy.

Employees are required to participate in training that is mandated by the AODA and this policy.

3.3.2.  Managers

In addition to their general responsibilities as employees of the organization, managers are responsible for ensuring that all employees within their departments are provided with the training required by the AODA and this Policy.

Managers are responsible to ensure the development and implementation of practices which encourage inclusion and accessibility in our workplace.

3.3.3.  Human Resources

Human Resources is responsible for facilitating the training of employees and any others as required by the AODA and this Policy.

Human Resources is responsible for providing guidance to managers and employees on the implementation of this policy and inclusive practices.

Compliance with AODA Accessibility Standards


These Guidelines are based on the Accessibility for Ontarians with Disabilities Act 2005 (AODA), Ontario Regulation 429/07, and the Integrated Accessibility Standards Regulation 191/11. 

The goal of the AODA is to remove barriers and make Ontario a welcoming and accessible place for persons with disabilities. To help organizations identify, prevent and remove barriers to accessibility, the AODA sets out General Requirements (see section 1 below) as well as specific Accessibility Standards in five key areas of daily living:

  • Customer Service (section 2)
  • Information and Communications (section 3)
  • Employment (section 4)
  • Transportation (N/A)
  • Built Environment (section 5)

These standards are rules that organizations in Ontario must follow so that people with disabilities have more opportunities to participate in everyday life.  Penguin Random House Canada commits to ensure operational policies and procedures are developed under the AODA standards and compliance requirements.

The purpose of these Guidelines is to inform employees and others of the means by which Penguin Random House Canada achieves its commitment to fully comply with AODA and its Accessibility Standards.

Accessibility resources for employees and supporting information are available from Human Resources.

1.    AODA General Requirement Guidelines 

Penguin Random House Canada ensures that AODA General Requirements are met by:

1.1 Establishing an Accessibility Policy and Guidelines;

1.2 Developing a Multi-Year Accessibility Plan;

1.2.1     Penguin Random House Canada has established and implemented a multi-year accessibility plan which is available on the website.  The purpose of this document is to outline the strategy to prevent and remove barriers.  The plan is reviewed and updated every five years.  An accessible version is provided on request to the Human Resources Department.

1.2.2     Penguin Random House Canada prepares an annual status report on the progress of measures taken to implement the strategy. 

1.3 Incorporating accessibility when procuring goods, services and facilities;

1.3.1     Penguin Random House Canada incorporates accessibility criteria and features when procuring or acquiring goods, services or facilities, except where it is not practicable to do so.

1.4 Training employees.

1.4.1     Penguin Random House Canada provides training on the requirements of the customer service accessibility standards, Integrated Accessibility Standards and on the Human Rights Code as it pertains to persons with Disabilities to:

1.4.2     All employees, and volunteers;

1.4.3     All persons who participate in developing the organization’s policies; and

1.4.4     All other persons who provide goods, services or facilities on behalf of the organization.

1.4.5     Penguin Random House Canada keeps a record of the training provided including the dates on which the training is provided and the number of individuals to whom it is provided through the Skill Soft training system.

2.    Customer Service Standard Guidelines

2.1. Scope

The Customer Service Standard applies to the provision of goods and services to members of the public and other third parties.

2.2. Compliance

Penguin Random House Canada ensures that AODA Customer Service Standard requirements are met by:      

2.3.1.        Penguin Random House Canada has established policies, practices and procedures on providing goods or services to people with disabilities;

2.3.2.        Customers or Employees can use their own personal assistive devices to access goods and services and to use services;

2.3.3.        Penguin Random House Canada will communicate with a person with a disability in a manner that takes into account his or her disability;

2.3.4.        Penguin Random House Canada allows people with disabilities to be accompanied by their Guide Dog or Service Animal in areas that are open to the public, unless the animal is excluded by law; or, if a Service Animal is excluded by law, by using other measures to provide services to the person with a disability;

2.3.5.        Penguin Random House Canada permits people with disabilities who use a Support Person to bring that person with them while accessing goods or services in premises open to the public or third parties;

2.3.6.        Where admission fees are charged, Penguin Random House Canada will provide notice ahead of time on what admission, if any, would be charged for the Support Person of a person with a disability;

2.3.7.        Penguin Random House Canada will provide notice when facilities or services that people with disabilities rely on to access or use our goods or services are temporarily disrupted; Penguin Random House Canada will provide notice of the reason, the expected duration and available alternatives if any.

2.3.8.        Notice may be by recorded message, posting on the Penguin Random House Canada website or other reasonable means in the circumstances.

2.3.9.        Penguin Random House Canada has provided training to staff, volunteers and others who interact with the public or other third parties on the topics outlined in the Customer Service Standard;

2.3.10.    Penguin Random House Canada accepts feedback from customers and employees in any format that is accessible to the individual including by phone, email, written or in person.

3.    Information and Communications Standard Guidelines

3.1 Scope

The Information and Communication Standard applies to information and communication to all customers and third parties interacting with Penguin Random House Canada.


The information and communications standards do not apply to:

  • Products and product labels,
  • Unconvertible information or communications, or
  • Information that Penguin Random House Canada does not control directly or indirectly through contractual relationship.

3.2 Compliance

Penguin Random House Canada ensures that AODA Information and Communications Standards are met by:

3.2.1     Making feedback mechanisms accessible;         Penguin Random House Canada accepts feedback from customers and employees in any format that is accessible to the individual including by phone, email, written or in person.

