About FIRB

The Manitoba Financial Services Agency

Accessibility Procedures and Practices

Updated April. 2019


Accessibility means giving people of all abilities opportunities to participate in all aspects of everyday life.

The Manitoba Financial Service Agency, which includes The Manitoba Securities Commission and Financial Institutions Regulation Branch, is committed to upholding the standards and guidelines put forward by the Accessibility for Manitobans Act and its customer service regulation. As a special operating agency of the Province of Manitoba, we strive to make our workspace a diverse, inclusive, safe, and respectful environment. This document has been prepared as part of the general Manitoba Government Accessibility Plan (MGAP).

The MFSA’s accessibility procedures and practices are consistent with the principles of independence, dignity and equality of opportunity for people with disabilities. The policies in this document have been written in accordance with reasonable accommodation practices and principles, and in compliance with The Human Rights Code.
This document reflects ongoing practices and measures in five (5) key areas of day-to-day activity:

1. Customer Service Standard
2. Information and Communication Standard
3. Transportation Standard
4. Employment Standard
5. Built Environment Standard

The eight (8) requirements of the Customer Service Standard, which are;

  • Meeting the communications needs of customers
  • Accommodating assistive devices
  • Welcoming support persons
  • Accommodating service animals
  • Maintaining barrier-free access
  • Advising customers on what accessibility features are not available
  • Inviting customers to provide feedback
  • Training staff on accessible customer service

Any current or future MFSA procedure or practice which does not adhere to Customer Service Standard principles will be reviewed, modified, or removed.

It should be noted that ‘Customer’ in this specific document refers to any visitor to an MFSA office space, or any staff member working in an MFSA office space.

The MFSA Accessibility Plan should be updated every five years.

Part 1. Baseline Report

A. Overview of Programs and Services

The MFSA is a Special Operating Agency of the Province of Manitoba that administers and enforces legislation for the province’s securities and insurance sectors, real estate and mortgage brokers, credit unions, caisses populaires, co-operatives, and trust and loan companies.

B. Accessibility Achievements

As of Jan, 2019,

The MFSA offices at 400 St. Mary Avenue are at level entry from the street with electronic door-opening facilities in place at front and rear entrances. Rear access to the building has a small ramp.

Elevators to the 2nd and 5th floors are easily accessible and have voice notification for each floor in English and French.

All three reception desks are set a lower level for easy access.

There are no stairs in our offices and hallways are acceptably wide and barrier free for ease of passage. Staff generally keep these halls clutter-free so there is no risk of encumbrance or injury.

Fifth floor washrooms are wheelchair accessible and have electronic door openers.

The Securities office does not have an electronic opener, but is kept open during office hours at all times.

www.mbsecurities.ca, www.recognizeinvestmentfraud.com, are mostly WCAG-compliant. There are currently three issues, noted in C.

www.moneysmartmanitoba.ca is generally WCAG compliant.  There are some minor issues with missing ALT text / attributes.

http://www.imworthit.ca/ is generally WCAG compliant. There are a few issues with html language codes, some issues with missing or incorrect alt-text, colour distinction issues, and other small formatting problems.

http://www.makeitcountonline.ca/ is generally WCAG compliant. There are similar issues as with the I’m Worth It site – language codes, alt text, colour and contrast, etc.

C. Accessibility Barriers

Fifth floor Real Estate office does not have electronic opener.

Second floor washrooms do not have electronic openers, but are not open to the public without an access code.

Second floor access to FIRB does not have an electronic opener – this was requested by MFSA of the building manager, Morgard, as of early 2018. A quote was provided, and it has been added to the MFSA budget for the fiscal year 2019-2020.

www.mbsecurities.ca, www.mbrealestate.ca, www.mbfinancialinstitutions.ca and www.recognizeinvestmentfraud.com  require proper language documentation. Developers should define the natural language of a document to ensure that screen readers and other user agents understand the language the document is to be interpreted in.  Specifically, when a document contains multiple inline language choices, screen readers and other assistive technology types must know what the default language type is to ensure they can appropriately switch between languages.

Per the HTML 4.01 recommendation, language declarations should be made in accordance with IETF RFC 1766.

The site also needs valid labels for form fields. When on-screen labels are present, they must be explicitly associated with form fields. When on-screen labels are not present, form fields must be given an accessible label. When form fields do not explicitly include a label, assistive technologies may incorrectly render the label or provide no label at all to users. When labels are not present or are incorrect, users of assistive technologies may not be able to complete a form.

Staff have not received training in MGAP guidelines, AMA, or The MFSA Accessibility Procedures and Practices document.

Part 2. Accessibility Plan

A. Statement of Commitment

The Manitoba Financial Services Agency is committed to ensuring equal access and participation for people with disabilities. We are committed to treating people with disabilities in ways that allow them to maintain their dignity and independence. We believe in inclusion. We are committed to meeting the needs of people who face accessibility barriers. We will do this by identifying, removing and preventing barriers if possible, and by meeting the requirements of The Accessibility for Manitobans Act (AMA).

