March-June 2022 Update

The Province of Ontario released new guidelines on March 9, 2022 regarding the lifting of various COVID-19 emergency orders. The mandatory vaccination policies were revoked on March 14, most masking mandates were removed on March 21, the Reopening Ontario Act expired on March 28, and all remaining emergency orders were expected to be removed on April 27. A full description of this media release from the Ministry of Health can be found here.

Individual organizations were encouraged to keep their own requirements in place. After reviewing the responses from related ministries and services/programs (ex. Ministry of Education, child care, high risk settings, other ABA providers), we decided to continue to follow Public Health’s COVID-19 recommendations, prior to the March 9 announcement. This meant that all current protocols in place would continue to be followed regarding vaccinations, masks, and using the school screener.

On April 22, 2022, the Province of Ontario released an update that included continued masking requirements in select indoor settings until June 11. A full description of this media release from the Ministry of Health can be found here.

On June 8, 2022, the Province of Ontario confirmed that all remaining directives would be revoked and replaced with Ministry of Health guidance for health care workers and organizations, including guidance on when masks should be worn in hospitals and other health care settings. The full media release can be found here. Ontarians are encouraged to continue to wear a mask if they feel it is right for them, are at high risk for severe illness, recovering from COVID-19, have symptoms of the virus, or are a close contact of someone with COVID-19. Organizations may also choose to implement their own policies as applicable.

Based on this most recent update from the Chief Medical Officer of Health, and after evaluating the various COVID-19 policies that are being implemented across services similar to ABA services (ex. childcare, schools, regulated health care professionals, public health services etc.), we have decided to follow the direction of Public Health and lift any mandatory masking requirements. Team members and parents are encouraged to keep the discussion open, to ensure everyone feels comfortable with this transition. Some team members may choose to still wear a mask, and some parents may feel more comfortable with masks being worn during sessions. We will continue to work together to provide a service that is not only effective and meaningful for the families we support, but also that maintains the health and safety of everyone involved. The vaccination policy written below will shift to a recommendation vs. requirement, for all team members. Rapid antigen screening is no longer provided by Best Behaviour Inc. If rapid antigen screening is available in your community, we encourage everyone to take advantage of this resource.

No other changes will be made; meaning that we will continue to use the school screener to conduct daily self-assessments and follow best practices when it comes to hygiene and symptom management.

Best Behaviour Inc. has been working very hard to adjust services and provide meaningful accommodations during the COVID-19 pandemic, and will continue to do so. Our services have been deemed essential, according to the most recent guidelines introduced on January 12, 2021. See page 27 under ‘Health care and social services’.

We have been able to safely provide in-person services (in home and in centre) by following all of the recommendations outlined by Public Health. We will also continue to provide various virtual accommodations, at both the service and supervisory levels.

• Virtual service options will be made available when clinically appropriate. This includes occasional shifts between virtual and in-person services, as needed in response to directions given by Public Health.

• Observations will continue to be provided in-person and virtually, depending on the needs of the learner and family preferences. Virtual observations and direct service will be delivered via secure platforms (ex. Ring security system, Google Meet). When planning for in-person observations, new and existing close contacts will be considered.

Self Assessments

The Government of Ontario has created a variety of self-assessment tools for individuals to use to screen and monitor COVID-19 symptoms.

We are asking all families to complete the school screener daily for their learner and other members of the household. Team members will also need to complete the school screener daily for themselves and members of their household. They may also complete a screener for the learner and/or family members upon arrival to session.

If everyone passes the screener, in-person services are deemed safe. If anyone does not, then the rest of the team should be notified and the recommendations listed on the screener will be followed.

Best Practices

The following precautions will be taken, in order to minimize everyone’s risk of exposure to COVID-19:

• If you or someone in your household is identified as a close contact of someone who has tested positive for COVID-19, please follow all necessary protocols outlined by Public Health re: confirmed and potential exposures to COVID-19.

• Complete regular daily self-assessments of all team members and clients (adults and children), home safety risk assessments, and point-of-care risk assessments.

• Encourage physical distancing whenever possible. Maintain a 2-metre distance and avoid unnecessary close contacts, and make use of outdoor space whenever possible. Arrange for pick-ups and drop-offs to happen outdoors, and stagger start/end times to avoid overcrowding. During times when individuals may become unmasked (ex. snack time), please keep these activities within a 10-15 minute time limit.

