Indeed.jobs Applicant Privacy and Accessibility Policies

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1. Introduction

Indeed has a responsibility to protect and preserve the private information of every applicant to a role with Indeed, and we take that responsibility seriously. This Privacy Policy is provided by Indeed, Inc. and its affiliates (‘Indeed’) to inform applicants for roles with Indeed about our activities relative to the handling of personal data concerning applicants (‘Applicant Personal Data’), namely information that identifies or may identify you as a specific individual. This Privacy Policy covers all individuals applying for roles at Indeed, including applications for all types of permanent and non-permanent positions. The primary applicable data controller in each case will be the Indeed entity that intends to enter the employment contract or contract for services with the applicant (Indeed, Inc. will be the data controller of applicants’ personal data who are located in the United States and Indeed Ireland Operations Limited will be the data controller of applicants’ personal data who are located outside of the United States.

2. Applicant Personal Data We Collect

2.1 Applicant Personal Data Provided Directly By You

During the application, recruitment, and onboarding process at Indeed, we may collect, store and process the following types of applicant personal data directly from you:

• identification and contact details, such as your name, address, telephone/email address, ID/passport, bank account details, social security numbers;
• job application information, such as academic and professional qualifications, CV/resume, transcripts and employment references, cover letters, information from interviews, compensation/benefits requests, relocation information, and any other information you provide to us in support of and during the recruitment process;
• URL links to online platform pages such as LinkedIn, other social networks and career sites, or portfolio sites; and
• information about your work eligibility, such as immigration status, work authorisations, and visas.

In limited situations, we may request, on a voluntary disclosure basis, limited and targeted provision of sensitive applicant personal data such as racial/ethnic origin, military status, disability status, and gender for the purposes of government reporting obligations and/or ongoing equal opportunities and diversity monitoring, where permitted by law. Additionally, you may provide personal information so that Indeed can arrange for any necessary accommodation access during the recruitment process. Applicants may also provide Indeed with sensitive applicant personal data, even where this is not solicited by Indeed. In all cases, Indeed will handle such sensitive applicant personal data in accordance with applicable laws.

2.2 Applicant Personal Data Provided by Third Parties

Indeed may also collect information about you from third parties or public sources as needed to support our recruitment process. For example, before your employment or appointment with Indeed, we may collect information from appropriate social media sources for recruitment purposes. We also may conduct background screenings through a third-party service provider and collect information about your past education, employment, credit and/or criminal history (where permissible and in accordance with applicable law). Alternatively, third parties may refer or recommend you to our recruiters.

– When you log in or use Indeed.jobs from some third-party websites

Third-Party Websites sign-in is not required. You can also log-in using the email address and password of your choice.

In order to log in using a third-party account such as Facebook, Google, LinkedIn, or Microsoft, your Indeed.jobs account will need to be connected to that third-party account.

Prior to log-in using your third-party account, you will need to have created an Indeed.jobs candidate profile. Please note, when you log in to Indeed.jobs using your Facebook, Google, LinkedIn or Microsoft account, these third-party websites will use cookies in order to authenticate you as their user.

By accessing Indeed.jobs through your Facebook, Google, LinkedIn, or Microsoft account, you understand that these third-party websites will share certain data with Indeed, for the purposes of authentication to permit you to access Indeed.jobs in a secure manner. The data commonly shared with Indeed is the email address linked to the third-party account. These third-party websites may also ask for your permission to share certain other details with Indeed, including but not limited to your name, profile picture, and public profile information.
Once you give this permission, the requested information will be shared with Indeed. This information will be used to provide services to you. The shared information will remain associated with your Indeed.jobs Profile until you modify or delete it.

If you no longer wish to share data with Indeed from these third-party accounts or wish to disable the connection between your Indeed.jobs account and these third-party accounts, you will need to adjust your account privacy settings directly from the third-party website.

2.3 The Legal Basis on Which Indeed Collects and Processes Your Applicant Personal Data

Indeed collects and processes your Applicant Personal Data on the basis of different legal grounds, depending on the nature of the Applicant Personal Data being provided and the type of processing involved.