B. Policies

See: Part 3, Practices & Procedures

C. Actions

  1. Establish Accessibility Working Group / Committee
    Management to appoint accessibility committee chair and group
    Group should establish expected outcomes and revise / update this document as needed|
    Group should establish workplan with multi-year timeframes
  2. Offer and provide information in accessible formats on request
    Develop a process for responding to requests for accessible supports / services
    Group chair should report processes to all staff by email
    Communications to promote availability of alternate formats on request, and include such wording on all new documents—which has been included on newer brochures and our Annual Reports.
  3. Staff awareness and training
    Management should confirm organization’s commitment in writing, endorse commitment at meetings and celebrate progress
    HR to offer training / awareness presentations to managers and staff
    Management to acknowledge achievements and share information with staff in the MFSA newsletter and staff meetings
  4. Monitor Progress
    Group chair and committee should track progress on challenges and requests for accommodation with budget implications
    Group should provide quarterly report to senior management
    MGAP should be integrated into operational plans
    Communications should provide progress report in MFSA annual report
    Accessibility plan should be posted on website and be made available in alternate formats

Part 3. Practices & Procedures

  1. Meeting the communications needs of customers

    MFSA does not make assumptions about anyone’s abilities or limitations; every person’s disability is different. We ask what method of communication works best, and communicate in a way that takes into account the nature of the barrier.
    To accommodate those with a communications barrier, MFSA staff will;

    Have patience and find a quieter space if required
    Have easy-to-read, san-serif fonts and plain language documents
    Have paper and pen available if required
    All publications must include, ‘This publication is available in alternate formats upon request.’
    Signage or verbal greeting will begin with ‘How can we help?’

    Websites: All web-based MFSA services must be accessible in order to provide equal access and equal opportunity to people with disabilities. MFSA sites will be accessible by following W3C priority 1 and 2 standards and/or Web Content Accessibility Guidelines (WCAG 2.0).

  2. Accommodating assistive devices

    The MFSA recognizes people with disabilities may use their personal assistive devices when accessing our goods, services, or facilities, or in the course of their daily duties.

    In cases where the assistive device presents significant and unavoidable health or safety concerns, we will attempt to use other measures to ensure the person with the disability has proper access.

    MFSA staff will be trained/familiarized with various assistive devices. This training will include appropriate interactions with those using an assistive device.

  3. Welcoming support persons

    The MFSA welcomes individuals who are accompanied by a support person.

    In practice, this means creating additional space when needed for support persons, and participating in training for appropriate interaction with individuals accompanied by support persons.

  4. Accommodating service animals

    The MFSA welcomes service animals as defined by the Human Rights Code of Manitoba, “an animal that has been trained to provide assistance to a person with a disability that relates to that person’s disability.”

    A service animal can usually be identified through visual indicators. If the animal cannot be immediately identified as a service animal, MFSA staff may ask if the animal is offering assistance and whether the animal has been trained to provide assistance.

    MFSA staff will not interact (pet, feed, play) with a service animal without the expressed permission of its handler.

    The individual with the service animal is expected to maintain control of the animal through physical means, voice, signal, or other means.

    Training will ensure MFSA staff understand the rights of persons accompanied by service animals.

  5. Maintaining barrier-free access

    The MFSA is committed to creating and maintaining a barrier-free space for customers and staff.

    Halls, ramps, meeting rooms will be kept clear of clutter or obstacles to movement, and adequate space will be maintained for mobility devices, as well as adequate seating provided in public areas.

  6. Advising customers on what accessibility features are not available

    In the event of a planned or unexpected disruption of services or facilities affecting individuals disabled by barriers, MFSA staff will post notices and when possible announce the disruption. A clearly posted notice should include additional information on the reason for the disruption, anticipated length, and a description of alternative facilities or services if available.

    MFSA staff will exercise best judgement on what services/facilities are affected by these procedures and practices and how best to notify customers/staff.

  7. Inviting customers to provide feedback

    The MFSA welcomes feedback on how accessible customer service is offered, which will help staff identify barriers and respond to future concerns. The MFSA will set up a process to receive and respond to feedback, including what action will be taken in response to complaints.

    Customers / staff will be provided with accessible feedback formats and communication supports upon request.

    Feedback will be directed to the Controller and the Executive Assistant, and may be referred to a Director-level office or higher depending on the nature of the complaint.

    Feedback should be met with an immediate response indicating receipt.

    Customers / staff can expect to hear back within five business days.

  8. Training staff on accessible customer service

    All MFSA staff will receive training on accessible customer service, and new hires should be trained within an acceptable timeframe.

    This training will include, but is not limited to:
    • The purpose of The Accessibility for Manitobans Act and the requirements of the Customer Service Standard
    • The policies and actions related to the Customer Service Standard
    • How to interact and communicate with disabled people, including persons who use an assistive device or require the assistance of a service animal or a support person
    • What to do if a person with a disability is having difficulty in accessing our facilities or services

Changes to the MFSA Accessibility Procedures and Practices should be brought to the attention of staff, and additional training can be considered. Updates in the monthly newsletter are required.

Accessibility Committee
The MFSA Accessibility Committee is responsible for identifying, removing, and preventing barriers to accessibility if possible, and will ensure that MFSA’s Accessible Customer Service practices and procedures are reviewed and updated as needed.  The Committee should have representation from Securities, Real Estate, and FIRB, if possible.