• If physical distancing is not possible, personal protective equipment (PPE) in the form of a mask or face covering is recommended, particularly for individuals 6 years of age and older. When interacting with individuals without a mask or face covering, additional protections such as eye protection is also recommended. PPE must be put on outdoors or while physically distancing, and replaced after each visit. Perform hand hygiene before PPE is put on, and before/after removal.

• For those who are unable to wear a mask due to individual challenges, working on mask desensitization or teaching appropriate mask use is a goal that should be introduced to the learner’s programming.

• Perform proper respiratory hygiene. Cover coughs with a tissue or cough into your elbow, followed by proper hand hygiene.

• Perform proper hand hygiene (including assisting children with hand hygiene) and incorporate additional hand hygiene opportunities. Wash hands upon entry and exit, before food is prepared/administered, and any other time hands are potentially contaminated or after other personal hygiene practices.

• Increase the frequency of cleaning and disinfecting objects, toys, and frequently touched surfaces (twice per day). Limit shared materials to only those that are essential. Ensure all toys used are made of material that can be cleaned and disinfected. Do not use water or sensory tables. Label personal items to discourage accidental sharing. Check expiry dates of cleaning products used and always follow manufacturer instructions.

• Do not share eating/drinking utensils or food. If food items are being shared with learners or team members (ex. bringing in a treat to celebrate a birthday), please ensure team members and parent/guardians are notified ahead of time. Please only bring in food items that have been prepared in regulated facilities (ex. store-bought or restaurant-prepared food items). Packaged/sealed food items are also preferred, since they can be sent home with learners if parents would feel more comfortable inspecting the food item before allowing the learner to consume it.

Vaccinations

The Province of Ontario has issued a directive that requires hospital and home/community care service providers to have a COVID-19 vaccination policy for employees, staff, contractors, students, and volunteers. The vaccination policy must be effective no later than September 7, 2021, and at a minimum will require these individuals to provide proof of one of three things:

• Full vaccination against COVID-19

• A medical reason for not being vaccinated against COVID-19

• Completion of a COVID-19 vaccination educational session, and regular antigen testing

In response to this directive, Best Behaviour Inc. has implemented the following vaccination policy, effective September 7, 2021:

• All employees, staff, contractors, students and volunteers must provide proof of immunization against COVID-19 by October 17, 2021. Public Health currently considers anyone who has received 2 doses of a COVID-19 vaccination for a minimum of 14 days as fully immunized. A copy of proof of vaccination can be sent to sophiacatania@bestbehaviour.ca to be kept on file. Only the enhanced vaccine certificate with QR code can be used as proof of vaccination at this time. Individuals can download their enhanced certificate with QR code by visiting covid-19.ontario.ca/get-proof.

• Anyone who cannot receive a vaccination due to a medical reason will have the option to submit a request for accommodation to sophiacatania@bestbehaviour.ca. This request must include a provincially-issued exemption QR code for verification. For more information about the exemption QR code process, please see the Province’s announcement on December 10, 2021.

• If a team member is unsuccessful after seeking a medical accommodation, proof of a first COVID-19 vaccination will be required within 72 hours of being notified or by October 17, 2021 (whichever comes first).

• Anyone granted accommodation or who is not yet fully vaccinated must test negative on a rapid antigen test no more than 72 hours prior to each scheduled day of work.

We will continue to monitor any updates regarding vaccinations, that would be relevant to our field of work and the learners we support.

At this time, full vaccination against COVID-19 is not mandatory for learners or families. The COVID-19 booster shots are also not required for team members, learners, or families.

Rapid Antigen Screening

Best Behaviour Inc. is enrolled in the Provincial Antigen Screening Program. This provides us with rapid antigen screening kits to be used for team members who work in-centre*. The Province of Ontario released new instructions around the use of rapid antigen tests on December 30, 2021. Due to the current shortage test availability, it is recommended that rapid antigen tests be used for “test-to-work” purposes. Asymptomatic team members can use them to return to work when they would otherwise be in isolation. Symptomatic team members can also use them to confirm if they have COVID-19 (with no requirement for a confirmatory PCR or rapid molecular test).