– Performance of a contract

Most of the applicant personal data processed by Indeed is performed on the basis that it is necessary for the performance of an employment contract or contract for services with you, or in order to take steps at your request prior to entering such a contract.

– Legitimate interest

A second ground relied upon by Indeed for other types of processing of your applicant personal data is that it is necessary for the purposes of legitimate interests pursued by Indeed, for example for the purposes of approaching you in relation to other roles at Indeed for which we believe you may be suitable.

– Compliance with a legal obligation

A third ground relied upon for certain types of processing is that it is necessary in order to allow Indeed comply with a legal obligation.

– Consent

Finally, in certain limited situations, Indeed may rely on your consent in order to process your applicant personal data. Where Indeed requires your consent in order to collect and process certain applicant personal data, we seek your consent at the time of provision, and such processing will only be performed where consent is secured. You can withdraw your consent by sending an email to applicantprivacy@indeed.com.

3. Purposes of Processing and Uses of Your Applicant Personal Data

We collect, process, store, maintain and transfer applicant personal data as we determine reasonably necessary in order to perform Indeed’s recruitment process. Applicant personal data is used in the recruitment process for purposes such as:

• determining the applicant’s qualifications, skills and background for a particular position;
• determining the applicant’s right to work;
• conducting background checks and similar inquiries in compliance with applicable laws, and otherwise to comply with all applicable laws;
• communicating with an applicant during the recruitment process;
• carrying out functions in relation to an applicant’s future employment; and
• managing and improving Indeed’s recruitment process.
• understanding, promoting and assisting in ensuring that our recruitment process is diverse and inclusive.

Processing of your applicant personal data may also be necessary in order to allow Indeed to comply with a legal or regulatory obligation. An example of this would be where Indeed is required to retain candidate records for fixed periods of time in order to comply with local legal requirements.

If you wish to obtain more information on any of the above-listed items or an exhaustive list of all the purposes for which Indeed is processing your applicant personal data and understand which of these purposes are strictly necessary to your recruitment process, please contact applicantprivacy@indeed.com.

Please refer to sections 4.2 and 4.3 of this privacy policy for more details on third party service providers and other third parties we may share your applicant personal data with.

4. Disclosures and Transfers of Your Applicant Personal Data

Indeed will not share or otherwise disclose applicant personal data for purposes unrelated to those detailed in this privacy policy without the prior consent of the applicant. To that end, Indeed will take reasonable precautions to allow access to applicant personal data to only those Indeed employees, agents, contractors, or similar entities to the extent necessary for the purposes set out in this privacy policy.

Such disclosures of applicant personal data in the course of the recruitment process will usually involve the transfer of applicant personal data to countries outside of where the information was originally collected (including countries outside the European Economic Area). All such transfers are performed in full compliance with applicable data protection rules and subject to appropriate safeguards, primarily through the use of extensive data protection agreements. Please refer to section 4.4 of this privacy policy for more information about the transfer of your applicant personal data to foreign countries.

4.1 Transfers of Your Applicant Personal Data Between Indeed Affiliated Entities

Applicant personal data may be disclosed among various affiliated companies within Indeed for the purposes set out in this privacy policy.

4.2 Transfers of Your Applicant Personal Data to certain Third-Party Service Providers

In the course of our recruitment activities, Indeed may make certain applicant personal data available to third parties who provide services to us to support those activities. Indeed will only do so where such a transfer is necessary, and in accordance with applicable data protection rules.

Your applicant personal data may be made available to the following types of service providers:

• companies that provide or help operate our applicant database,
• companies that help with relocation support services,
• companies that provide payroll support services,
• companies that help with verification/background checking services,
• companies that help with candidate experience surveys,
• cloud services companies that provide hosting, data storage, and other services pursuant to standard terms and conditions that may be non-negotiable
• companies that help improve Indeed services to applicants. These third parties may provide data points including how much time you spend on specific pages, which links you choose to click, and data that helps determine user preferences. This information enables us to build and maintain our services with user feedback. These third parties may use cookies and other technologies to collect data on your behaviour and devices such as the device type, browser information, and preferred language.
• companies that help manage candidates’ recruitment life cycle via cloud-based recruitment software solutions. These are known as applicant tracking systems (ATS).