3.2.2     Making information accessible to the public;         Penguin Random House Canada, upon request, provides or arranges for the provision of Accessible Formats and Communication Supports for persons with Disabilities, in a timely manner that takes into account the person’s accessibility needs due to Disability; and at a cost that is no more than the regular cost charged to other persons.         Penguin Random House Canada consults with the person making the request in determining the suitability of an Accessible Format or Communication Support.         Penguin Random House Canada notifies the public about the availability of Accessible Formats and Communication Supports via the Accessibility page on the website.         If Penguin Random House Canada determines that Information or Communications are unconvertible, the organization provides the person requesting the Information or Communication with:    An explanation as to why the Information or Communications are unconvertible; and    A summary of the unconvertible Information or Communications.

3.2.3      Making emergency information accessible to the public;   Penguin Random House Canada prepares emergency procedures, plans or public safety Information and makes the Information available to the public via Penguin Random House Canada public website, signage throughout Penguin Random House Canada.     If required to evacuate, Penguin Random House Canada ensures that individuals with Disabilities are able to exit Penguin Random House Canada or exit particular facilities within Penguin Random House Canada safely. Penguin Random House Canada provides the Information in an accessible format or with appropriate Communication Supports, as soon as practicable, upon request. Requests for Accessible Formats should be made to the Health and Safety Officer.     Penguin Random House Canada provides individualized workplace emergency response Information to employees who have a Disability, if the Disability is such that the individualized Information is necessary and the employer is aware of the need for accommodation due to the employee’s Disability.  A Personal Emergency Plan (PEP) can be requested through the employee’s manager and will be developed with the Health and Safety Manager.  The Personal Emergency Plan will be stored in the database in the Health & Safety office.  

3.2.4          Making the website accessible in accordance with the legislated schedule  Penguin Random House Canada makes their Internet Websites and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, initially at Level A and increasing to Level AA, to websites and web content, including  web-based applications, that Penguin Random House Canada controls directly or through a contractual relationship that allows for modification of the product; and to all web content published on a website;

3.2.5          Producing accessible educational and training materials; 

4.    Employment Standard Guidelines

4.1 Scope

The Employment Standard applies to all applicants, candidates and employees of Penguin Random House Canada.

4.2 Compliance

Penguin Random House Canada ensures that AODA Employment Standards are met by developing specific practices to:

4.2.1     Make hiring accessible;

4.2.2     Advise staff about policies for supporting employees with disabilities;

4.2.3     Make information accessible to employees;

4.2.4     Develop accommodation plans for employees with disabilities;

4.2.5     Assist employees with disabilities in return to work; and,

4.2.6     Make performance management, career development and job changes accessible to employees. 

5. Built Environment Standard Guidelines 

5.1 Public spaces

The Penguin Random House Canada ensures that the Design of Public Spaces standards are met by developing specific practices to:

5.1.1 Follow accessibility requirements when embarking on the design of public spaces newly constructed or redeveloped

    • Recreational trails
    • Beach access routes’
    • Outdoor public use eating areas’
    • Exterior paths of travel
    • Accessible parking




Customer Service Standards

  • Customer: A member of the public or other third party to whom Penguin Random House Canada of Canada Limited provides goods or services.
  • Dignity: The state of being worthy of respect. Penguin Random House Canada treats persons with disabilities with dignity so as to permit the person to maintain self-respect and the respect of other people.
  • Guide Dog: An animal as defined in section 1 of the Blind Persons’ Rights Act.
  • Independence: A state of being that exists when a person with disabilities is allowed to do things on their own without unnecessary help or interference from others.
  • Service Animal: An companion animal for a person with disabilities where: it is readily apparent that the animal is used by the person for reasons relating to the disabilities; or, the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disabilities.
  • Support Person: Relating to a person with disabilities, means another person who accompanies the person with disabilities in order to help with communication, mobility, personal care or medical needs, or with access to goods or services. 

Integrated Accessibility Standards

  • Accessible Formats: May include, but are not limited to, large print, recorded audio and electronic formats, Braille and other formats usable by persons with Disabilities.
  • Communication Supports: May include, but are not limited to, captioning, alternative and augmentative Communication Supports, plain language, sign language and other supports that facilitate effective communication.
  • Communication: The interaction between two or more persons or entities, or any combination of them, where Information is provided, sent or received.
  • Conversion Ready: An electronic or digital format that facilitates conversion into an accessible format.
  • Information: Data, facts and knowledge that exists in any format, including text, audio, digital or images, and that conveys meaning.
  • Kiosk: An interactive electronic terminal, including a point-of-sale device, intended for public use that allows users to access one or more services or products or both.
  • Communications: The interaction between two or more persons or entities, or any combination of them, where Information is provided, sent or received.
  • Conversion Ready: An electronic or digital format that facilitates conversion into an accessible format.
  • Information: Data, facts and knowledge that exists in any format, including text, audio, digital or images, and that conveys meaning.
  • Extranet Website: A controlled extension of the intranet, or internal network of an organization to outside users over the Internet.
  • Internet Website: A collection of related Web Pages, images, videos or other digital assets that are addressed relative to a common Uniform Resource Identifier (URI) and is accessible to the public.
  • Intranet Website: An organization’s internal website that is used to share privately and securely any part of the organization’s Information or operational systems within the organization and includes Extranet Websites.
  • New Internet Website: Either a website with a new domain name or a website with an existing domain name undergoing a significant refresh.
  • Web Content Accessibility Guidelines: The World Wide Web Consortium Recommendation, dated December 2008, entitled “Web Content Accessibility Guidelines (WCAG) 2.0.”
  • Web Page: A non-embedded resource obtained from a single Uniform Resource Identifier (URI) using Hypertext Transfer Protocol (HTTP) and any other resources that are used in the rendering or intended to be rendered together with it by a user agent.