The results of all rapid antigen tests completed in-centre must be reported using the Google Form provided. Best Behaviour Inc. is required to report all rapid test results completed. Training on how to complete the screening and report results will be provided.

Team members who are not fully vaccinated and are required to complete a rapid antigen test every 72 hours may not use the tests provided at the centre. Please obtain tests from a community distributer. Personal rapid antigen test results do not need to be reported to Best Behaviour Inc. at this time. 

In the event that a team member receives a ‘positive’ result, they will be required to immediately cancel their sessions for the day and follow the subsequent recommendations from Public Health. We recognize the inconvenience this may cause families, however this is one of the ways we can help slow the spread of COVID-19 in our community and workplace.

*Screening provided by Best Behaviour Inc. is not currently available for team members working in-home, clients, or families. However, if a team member working in-home requires a rapid antigen test for a ‘test-to-work’ purpose or to confirm if they have COVID-19, please contact Sophia Catania to confirm if a rapid antigen test can be made available.

If rapid antigen screening becomes available in your community, we encourage everyone to take advantage of this resource.

In-Centre Reminders

Here's what you can do to help us maintain a safe work environment at the centre:

• No walk-ins. Please do not enter the unit unless you have been instructed to do so. Please call 226-755-0015 if you are unsure how to proceed upon arrival.

• Call before entering the unit for your scheduled appointment, if no one is there to meet you. You will be met in the hallway, outside, or at your designated meeting point.

• Before entering the unit, please complete a self-assessment. Contactless temperature checks may also be conducted.

• Wash or sanitize your hands upon entering the unit.

• Cough or sneeze into your elbow and avoid touching surfaces/materials when possible.

• Maintain a 2-metre distance between yourself and others when possible.

• If this is not possible, personal protective equipment (PPE) in the form of a mask or face covering is recommended for adults. It is also recommended for children over the age of 2 years old, particularly for individuals 6 years of age and older. PPE must be put on outdoors or while physically distancing, and replaced after each visit. When interacting with individuals without a mask or face covering, additional protections such as eye protection are required for adults only.

Cancellation Policy Clarification

In light of Public Health recommendations that may result in an increased number of cancelled sessions, it is also important to review our 24-hour cancellation policy. For one-to-one sessions (as stated in the One-to-One Registration Form) …

• In the event of a cancellation, I must notify the ABA Therapist(s), Senior Therapist, and Clinical Supervisor. Sessions cancelled twenty-four (24) hours in advance will not be billed. Cancelled sessions can be rescheduled at the discretion of the Parent/Guardian and Therapist, but it is not required.

• Sessions cancelled within twenty-four (24) hours notice will be billed in full, as a Late Parent Cancellation. If possible, these hours will be used to benefit the learner’s programming.

• If the learner is sick and the session is not cancelled, the Therapist may cancel upon arrival or end session early at their discretion, and it will be considered a Late Parent Cancellation.

• If the Therapist cancels a session for any reason, all parties will be notified as soon as possible. If the session cannot be covered by another team member, the session will be cancelled and will not be billed. Cancelled sessions can be rescheduled at the discretion of the Parent/Guardian and Therapist, but it is not required.

Team members, please record the date/time you received notification of a cancelled session when tagging it as a Late Parent Cancellation on Clockify, in the description.

This applies to the first instance of a cancellation, not subsequent cancellations. For example, if SC is exhibiting symptoms and the self-assessment indicates that sessions will need to be cancelled until the learner is symptom free for 24 hours, that first cancelled session may be billed in full if it was cancelled less than 24 hours before the expected start of session. However, it is understood that all subsequent sessions are cancelled until further notice, so there would be no ‘Late Parent Cancellation’ charges for subsequent sessions. In this example, a parent would notify their therapy team when the learner has been symptom free for 24 hours and sessions would resume at the therapists’ earliest available start date.

Financial Benefit Programs

There are many financial benefit programs available to help families and workers facing hardship as a result of the COVID-19 pandemic. These programs include benefits geared towards caregivers, employees, and independent contractors, who may be required to stay home and self-isolate or who experience a significant drop in income due to someone else’s self-isolation.

Here is a list of the most up-to-date financial benefit programs.

Employees were eligible for the Ontario COVID-19 Worker Income Protection Benefit, however this program ended as of April 1, 2023.

