Office of the Superintendent of Financial Institutions
As an organization, OSFI strives to create environments that are inclusive for everyone. To achieve this vision, a level of honesty and understanding is critical to address barriers at OSFI faced by any employee or stakeholder with a disability. Steps have been taken to acknowledge this and we are dedicated to moving forward in a positive way. For these reasons and many more, I am proud to introduce OSFI’s Accessibility Plan 2023-2026.
The Accessibility Plan is our commitment to upholding the
Accessible Canada Act (ACA) principles. This work will guide the future of our accessible workplace. The
Accessible Canada Act aims to create a barrier-free Canada. It outlines expectations to improve overall accessibility and offer an environment that allows for more accessible technologies and products.
To successfully fulfill our mandate, OSFI nurtures three core values: Respect, Curiosity, and Stewardship. These values reflect those of the
Accessible Canada Act. This Accessibility Plan is an important step toward our own inclusivity goals.
We understand that accessibility barriers can exist at different stages of a career. This plan is our commitment to supporting employees by evaluating the accessibility of OSFI practices, policies, and processes. It begins at the recruitment stage and continues until an employee exits the organization. We are also examining and working to correct barriers and accessibility gaps that any person visiting our premises may face. We commit to implementing this 2023-2026 plan diligently at all levels of the organization, and acting swiftly to resolve new barriers that come to light along the way. Through experimentation, OSFI will strive to be an early adopter of innovative solutions to address barriers in our workplace.
I am very proud of OSFI’s work to build a safe and respectful workplace, and this Accessibility Plan sets an important foundation to improve inclusivity for persons with disabilities.
Peter Routledge, Superintendent of Financial Institutions
The Office of the Superintendent of Financial Institutions (OSFI) is an independent federal government agency that regulates and supervises more than 400 federally regulated financial institutions and 1,200 pension plans to determine whether they are in sound financial condition and meeting their requirements. OSFI analyzes financial and economic trends to identify emerging issues that could adversely affect institutions. Although OSFI plays an important oversight role, it does not manage the operations of institutions or pension plans. OSFI is a Schedule V agency under the
Financial Administration Act (FAA) and governed by the
Public Service Employment Act (PSEA).
OSFI’s corporate values of Respect, Curiosity and Stewardship form the basis of our work. We recognize that accessibility is a key part of living these values. OSFI is committed to supporting accessibility at all levels of our workforce. At OSFI, we are working on creating a barrier-free environment so that employees with disabilities are not prevented from providing their expertise in their service to Canada. We also want to make sure that the needs of any person with disabilities visiting our premises are always considered and met. We understand the importance of creating accessible and inclusive environments and are dedicated to helping create a more accessible Canada.
The accessibility lead for OSFI is in the Culture, Inclusion and Development Unit. For more information, to provide feedback, to get a description of our feedback process or to request alternate formats of this Plan, you can contact:
OSFI’s accessibility vision is to create a fully accessible, respectful, and inclusive workplace that values and enables disabled persons. While we work to develop our enterprise-wide Accessibility Strategy, we have created this Accessibility Plan following the framework identified in the Accessible Canada Regulations. The Culture, Diversity, Equity, and Inclusion Team is leading this work, but every employee at OSFI is responsible for learning about accessibility and demonstrating inclusion in their work, their workplace and their behaviours. We all have an important role to play.
To achieve that vision, the Accessibility Plan is designed to help all employees:
OSFI’s Accessibility Plan addresses the following key elements that create change and drive a culture of accessibility:
Accessibility refers to how services, technology, locations, devices, environments, and products are designed to accommodate persons with disabilities. Accessibility means giving people of all abilities equal opportunities to take part in life activities. The term implies conscious planning, design, and/or effort to make sure something is barrier-free to persons with disabilities. Accessibility also benefits the general population by making everything more usable and practical for all people.
According to the
Accessible Canada Act (2019):
“Barrier means anything – including anything physical, architectural, technological or attitudinal, anything that is based on information or communications or anything that is the result of a policy or a practice – that hinders the full and equal participation in society of persons with a physical, mental, intellectual, learning, communication or sensory impairment or a functional limitation.”