These service providers may change over time but we will always use trusted service providers who will handle your applicant personal data in a manner consistent with this privacy policy and in accordance with applicable law.

4.3 Transfers of Your Applicant Personal Data to Other Third Parties

In addition to section 4.2, Indeed may also disclose your applicant personal data to other third parties in certain limited circumstances, including (but not limited to):

• to comply with our legal obligations;
• to establish, exercise or defend against potential, threatened or actual litigation;
• where necessary to protect Indeed, your vital interests, or those of another person; or
• in connection with the sale, assignment or other transfer of all or part of our business.

Please contact applicantprivacy@indeed.com if you would like to get more information on these third parties.

4.4 Region-Specific Information

Indeed is a global organisation with offices in multiple locations around the world. This means we may transfer your personal information to other Indeed entities, third parties or business partners in various countries. We have implemented measures to safeguard your personal information should it be transferred to another country, which are set out below. In this section you will also find information relevant to your specific region, where applicable.

Europe: Cross-border data transfers outside the EEA, UK and Switzerland

Where appropriate, Indeed Ireland’s transfers of Personal Data of individuals in the EEA, the United Kingdom, and Switzerland to jurisdictions outside the EEA, United Kingdom, and Switzerland are performed using lawful transfer mechanisms pursuant to GDPR. For example, transfers are typically based on the European Commission’s standard contractual clauses. These agreements also incorporate the protections and requirements provided for under Chapter V (and Article 28, where appropriate) of the GDPR.

EU-US Data Privacy Framework 

Indeed Inc. complies with the EU-U.S. Data Privacy Framework program (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework program (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Indeed Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  Indeed Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework program Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

The Data Privacy Framework Principles are:

• Notice
• Choice
• Accountability for onward transfer
• Security
• Data integrity, and purpose limitation
• Access
• Recourse, enforcement, and liability

Below is also a list of the Indeed U.S. entities or U.S. subsidiaries that adheres to the EU-U.S. DPF Principles: 

• Indeed Inc., 
• HR Tech Investments LLC, 
• Indeed Hire, Inc., 
• RGF OHR USA, Inc., 
• SH, Inc., 
• Resume.com Inc., 
• Prehire, Inc., 
• JS Media Inc., and
• Indeed Financial Services, Inc.

Indeed Inc’s business operations are aligned with the DPF Principles as further detailed below:

• Data collection and use – For the types of personal data collected and details of the purposes for which Indeed Inc. collects and uses personal information, please refer to the “Data Collection and Use” section.
• Contacting Indeed Inc.- On how to contact Indeed Inc. with any inquiries or complaints, please see our “Contacting Indeed” section.
• Who we share your data with – Regarding the type or identity of third parties to which Indeed Inc. discloses personal information and the purposes for which it does so, please see the “Who we share your data with” section.
• Your personal data rights – Regarding the right of individuals to access their personal data and the choices and means Indeed Inc. offers individuals for limiting the use and disclosure of their personal data, please see our “Your personal data rights” section.
• Complaints and Disputes:
  • In compliance with the EU-US Data Privacy Framework Principles, Indeed Inc. commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the DPF Principles. European Union, Swiss and United Kingdom individuals with DPF inquiries or complaints should first contact Indeed Inc.
  • Indeed. Inc has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you. If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2
  • For more information, please see the “Complaints and Disputes” section.
• Indeed Inc. is subject to the investigatory and enforcement powers of the FTC.
• Indeed Inc. shall, where required, disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. For more information, please see our “Transparency Report“
• Regarding Indeed Inc’s liability in cases of onward transfers to third parties, a DPF participating organisation has responsibility for the processing of Personal Data it receives under the DPF and subsequently transfers to a third party acting as an agent on its behalf. Indeed Inc. shall remain liable under the Principles if its agent processes such personal data in a manner inconsistent with the principles unless Indeed Inc. proves that it is not responsible for the event giving rise to the damage.