Updated: September 12, 2023

Best Behaviour Inc. follows a conflict resolution process to address conflicts that arise. This policy applies to both team members and parents/caregivers. Having a policy ensures that all stakeholders know what is expected and that they are treated fairly in the event of a conflict.

Raising a Concern

• Should a team member or parent/caregiver have a concern or experience a conflict, they are encouraged to communicate that concern directly to a supervisor. Communication may occur in-person, over the phone, or via email.

Conflict Resolution Process

• The supervisor will initiate the conflict resolution process outlined below. Please note that Best Behaviour Inc. reserves the right to combine or skip steps, depending on the situation.

1.     Data Collection

• The supervisor will provide acknowledgement of the problem to the person who raised the concern within 5 days of it being raised.

• At this time, the supervisor will fill out a Conflict Resolution Log to note the primary concern and begin the data collection process.

• Subsequent behaviours/incidents related to the original behaviour/incident that warranted the conflict resolution process will be monitored and recorded. 

2.     First Warning

• At any point during the initial reporting or data collection phase, a first warning may be given as an acknowledgement of the problem to the individual.

• The supervisor will discuss with them the nature of the problem or how their behaviour was in conflict with company policies, procedures and/or values. The supervisor will clearly describe the expectations and the steps the individual must take to improve their performance or resolve the problem.

• Subsequent behaviours/incidents related to the original behaviour/incident that warranted the conflict resolution process will be monitored and recorded. 

3.     Second Warning

• Should the problem continue, the supervisor may provide a second verbal warning.

• The supervisor will re-describe the expectations and the steps the individual must take to improve their performance or resolve the problem, and notify their supervisor(s) for additional support as needed.

• Subsequent behaviours/incidents related to the original behaviour/incident that warranted the conflict resolution process will be monitored and recorded.

4.     Final Written Warning

• If the problem continues after 2 warnings, the supervisor will provide a third verbal warning.

• The supervisor will re-describe the expectations and the steps the individual must take to improve their performance or resolve the problem.

• Notify the individual that they will be provided with a final written warning, and that failure to improve performance or resolve the problem may result in termination.

• Subsequent behaviours/incidents related to the original behaviour/incident that warranted the conflict resolution process will be monitored and recorded.

5.     Termination

• This step is taken when all others have been exhausted.

• The supervisor will meet with the Director to review all of the documentation related to the problem. The Director will outline the steps that will be taken should termination be required.

Documenting Conflict Resolution

• Supervisors will document each step in the conflict resolution process using the Conflict Resolution Log.

• This document will be kept in the individual’s team member or client file.

• When an individual is named in a Conflict Resolution Log, they must be informed of the conflict that involves them (starting with Step 2), what stage in the conflict resolution process they are in, the consequences of further conflict, and the actions they can take to resolve it.

Behaviours Warranting Conflict Resolution for Team Members

Behaviours that warrant conflict resolution may include, but are not limited to, the following:

• Failure to perform roles and responsibilities outlined in one’s job description

• Dress code violations

• Inappropriate behaviour with co-workers or clients

• Attendance issues/frequent cancellations

• Discrimination

• Theft of physical and/or intellectual property

• Theft of clients or staff

• Complaints filed by other co-workers or clients

• Complaints regarding company policies/procedures

Behaviours Warranting Conflict Resolution for Parents/Caregivers 

Behaviours that warrant conflict resolution may include, but are not limited to, the following:

• Inability to provide the supports and/or resources needed to work towards important goals

• Inappropriate behaviour with therapists

• Attendance issues/frequent cancellations

• Discrimination

• Theft of physical and/or intellectual property

• Theft of staff

• Complaints filed by therapists

• Complaints regarding company policies/procedures

Appeals Process

Individuals have the right to present evidence to refute the information that was used as the basis for the conflict. The supervisor will evaluate the evidence presented and decide on next steps.

Questions or Concerns

• Best Behaviour Inc. welcomes feedback on the Conflict Resolution Policy. Sophia would be happy to discuss any concerns about this policy. She can be reached at (226) 755-0015 or sophiacatania@bestbehaviour.ca.