According to the
Accessible Canada Act (2019), disability is:
“A physical, mental, intellectual, learning, communication or sensory impairment – or a functional limitation – whether permanent, temporary or episodic in nature, that, in interaction with a barrier, hinders a person’s full and equal participation in society.”
Anyone can identify as a person with a disability (PWD) if they experience one or more of these impairments or functional limitations that, in interaction with a barrier, hinders their full and equal participation in society.
Refers to the core public administration (departments and agencies named in Schedules I and IV of the
Financial Administration Act (FAA), for which the Treasury Board Secretariat is the employer) and separate agencies (organizations named in Schedule V of the FAA).
The Accessibility, Accommodation and Adaptive Computer Technology (AAACT) is a program that offers public servants with disabilities a wide range of adaptive computer technologies, tools, training, services, and resources. The goal of the AAACT program is to help the public service support departments who offer programs and services to Canadians and to build accessible workplaces with equal opportunities for all employees
The promising practices presented under sections 4.1 – 4.6 of this Plan are a short summary of the actions that OSFI is already taking to improve accessibility in the priority areas. Some of these actions may be completed and others may be in the process of being implemented.
The planned actions presented under sections 4.1 – 4.6 of this Plan are the steps that OSFI intends to take to address the barriers. Some of these planned actions may have already begun and others may not yet have started.
To prepare for developing our Accessibility Plan, OSFI conducted a series of virtual interviews with more than 40 OSFI employees. We worked to capture diverse perspectives throughout the organization. We also conducted a focus group with more than 15 members of the Mental Health and Accessibility stream of the Inclusion Network. The Inclusion Network is a grassroots collection of employees working to improve mental health and accessibility awareness and supports for OSFI employees. The focus group with this network was designed to facilitate honest feedback and identify barriers to accessibility within the organization.
Employees who were consulted as part of the process included:
With each recommendation made, OSFI has provided an expected timeline for implementation. The timelines are as follows:
These suggested timelines consider the magnitude of the recommended action, the nature of the organization, and the potential barriers that may occur during the implementation process. Due to the complexity of implementation, these timelines are estimates and should not be interpreted as strict commitments.
OSFI as an organization is committed to creating a barrier-free workplace. The practice of creating this Accessibility Plan has revealed many things OSFI is doing well towards this goal as well as several areas for improvement. The primary focus of this Plan was to capture the perspectives of OSFI employees with lived experience and to understand diverse perspectives across OSFI. The findings presented in this Plan highlight these perspectives.
The barriers and recommendations in this Plan are presented across the seven priority areas under the
Accessible Canada Act (ACA), but there are several barriers to accessibility that touch multiple core areas.
One of these barriers is the need for improved communication regarding accessibility work already being done at OSFI. Our organization has taken many steps to remove barriers, simplify processes, and improve accessibility at large. These initiatives need to be better communicated to all employees so that the accessibility supports are understood.
There is also a need to improve accessibility training throughout the organization. Training needs to be offered at both the general awareness level as well as the role-specific level. OSFI will be working with managers to better understand the training needs for each role and will provide training accordingly.
The entire employee experience has been a core consideration in the development of this plan. OSFI wants to ensure that all aspects of accessibility are considered, from the first interaction a prospective employee has with OSFI until the time an employee leaves the organization. For this to happen, feedback from employees with disabilities is critical. OSFI is committed to implementing the planned changes in close consultation with persons with disabilities.
This Plan represents only the beginning stages of the work needed to eliminate barriers to accessibility at OSFI. As an organization, we are dedicated to following through on the actions presented in this Plan. We are excited to make progress in the coming years.
There are seven priority areas described under Section 5 of the
Accessible Canada Act. These areas include:
The following sections are divided into these areas. Each section will include a short summary, promising practices, barriers, and actions we plan to take to address each barrier.
Employment includes an employee’s entire experience at OSFI, from the time the recruitment process starts until they leave the organization. OSFI wants employees with disabilities to feel supported throughout their journey with us. This includes recruitment, hiring, onboarding, development, promotion, and exit from the organization. OSFI cares about being a responsible employer and is committed to ensuring a barrier-free workplace for all employees.