United States: Your California privacy rights

The following rights and information are provided to California residents.

— The sale of your personal data

California has defined ‘sales’ under the California Consumer Protection Act (CCPA) and how certain transfers of Personal Data that are integral to the products and services we offer to our users may be captured by this definition.
Indeed will not sell your applicant personal data.

— CCPA requests report

As described in section 6, Indeed allows all of its users to exercise their right to access or delete their user data. The form mentioned there is the primary method by which users exercise their rights under applicable privacy laws, like GDPR and CCPA.

Japan: APPI privacy compliance

If you are a user located in Japan, this section applies to our processing of your personal data under the requirements of the Act on the Protection of Personal Information (APPI).

— Transfer of your personal data to our affiliates and third parties in foreign countries

Indeed may transfer your personal data to our affiliates and third parties in foreign countries for the purposes described in section 3. The details of such transfers can be found here.

— Disclosure of information

Under APPI, if you are a resident of Japan, Indeed will disclose, when requested, the following information:

• Our security control measures (including safeguards for the international transfer)
• Regarding the transfer (based on equivalent action) of your personal data to our service providers located in foreign countries.

Please make your request through ​​applicantprivacy@indeed.com.

— Personally referable information

We provide cookies, which are personally referable information, to the following affiliated companies, which may manage and use it in conjunction with personal data in accordance with their privacy policies. A list of our affiliates and their privacy policies can be found here.

We may also link the personally referable information we receive with personal data we hold about you.

— Inquiries and complaints

If you have any inquiries or complaints regarding the use of your personal data, you may contact us using applicantprivacy@indeed.com.

5. Retention of Your Applicant Personal Data

You agree that Indeed and its affiliates may retain the information you provide in your application in order to permit Indeed to contact you in the future with respect to other positions for which you may be suitable. If you become an employee of Indeed, this information will become part of your employment record. Where you do not wish Indeed to retain your CV and cover letter (as applicable) for these purposes on our applicant database you might please refer to section 6 of this Privacy Policy to request the deletion of your Applicant Personal Data.

If you do not become employed or appointed by Indeed, and the retention of your applicant personal data is not necessary for the purposes set out in this privacy policy, such data will be confidentially deleted in accordance with the applicable laws and regulations.

Please note, Indeed might have a legal obligation to retain certain personal data from your job application for a period of time as mandated by the law local to your location.

6. Exercising Your Rights

You have a number of rights available to you with respect to your applicant personal data held by Indeed. These may include:

• the right to rectify your applicant personal data;
• the right to object to or restrict the processing of your applicant personal data;
• the right of access to and portability of your applicant personal data; and
• the right to delete your applicant personal data;

If you want to request that any of these rights be actioned in relation to your applicant personal data, or if you want to obtain more information as to how we process requests in relation to these rights, please contact applicantprivacy@indeed.com.

Such rights of rectification, objection, restriction, access, portability and deletion are subject to certain limitations, as provided for by applicable laws. Individual requests will be completed within the time allotted by relevant laws and regulations, which starts to run from the point of us confirming your request.
Where permitted, please note there may be a charge for subsequent requests from the same individual, which will be determined by Indeed and only imposed to the extent permitted by applicable law.

You can update and amend the application information that you submitted at any time in the same manner as you provided it to Indeed and/or from adjusting your user profile.

You can request a copy of your applicant personal data or request to have your applicant personal data deleted, directly from your user dashboard. Please note that when such requests are made, they will take effect immediately and there will be no follow-up confirmation that your applicant personal data were actioned as requested.

When you request access to your applicant personal data, these will be sent to the email address associated with your user account, in a readable format.

When you request the deletion of your applicant personal data, any in-flight or in-progress applications will be cancelled and your user profile information will be deleted. You will no longer be able to access your user profile or use the email address associated with it in order to create a new user profile. However, you will be able to create a new user profile at any time, using a different email address.