Updated: April 2024

Best Behaviour Inc. is committed to protecting personal information and keeping it safe. The following policies and procedures have been introduced to ensure personal information is handled with care and kept private, according to the rules and regulations enacted in the Province of Ontario and within the professional field of Applied Behaviour Analysis(“ABA”). Current legislation that applies to Best Behaviour Inc. includes the Child and Family Services Act, 1990 (“CFSA”), Healthcare Consent Act (“HCA”), Municipal Freedom of Information and Protection of Privacy Act, 1990 (“MFIPPA”), Personal Health Information Protection Act, 2004 (“PHIPA”), Protection of Personal Information and Electronic Documents Act (“PIPEDA”), and the Professional and Ethical Compliance Code for Behavior Analysts.

Definition of Personal Information

• Personal Information is defined as any information about an identifiable individual. This includes, but is not limited to, personal characteristics (e.g. name, home address, home phone number, age, marital status, ethnic background, education level), health information (e.g. medical history and conditions, health services received), and activities/views (e.g. community involvements, religious affiliations).

• Personal Information does not include business information (e.g. business phone number, business address). Business information is not protected by privacy legislation.

Definition of Consent and Assent

• Consent is the voluntary agreement of an individual, or his or her authorized representative, who has the legal capacity to give consent and exercise free power of choice, without undue inducement or any other form of constraint or coercion to participate in treatment. The individual must have sufficient knowledge and understanding of the nature of the proposed treatment, the anticipated risks and potential benefits, and the requirements of the treatment to be able to make an informed decision.

  • It is important to note that the age of majority in Ontario is eighteen (18) years of age. Written or verbal consent from a parent/guardian is required for individuals under the age of eighteen (18). Individuals over the age of eighteen (18) may provide and revoke their own consent if deemed capable of consenting.

• Assent is a term used to describe an individual’s willingness to participate in treatment by persons who are by definition too young to give consent but who are old enough to understanding of the nature of the proposed treatment, the anticipated risks and potential benefits, and the requirements of the treatment, to be able to make an informed decision.

  • Minors may be provided with written information regarding the nature of the proposed treatment, the anticipated risks and potential benefits, and the requirements of the treatment, to be able to make an informed decision when assenting. A simple verbal explanation may also be given with reassurances that they do not have to agree if they do not want to. This verbal assent discussion will be documented and retained. Minors are not required to write their name on an official document, rather that the person obtaining assent will note that a discussion occurred, what was discussed, whether the minor agreed to participate, and the date on which the discussion occurred.

 Collection and Use of Personal Information

• Best Behaviour Inc. only collects and uses personal information deemed necessary to provide services. This information is needed to develop an individualized, effective treatment plan for the learner, as well as to maintain accurate client and team member files. Personal information is also collected to invoice for services rendered and to share relevant information and discuss the learner’s therapy with person(s) where written or verbal consent has been obtained.

• Personal information can only be collected with written or verbal consent, with the following exceptions:

  1. It is believed that consent would be provided but it is not practical to obtain consent

  2. The law requires the collection or use of information in an emergency situation

• Consent may be revoked at any time.

• Personal information is not collected at www.bestbehaviour.ca and cookies are not used. Personal information is not collected for the purpose of sending mail-outs about services.

• Each learner will have a consent form in their Google Drive file (in the form of a Google Doc) or in their Jane Account. This working document allows written consent to be collected and updated regularly by any member of the learner’s therapy team.

Disclosure of Personal Information

• When a learner enters service at Best Behaviour Inc., they will receive a Google Drive folder in our Google Workspace or a Jane Account. These will be shared with at least one Parent/Guardian (if applicable), the learner (if applicable), and members of the learner’s therapy team. Each file is also automatically shared with the Clinical Director, and admin staff. To ensure you can easily access the learner’s folder, save this as a shortcut to your Drive.

• Personal information will also be shared with the bookkeeper and accountant at Best Behaviour Inc. as needed.

• Personal information will not be shared without written or verbal consent, with the following exceptions:

  1. An individual expresses intent to seriously harm themselves or others

  2. An individual shares information about a child, currently under the age of sixteen (16), who has been abused or neglected, or is at risk of being abused or neglected

  3. An individual indicates that they or a child has been sexually abused by a Regulated Health Professional

  4. A court of law subpoenas files that contain personal information

  5. Various government agencies (e.g. Office of the Privacy Commissioner, Canada Revenue Agency, Canadian Human Rights Commission, Ontario Autism Program) require information or conduct an interview as part of their mandate

• Individuals are encouraged to raise concerns that meet these exceptions to Sophia Catania for assistance and direction on how to proceed.