Barriers to accessibility observed at OSFI related to employment include:
OSFI recognizes the importance of training to improve awareness and understanding of accessibility. We have identified a lack of accessibility training at both the onboarding and role-specific levels. Standard training for all employees creates a baseline understanding of accessibility. OSFI employees have also expressed the need for training specific to their roles. Some role-specific training has been done. For example, there has been web accessibility training for the web team within Communications, Engagement and Stakeholder Affairs. However, OSFI would like to see more job-specific training on accessibility across the organization.
OSFI will complete a review of the training platforms and courses available. OSFI will work with team leads within each of the divisions to understand the type of training required specifically for their staff. OSFI will take action to provide training in a timely manner.
Responsibility and outcomes
OSFI has worked to attract and retain employees with disabilities. However, efforts must be made to ensure that Canadians with disabilities continue to be properly represented within OSFI. OSFI needs to identify where barriers to employment for persons with disabilities may exist within our hiring practices.
OSFI will review the staffing process to explore where barriers might exist for disabled applicants. OSFI also plans to increase disabled employee representation by developing a persons with disabilities-specific outreach program. By building relationships with organizations that support employment of persons with disabilities, OSFI can better promote employment opportunities.
The built environment at OSFI includes all physical spaces that OSFI employees interact with as part of their work, including work from home.
OSFI understands that accessible spaces are key to having an environment where people with disabilities can work to their full potential. Achieving accessibility of built environments is complex, because OSFI has employees who work in hybrid environments and office locations in Ottawa, Toronto, Montreal, and Vancouver.
OSFI has taken many steps towards creating and maintaining accessible spaces for our employees. We are working to identify barriers at our office locations and to make our spaces as universally accessible as possible. We will create more opportunities for our employees with disabilities to provide feedback on the built environment. We will also act quickly to fulfill accessibility related requests.
OSFI is dedicated to removing any physical barriers our employees with disabilities face. We will always consider accessibility as we build and update our spaces.
Barriers to accessibility observed at OSFI related to built environment include:
As OSFI transitions into a hybrid working environment, employees raised concerns about the accessibility constraints of unassigned seating. Unassigned seating can lead to challenges for employees with disabilities to have access to the tools and technologies they need to work effectively.
OSFI is committed to ensuring every employee feels fully supported when coming into the office to work. OSFI will also be engaging with persons with disabilities within the organization to collaboratively design a system of shared accessibility and ergonomic tools.
OSFI made major strides in offering ergonomic assessments to all employees who requested one. However, there are still many employees who do not go through the process of making these requests. Ergonomic assessments help all employees feel comfortable while doing their job. Ideally, more employees should be aware that these assessments are offered to all employees.
OSFI believes in supporting employees in their working setups and will continue to provide standard ergonomic assessments to all OSFI employees who request one. OSFI will work to better promote these assessments.
The Facilities team within OSFI works hard to be responsive to employees’ accessibility needs. However, there is opportunity to further engage with OSFI’s PWD community. OSFI understands that employees with lived experience of disability have valuable insights on how to make improvements to the built environment. The Facilities team at OSFI wants to add more ways to gather feedback about the built environment from employees with disabilities.
The Facilities team within OSFI will create an open call out to all employees requesting feedback on how the built environment could be made more accessible. As well, OSFI will explore bringing in built environment accessibility professionals to review built environment locations.
OSFI has historically had emergency evacuation plans that properly considered the needs of employees with disabilities. Some of the policies in these plans have been impacted due to the changing nature of the hybrid working environment. OSFI needs to review these evacuation plans to make sure we are still considering the needs of all employees.
OSFI will conduct a review of existing evacuation policies to identify ways for safe evacuation for all employees in the hybrid working environment. This review will include engagement with employees with disabilities to confirm evacuation policies fit the needs of all employees.
Information and Communication Technologies (ICT) in this report relates to all aspects of the technologies OSFI employees interact with as part of their job.