Please note, in order for Indeed to process a request to delete your applicant personal data, you must provide your physical address. This information is used to determine Indeed’s legal obligation to retain certain personal data from an application for a period of time as mandated by the local law in your location.

To facilitate your deletion request, you should make sure that your user profile is updated with your address or include your city and country when you submit the request. If your physical address does not appear in your profile or CV, or if it is incomplete or unclear, Indeed might contact you and ask you to provide some clarifications.

If you are unable to request a copy of your applicant personal data or to have them deleted directly from your user dashboard, or if you have further questions regarding the above processes or the information contained in your user profile, please contact applicantprivacy@indeed.com. Our teams will process any of these requests for you and answer your questions. Please contact us using the email address that you have been in contact with Indeed from, so we can verify your identity.

If you are a user located in Japan, you can also request disclosure of records provided to third parties.

7. General Inquiries and Complaints

7.1 Contacting Indeed

You may contact Indeed by emailing applicantprivacy@indeed.com. If you would like to contact Indeed’s Data Protection Officer, please send an email to privacy-dept@indeed.com.

7.2 Complaints

If you believe your data protection rights have been infringed by Indeed, you have the right to complain to the appropriate data protection supervisory authority in your jurisdiction. For example, if you are in the EU, Indeed’s main establishment in the EU is Indeed Ireland Operations Limited in Ireland, and it is regulated by the Irish Data Protection Commission, in which case you should consult this link for these purposes.

8. Updates to this Privacy Policy

Please review the “Last Updated” legend at the top of this page to determine when this Privacy Policy was last amended. Any changes to this Privacy Policy will become effective on the “Last Updated” date indicated above. We encourage you to check back to this Privacy Policy periodically in order to be aware of the most recent version.

9. Miscellaneous

Please also be aware this Privacy Policy covers the handling of your APD as a job applicant for a role with Indeed. It does not cover your use of Indeed products or services. To learn more about our data collection practices in our products or services, please see the privacy policy(ies) linked to those products and services.

Introduction and Statement of Commitment

In 2005, the government of Ontario passed the Accessibility for Ontarians with Disabilities Act (the “AODA”). The AODA requires that Indeed Canada Corp. (the “Company”) establish, implement, maintain and document a multi-year accessibility plan which outlines the organization’s strategy to prevent and remove barriers for persons with disabilities and to meet its requirements of the Integrated Accessibility Standards (the “IAS”).

This multi-year accessibility plan (the “Accessibility Plan”) outlines the Company’s strategy to prevent and remove barriers for persons with disabilities and to address the current and future requirements of the IAS in order that the Company may fulfill its commitment as outlined in the Company’s Integrated Accessibility Standards Policy and its Accessible Customer Service Policy.

This multi-year accessibility plan was last reviewed in January 2020. The next formal review and update of this multi-year accessibility plan shall be in January 2025 unless circumstances necessitate that it be reviewed and updated at an earlier date.

 

General Accessibility Standards

 

Requirement	Responsible Party	Action	Status
Accessibility Policy Develop, implement and maintain policies governing how the Company achieves or will achieve accessibility through meeting the requirements of the IAS. Statement of organizational commitment to meeting the accessibility needs of persons with disabilities in a timely manner. Prepare one or more written documents describing the policies and make the policies publicly available and provide them in an accessible format upon request.	Human Resources Canada	A policy has been developed and implemented and is posted on the Company’s Intranet.	Complete
Multi-Year Accessibility Plan Establish, implement, maintain and document a multi-year accessibility plan, which outlines the organization’s strategy to prevent and remove barriers and meet its requirements under this Regulation Post the accessibility plan on the website and provide the plan in an accessible format upon request. Review and update the accessibility plan at least once every five years.	Human Resources Canada	This multi-year accessibility plan has been implemented.It was reviewed in January and November 2020 and is scheduled to be reviewed and updated in January 2025 unless circumstances necessitate an earlier review. The multi-year accessibility plan has been posted on the Company’s website.	Complete and ongoing
Training Provide training to all existing employees, volunteers and all persons who participate in the development of AODA Policies. Training must include: the requirements of the IAS; the Human Rights Code as it pertains to persons with disabilities; and the AODA Policies as required by the IAS. Keep 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. Ensure that contractors providing goods, services, and/or facilities on its behalf have received the training required under the IAS.	Human Resources Canada	The Company trains its employees using the approved training modules provided by Access Forward and the Ontario Human Rights Commission.Records of the training provided are maintained.	Complete and ongoing

