The Information and Communications Standards under the AODA and the Information and Communication Standard under the Accessibility for Manitobans Act (AMA) both require organizations to make information and communication accessible to people with disabilities. Moreover, both standards require many of the same processes and practices to ensure accessibility. However, there are many important differences between the standards. The third review of the AODA recommends that the Ontario government should coordinate with other provinces and the federal government to ensure that accessibility laws are consistent across Canada. Therefore, requirements in the AODA may one day change to align with mandates under the Accessibility for Manitobans Act. In this article, we will explore requirements for accessible feedback processes in Ontario and Manitoba.
Accessible Feedback Processes in Ontario and Manitoba
The AODA’s Information and Communication Standards and the Accessible Information and Communication Standard of the Accessibility for Manitobans Act (AMA) both require organizations to have accessible feedback processes. In both provinces, organizations must create and implement processes to receive feedback using accessible formats or communication supports. In addition, once organizations receive this feedback, they must respond to it in accessible ways. Moreover, organizations must alert the public that they have these processes for receiving and responding to feedback.
Under Manitoba’s standard, all organizations should have these accessible feedback processes. However, the processes only apply to accessible communication. In other words, someone could not give feedback in an accessible format about a topic other than accessibility. For example, a restaurant surveying diners about new menu items would not need to make this survey accessible. While a diner could request an accessible survey, the law does not require the restaurant to prepare in advance.
On the other hand, under Ontario’s standards, organizations are not required to have accessible feedback processes specifically about communication. However, if an organization does have a feedback process about any topic, the organization must make that process accessible.
Implications of Accessible Feedback Processes in Ontario and Manitoba
The contrast in these laws suggests two different views about how people with disabilities can help organizations. The Accessibility for Manitobans Act implies that people with disabilities only have suggestions to make about accessibility. While non-disabled people can give feedback about any topic, people with disabilities can only give feedback related to accessibility. However, the AODA implies that people with disabilities should easily be able to offer advice on any topic.
Conversely, these laws also place different emphases on the importance of feedback. While the AODA allows feedback on any topic, it does not require every organization to have a feedback process. Although the AMA limits the topics that people can provide feedback about, it ensures that every organization will receive and respond to that feedback in accessible ways.
The respective strengths of accessible feedback processes in Ontario and Manitoba could combine to create coordinated accessibility law across the country.