OSFI is making accessible ICT a top priority. We are aiming for universal design in our systems, making them easy to use for all while supporting individuals’ needs as required. OSFI wants to confirm that our hardware and software can be used by people with a wide range of abilities and disabilities. We are moving from a reactive approach to a proactive approach, where we plan for accessibility by design.
We also intend to improve our processes, practices, and communications about ICT to support accessibility. We are working toward a future where fewer barriers exist in ICT at OSFI for persons with disabilities and where obstacles to full participation are quickly removed.
Barriers to accessibility observed at OSFI related to ICT include:
The IT Division at OSFI is building up a solid base of accessible hardware and software offerings. There is a concern, though, that employees lack an understanding of the tools available to them. Not enough communication has been provided to make employees fully aware of accessibility offerings within IT.
OSFI and the IT Division are committed to promoting a variety of accessibility offerings to employees and plan to create a comprehensive list of all accessibility tools and resources. OSFI will share this list with all employees to familiarize them with what is available and what types of tools can be requested.
Both the IT and Service Desk teams within OSFI are committed to delivering high quality support to all employees. We are especially committed to ensuring accessibility barriers are addressed. Overall, there needs to be a review of all ICT processes to ensure that they are accessible for OSFI employees.
OSFI will work in consultation with persons with disabilities to perform a review of all ICT processes to establish where accessibility barriers may exist and how these barriers can be eliminated. OSFI will develop a communications plan to clarify any ICT processes that are unclear. OSFI will also provide documentation around accessibility considerations in each process.
OSFI needs to assess legacy tools and platforms used by OSFI employees to determine where they may present accessibility barriers.
OSFI aims to develop a high-level strategy around the use of these tools. Many of these tools are not developed internally at OSFI and are beyond the control of the organization. OSFI will verify that IT and Service Desk employees are familiar with the challenges posed by these platforms. IT and Service Desk employees will be available to support staff in navigating these platforms.
This section defined under the ACA relates to all forms of communications distributed within OSFI and communications distributed outside of the organization.
OSFI is committed to making all internal and external communications for the organization accessible by design – a mindset of designing policies, products, processes, and services with accessibility at the forefront. We want everyone to clearly understand the information we share and have easy access to information in formats that work for them.
Our goal is to exceed accessibility standards for communication by regularly reviewing our internal and external websites, documents, videos, and other media. We will create avenues for people with disabilities to provide feedback.
OSFI has already established many promising practices in accessible communications. We will work to share these practices across the organization. OSFI will create more opportunities for our employees and stakeholders to understand accessibility and share our commitment to being accessible by design.
Barriers to accessibility observed at OSFI related to Communications and other than ICTs include:
Although accessibility is a priority for OSFI, more can be done to ensure that all content developed for external and internal audiences (including Portable Document Formats, also known as PDFs, Power Point, Word, and videos) is accessible and meets accessibility standards.
OSFI is moving towards an accessible by design model. In doing so, employees will be aware of the proper accessibility standards for creating content. This movement towards accessibility by design will include the development of standards, training, and communications around the various aspects of accessibility.
Although OSFI is working hard to implement accessibility across all forms of communications, we want to better understand the types of accessibility requirements needed by OSFI employees.
The needs of all employees must be fully understood to remove communications barriers. OSFI will engage with employees with disabilities to understand their needs in this area and look at options to implement findings.
This section on procurement relates to all goods and services procured by OSFI as well as the procurement process itself.
As a large purchaser of goods and services, the federal public service can be a leader in accessible procurement. OSFI wants to incorporate universal design principles into procurement processes and consider the diverse needs of the broadest range of end users. We understand that thinking about accessibility from the beginning can cost less than modifying or replacing a good or service later.
OSFI will include accessibility criteria when specifying requirements for goods or services. OSFI will also incorporate accessibility features. We are committed to improving our processes and practices to make sure that requests for purchases related to accommodations for employees with disabilities are quickly managed. We want procurement at OSFI to be inclusive by design and accessible by default.
Barriers to accessibility observed at OSFI related to procurement include:
OSFI needs to increase accessibility training for procurement officers to allow these officers to better question vendors when identifying accessibility needs.