 

Information and Communication Standards

 

Requirement	Responsible Party	Action	Status
Feedback Ensure that processes for receiving and responding to feedback are accessible to persons with disabilities by providing or arranging for the provision of Accessible Formats and Communications Supports, upon request. Notify the public that Accessible Formats and Communications Supports are available in respect of its feedback procedures	Employee Experience	The Company has various ways of receiving feedback from customers and employees.Managers are trained on the need to provide Accessible Formats and Communication Supports upon request in respect of the Company’s feedback procedures. Please see the Notice of the Availability of Accessible Formats and Communication Supports below	Complete and ongoing
Accessible Formats and Communication Supports  Upon request, provide or arrange for the provision of Accessible Formats and Communication Supports in order to make its communications or information about the goods, services and/or facilities it offers accessible to persons with disabilities. Provide Accessible Formats and Communication Supports in a timely manner at a cost that is no more than the regular cost charged to other persons and in a manner that takes account of the person’s accessibility needs due to disability. Consult with the person making the request when determining the suitability of an Accessible Format or Communication Support and notify the public of the availability of the same.	Employee Experience	Managers are trained on the need to provide Accessible Formats and Communication Supports upon request in respect of the Company’s feedback procedures.Please see the Notice of the Availability of Accessible Formats and Communication Supports below	Complete and ongoing
Accessible Websites and Web Content Ensure that, where practicable, a New Internet Website and web content on such site(s) conforms with WCAG 2.0 Level A. By January 1, 2021, ensure that, where practicable, any website or content on that site(s) published after January 1, 2012 conforms with WCAG 2.0 Level AA to the extent required by the IAS.	Product Department in the United States	The website is expected to be compliant by January 1, 2021	Ongoing

 

Employment Standards

 

