AODA – Integrated Accessibility Standards Regulation (IASR) Information and Communications Policy

This policy is intended to meet the requirements of the Integrated Accessibility Standards, Ontario Regulation 19111 for the Information and Communications Standard set forth under the Accessibility for Ontarians with Disabilities Act, 2005. This policy applies to the provision of information and communications services and materials for people with disabilities.

All information and communications materials and services provided by Starlight Group Property Holdings Inc. (“Starlight”) shall follow the principles of dignity, independence, integration and equal opportunity.


Accessible Formats – Include but are not limited to large print, recorded audio and electronic formats, braille and other formats usable by persons with disabilities.

Communication Supports – Include but are not limited to captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications.

Conversion Ready – An electronic or digital format that facilitates conversion into an acceptable format.

General Principles

In accordance with the Integrated Accessibility Standards, Ontario Regulation 19111, this policy addresses the following:

General RequirementsFeedback ProcessAccessible Formats and Communication SupportsAccessible Websites and Web ContentEducation and Training ResourcesExceptionsReview

A) General Requirements

General requirements that apply across Information & Communications and Employment are outlined as follows.

Establishment of Accessibility Policies and Plans

Starlight will develop, implement and maintain policies governing how it will achieve accessibility through these requirements.
Starlight will include a statement of its commitment to meeting the accessibility needs of persons with disabilities in a timely manner in its policies. These documents will be made publicly available in an accessible format, upon request. Starlight will establish, implement, maintain and document a multi-year accessibility plan outlining its strategy to prevent and remove barriers and meet its requirements under the IASR. Accessibility plans will be made available in an accessible format, upon request, and will be posted on our website.
Starlight will review and update its accessibility plan once every five (5) years and will establish, review and update our accessibility plans in consultation with persons with disabilities or an advisory committee. Annual status reports will be prepared that will report on the progress of the steps taken to implement Starlight’s accessibility plan. This status report will be posted on our website. If requested, the report shall be created in an accessible format.

Procuring or Acquiring Goods and Services, or Facilities

Starlight will incorporate accessibility criteria and features when procuring or acquiring goods, services or facilities. The only exception is in cases where it is impracticable to do so.

Training Requirements

Starlight will provide training for its employees regarding the IASR and the Ontario Human Rights Code as they pertain to individuals with disabilities. Training will also be provided to individuals who are responsible for developing Starlight’s policies, and all other persons who provide goods, services or facilities on behalf of Starlight. Training will be provided as soon as is reasonably practicable, but no later than January 2016. Training will be provided on an ongoing basis to new employees and as changes to Starlight’s accessibility policies occur.


Starlight will maintain records on the training provided, when it was provided and the number of employees that were trained.

B) Feedback Process

Starlight will ensure that all feedback processes (both internal and external) are made accessible to clients/​customers or employees, upon request. In accordance with the Accessibility Standards for Customer Service, Ontario Regulation 42907, Starlight will make the availabilityof accessible feedback formats publicly known.

C) Accessible Formats and Communication Supports

Unless deemed unconvertible, Starlight will provide or arrange for the provision of accessible formats and communication supports for persons with disabilities, upon request. Accessible formats and communication supports will be provided in a timely manner and at no additional cost to the individual. Starlight will take into account the person’s accessibility needs when customizing individual requests and shall consult with the individual making the request to ensure suitability.
Starlight will make the availability of accessible formats and communication supports publicly known.

D) Accessible Websites and Web Content

Starlight will ensure that our website and all web content published after January 1, 2012, conform to the Web Content Accessibility Guidelines (WCAG) 2.0 in accordance with the schedule set out in the IASR.

E) Exceptions

The Information and Communications Standard does not apply to:

Unconvertible information or communications; orInformation that the organization does not control either directly or indirectly through a contractual relationship.

Unconvertible Information or Communications

If it is determined, in consultation with the requesting party, that information or communications are unconvertible, Starlight will ensure that the individual who made the request is provided with an explanation and a summary of the information.
Starlight will classify information or communications as unconvertible where:

It is not technically practicable to convert; orThe technology required to make the conversion is not readily available.

F) Review

This policy will be reviewed regularly to ensure that it is reflective of Starlight’s current practices and legislative requirements.