OSFI will increase accessibility training across the organization. We will provide specific training to procurement officers highlighting accessibility standards and clearly articulating OSFI’s expectations from vendors.
OSFI has already worked to make many of its procurement forms accessible internally. However, an increased effort around ensuring all procurement forms are standardized and meet accessibility standards is needed.
OSFI will conduct an audit of all procurement forms to evaluate their respective levels of accessibility. We will focus on ensuring outstanding accessibility gaps are addressed in these forms.
OSFI has requirements for prospective vendors to address accessibility in their proposals. However, many proposals that come in to OSFI are missing these requirements.
OSFI will work to make the requirements of prospective vendors clearer as it relates to accessibility. OSFI will also evaluate the potential of changing evaluation criteria to amplify accessibility in procurement decisions.
This section is centered around the ways in which OSFI engages with all external stakeholders.
As a prudential regulator, OSFI undertakes regulatory and supervisory activities as its main business line of service delivery. OSFI is working hard to become a more inclusive workplace for persons with disabilities. However, we need to better understand the accessibility of our interactions with our external stakeholders. We will seek out best practices and develop tools to better serve and respond to feedback from our stakeholders with disabilities.
Barriers to accessibility observed at OSFI related to design and delivery of programs and services include:
There is no publicly available process for external stakeholders to request accommodations or accessible materials from OSFI. Currently, stakeholders work with their point of contact at OSFI to ask for accommodations. OSFI could work to formalize this process.
OSFI will develop a robust process and make available so that stakeholders receive a consistently high level of accessibility support. This process will highlight to stakeholders the variety of ways accommodations can be provided and how they can make a formal request to receive these, as well as provide feedback.
Individual aspects of internal service delivery are doing well from an accessibility perspective. OSFI will now continue to focus our efforts on developing an overall strategy focused on accessibility for our both our internal and external stakeholders.
OSFI plans to start a formal conversation with relevant members of OSFI’s leadership to build out an accessibility strategy for internal and external service delivery. OSFI will engage with stakeholders in the development phase of the strategy to better understand what OSFI can do to further reduce and remove barriers during engagements.
Due to OSFI’s limited involvement with transportation, barriers have not been identified under this priority area. OSFI is committed to ensuring that all aspects of accessibility are considered. Should OSFI become more involved with any form of transportation, a full accessibility review will be conducted.
This Accessibility Plan is an important step for OSFI to create a more accessible workplace, but it cannot stand alone. Throughout this Plan, we have highlighted our commitments to addressing barriers within our organization. We are dedicated to acting on these commitments.
Accessible Canada Act mandates that annual progress reports be published to track progress on the implementation of the actions described in this Plan. OSFI is excited to continue the implementation of these actions. The progress reports we publish in the coming years will reflect our commitment to becoming barrier-free for persons with disabilities.
OSFI will be working in consultation with persons with disabilities to establish tracking and reporting mechanisms to monitor progress against the action items in this plan. The monitoring of progress against these actions will hold OSFI accountable to the accessibility commitments we have made. It will push us to work beyond just the actions set forth in this plan.
OSFI will continue to identify barriers to accessibility within our organization. We will remain committed to addressing these barriers and creating an organization that is inclusive of all.
OSFI welcomes feedback on accessibility, especially from persons with disabilities. We have established the following process for receiving and actioning feedback related to accessibility. Feedback related to barriers to accessibility at OSFI or the implementation of OSFI’s Accessibility Plan can be directed to:
Feedback can be submitted anonymously or with personal information identified. If the feedback was not submitted anonymously, it will be acknowledged within 15 business days. The feedback will be taken into consideration by the Culture, Diversity, Equity, and Inclusion Team. It will then be forwarded to relevant divisions when necessary. Feedback submitted anonymously will not receive a response.
If the feedback included contact information, any immediate action resulting from the feedback will be communicated to the person who submitted the feedback. All feedback related to accessibility will be captured in a central location for analysis and record keeping. Feedback will be used to help identify, prevent, and remove barriers in a timely manner.
© His Majesty the King in Right of Canada, as represented by the Minister of Finance, 2022, ISSN: 2817-1233, IN3-39E-PDF