Requirement	Responsible Party	Action	Status
Recruitment Notify the public and employees about the availability of accommodation for applicants with disabilities in its recruitment processes	Talent Acquisition	A notification about the availability of accommodation during the recruitment process is included in every job posting.	Complete and ongoing
Recruitment, assessment, or selection process Notify job applicants, when they are individually selected to participate in an assessment or selection process that accommodations are available upon request in relation to the materials or processes to be used. Consult with an applicant requesting an accommodation to provide or arrange for the provision of suitable accommodation in a manner that takes into account the applicant’s accessibility needs due to disability	Talent Acquisition	Candidates are notified of the availability of accommodation in respect of the materials and process used during the assessment and selection process at every stage of the hiring process through a notification in the email signature of the talent acquisition employee with whom they are in contact.	Complete and ongoing
Notice to successful applicants Notify successful applicants of the Company’s policies for accommodating employees with disabilities.	Human Resources Canada	Successful applicants are notified of the Company’s policies for accommodating employees with disabilities through a clause in their employment contract.New employees are provided with these policies on the first day of their employment.	Complete and ongoing
Informing employees of supports Inform employees of policies used to support employees with disabilities, including policies on the provision of job accommodations that take into account an employee’s accessibility needs due to disability. Provided to new employees as soon as practicable after commencing employment Provide employees with updated information whenever there is a material change to its policies on the provision of job accommodations for employees with disabilities	Human Resources Canada	Employees are informed of the Company’s policies on accommodating employees with disabilities and updates to any such policies through the Company’s HRIS system.New employees are provided with these policies on the first day of their employment.	Complete and ongoing
Accessible Formats and Communication Supports for employees Upon the request of an employee with a disability, provide or arrange for the provision of Accessible Formats and Communication Supports in order to ensure that (i) information required by the employee to perform his/her job; and (ii) information generally available to employees in the workplace, is accessible to the employee with a disability. Consult with the employee making the request to determine the suitability of any Accessible Format or Communication Support. However, where the needs of an employee with a disability may be accommodated in various different ways, the Company reserves the right to determine the type of Accessible Format or Communication Support that will be provided in the circumstances.	Managers and Human Resources Canada	Managers are trained on the obligation to provide Accessible Formats and Communications Supports to employees upon request.Managers are also trained on the requirement to consult with the employee making the request to determine the suitability of the Accessible Format and/or Communication Support provided.
Workplace emergency response information Provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary, and if the Company is aware of the need for accommodation due to the employee’s disability. Provide this information as soon as practicable after becoming aware of the need for accommodation. With the consent of the employee, provide the workplace emergency response information to the person designated by the Company to provide assistance to the employee if the employee needs assistance by reason of disability Review individualized workplace emergency response information when the employee moves to a different location in the organization, when the employee’s overall accommodation needs or plans are reviewed and when the company reviews its general emergency response policies.	Managers and Human Resources Canada	A notification of the availability of individualized workplace emergency response information is posted on the Company’s health and safety bulletin boards.Managers are trained on the obligation to provide individualized workplace emergency response information to employees who so require it.	Complete and ongoing
Documented individual accommodation plans Have in place a written process for the development of documented individual accommodation plans for employees with disabilities. The process must include the following elements: The manner in which an employee requesting accommodation can participate in the development of the individual accommodation plan. The means by which the employee is assessed on an individual basis. The manner in which the Company can request an evaluation by an outside medical or other expert, at its own expense, to assist in determining if the accommodation can be achieved and, if so, how accommodation can be achieved. The manner in which the employee can request the participation of a representative from his or her bargaining agent, where the employee is represented by a bargaining agent, or other representative from the workplace, where the employee is not represented by a bargaining agent, in the development of the accommodation plan. The steps the Company will take to protect the privacy of the employee’s personal information. The frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done. If an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee. The means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs due to disability. Where requested, an employee’s individual accommodation plan will include any information regarding the provision of Accessible Formats and Communications Supports. Where required, an employee’s individual accommodation plan will include individualized workplace emergency response information.	Managers and Human Resources Canada	A policy on the development of documented individualized accommodation plans has been developed and is posted on the Company’s Intranet.	Complete and ongoing
Return to Work Process Have in place a documented return to work process for employees who have been absent from work due to a disability and who require disability-related accommodations in order to return to work. The return to work process must outline the steps the Company will take to facilitate the employee’s return to work and will include documented individual accommodation plans as part of the process	Managers and Human Resources Canada	A policy on the return to work process for employees who have been absent due to disability has been developed and is posted on the Company’s Intranet system.	Complete and ongoing
Performance management Take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when using its performance management process in respect of employees with disabilities.	Managers and Human Resources Canada	Managers have received training on the need to take accessibility needs into account when engaging in performance management.	Complete and ongoing
Career development and advancement Take into account the accessibility needs of employees with disabilities as well as any individual accommodation plans when providing career development and advancement to employees with disabilities.	Managers and Human Resources Canada	Managers have received training on the need to take accessibility needs into account when providing career development and advancement opportunities.	Complete and ongoing
Redeployment Take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when redeploying employees with disabilities.	Managers and Human Resources Canada	Managers have received training on the need to take accessibility needs into account when redeploying employees.

 

Design of Public Places

(The following requirements only apply to public spaces that are newly constructed or redeveloped on and after January 1, 2017.)

 

Description	Responsible Party	Action	Status
Obtaining Services Ensure that the Company meets the requirements of the Design of Public Places Standards in respect of its reception desk.	Real-Estate Team	The reception desk meets the accessibility standards.	Complete
Maintenance Ensure accessibility plans include: 1. Procedures for preventative and emergency maintenance of the accessible elements in public spaces. 2. Procedures for dealing with temporary disruptions when accessible elements required are not in working order.	Receptionist	The receptionist will provide a person with a disability service in another manner in the event the reception desk is temporarily unavailable.	Complete and ongoing

 

Customer Service Standard

 

Requirement	Responsible Party	Action	Status
Customer Service Policy Develop, implement, and maintain policies governing how the Company provides goods, services, or facilities to persons with disabilities in compliance with the requirements of the Customer Service Standard. Ensure policies address the use of assistive devices by persons with disabilities to obtain, use or benefit from the goods, services, or facilities or with the availability of other measures, if any, which enable them to do so. Prepare one or more written documents describing the policies and on request, give a copy of any such document to any such person. Notify persons to whom it provides goods, services, or facilities that the documents are available upon request.	Client Success Team and Human Resources Canada	A policy has been developed and implemented which addresses all of the requirements of the Customer Service Standards. The Policy is posted on the Company’s Intranet.Please see the Notice of the Availability of Accessible Formats and Communication Supports below.	Complete and ongoing
Service Animals Allow a person with a disability to be accompanied by a service animal while on the organization’s premises and to keep the animal with him or her unless the animal is otherwise excluded by law. If service animals are excluded by law, ensure other measures are available to enable a person with a disability to obtain, use, or benefit from the organization’s goods, services, or facilities.	Employee Experience	Employees have received training on this requirement.	Complete and ongoing
Support Persons Permit a person with a disability to be accompanied by their support person and that the person with a disability is not prevented from having access to the support person while on the premises. Before requiring the presence of a support person, consult with the person with a disability and consider the health and safety implications based on available evidence. If requiring the presence of a support person, waive fees for a support person.		Employees have received training on this requirement.A support person would be required to sign the same Non-Disclosure Agreement that the individual seeking service would be required to sign.	Complete and ongoing
Notice of Temporary Disruptions Provide notice of temporary disruptions to facilities or services used by persons with disabilities to access the organization’s goods, services, or facilities. Notice of the disruption must include the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if any, that are available.	Website Disruptions – Product and Engineering Disruptions to Facilities – Employee Experience Team	Employees have received training on this requirement and appropriate notices are made in the event of disruptions.	Complete and ongoing.
Training Ensure training on the provision of goods, services, or facilities to persons with disabilities is provided to everyone who: is an employee or volunteer provides goods, services, or facilities on the organization’s behalf; participates in developing the organization’s policies Ensure training includes a review of the purpose of AODA, requirements of the Customer Service Standard and instruction on: how to interact and communicate with persons with various types of disability how to interact with persons using assistive devices or requiring the assistance of a service animal or support person how to use equipment or devices available on premises or provided by the organization that may help with the provision of goods, services, or facilities to a person with a disability what to do if the person with a particular type of disability is having difficulty accessing the organization’s goods, services, or facilities Maintain records of when and to whom training is provided.	Human Resources Canada	The Company trains its employees using the approved training modules provided by Access Forward and the Ontario Human Rights Commission.Records of the training provided are maintained.	Complete and Ongoing
Feedback Process Establish a process for receiving and responding to feedback about the manner in which the organization provides goods, services, or facilities to persons with disabilities. The process must be accessible to persons with disabilities by providing, or arranging for the provision of, accessible formats and communication supports upon request. Make feedback process available to the public.	Employee Experience Team	A feedback process has been developed and is included in the Company’s Accessible Customer Service Policy.Please see the Notice of the Availability of Accessible Formats and Communication Supports below.	Complete and Ongoing
Accessible Formats & Communication Supports Provide, or arrange for the provision of, information in document(s) describing policies with respect to the Customer Service Standards in an accessible format or with communication supports upon request in a timely manner that takes into account the person’s accessibility needs and at no additional cost. Consult with the person to determine the suitability of the format or support.	Employee Experience Team	Employees are trained on the requirement to provide Accessible Formats and Communication Supports upon request.Please see the Notice of the Availability of Accessible Formats and Communication Supports below.