• It is also important to note that therapy is most effective when a trusting relationship exists between the therapist and learner. Privacy is especially important in securing and maintaining that trust. It is necessary for the learner to establish a 'zone of privacy' with their therapist that allows them to feel free to discuss personal matters. To achieve this, confidentiality is ensured between the learner and therapist unless otherwise discussed with the learner or in the case of circumstances described above.

Protection of Personal Information

• The following safeguards have been put in place to ensure every attempt to protect personal information is being made:

  1. Paper information is under supervision when in use, or stored in locked or restricted areas. The current storage location is 15 Willow Street. Sophia Catania is the only team member with keyed access. If transmitted through Canada Post or Purolator, envelopes are sealed and marked confidential. Paper information stored by individual clinicians in the community will follow the same storage requirements.

  2. Electronic hardware and storage (e.g. computers, cell phones, tablets, hard drives, cloud storage) are under supervision or stored in locked or restricted areas, and password protected. Electronic communication is accompanied by a privacy clause and includes minimal identifiable information when possible.

  3. Virtual sessions are run using only secure platforms. Google Meet and Jane are the platforms of choice, however any platform that is compliant with the Health Insurance Portability and Accountability Act ("HIPAA") is acceptable.

Retention of Personal Information

• Best Behaviour Inc. is required to retain personal information for reasons that include, but are not limited to:

  • Using older files to review treatment progress over time

  • Answering questions about services received in the past, when services are currently being provided or services have been discontinued

  • Remaining accountable to various government agencies and the BACB

  • Security monitoring (e.g. Ring security system at 15 Willow Street)

• It is considered best practice to retain records for a minimum of seven (7) years after the date of last contact. In order to protect privacy, files are not kept beyond seven (7) years, except in circumstances where abuse has been alleged or substantiated. These files are kept indefinitely.

  • ABA program binders (which include reports, session notes, programs, data sheets, graphs etc.) will remain the property of the Parent/Guardian after the last invoice is paid. Program binders must be stored for at least seven (7) years following the termination of therapy. All programs are the intellectual property of Best Behaviour Inc. and can be used by other service providers for reference only. Programs cannot be used to continue therapy with other service providers or learners, and cannot be copied or sold.

• In the unlikely event that Best Behaviour Inc. becomes unable to practice, personal information will be placed in the care of another professional or the original owner for protection and retention only.

• Best Behaviour Inc. discontinued retention of personal information in paper format, effective January 1, 2022. At this time, electronic hardware and cloud storage will be used to retain all personal information. The purpose of this change is to facilitate easier access to personal information for clients and team members. All paper files will be updated to December 31, 2021.

Destruction of Personal Information

• Best Behaviour Inc. destroys paper files containing personal information by destroying them beyond recognition (e.g. shredding or ripping up).

• Electronic files are deleted, or electronic hardware is physically destroyed if needed.

Access to Personal Information

• When a learner enters service at Best Behaviour Inc., they will receive a Google Drive folder in our Google Workspace or a Jane Account. These will be shared with at least one Parent/Guardian (if applicable), the learner (if applicable), and members of the learner’s therapy team. Each file is also automatically shared with the Clinical Director, and admin staff. To ensure you can easily access the learner’s folder, save this as a shortcut to your Drive.

• Personal information will also be shared with bookkeeper and accountant at Best Behaviour Inc. as needed.

• Owners of personal information being stored by Best Behaviour Inc. are permitted to view and/or make copies of their information, unless the information could potentially inflict harm.

• Owners may be asked to put their request for personal information in writing. If Best Behaviour Inc. cannot comply with the request, notification will be provided within thirty (30) days. There will be a charge of twenty-five (25) cents per page for paper copies.

• In the unlikely event that personal information is compromised (collected, used, disclosed, retained or destroyed in a manner inconsistent with privacy legislation), Sophia Catania will be notified immediately, as well as the individuals’ whose privacy has been compromised.

Challenges to the Accuracy of Your Personal Information

• Owners of personal information being stored by Best Behaviour Inc. have the right to challenge the accuracy of such information. Owners may be asked to put their request in writing. If Best Behaviour Inc. agrees that a mistake has been made, the mistake will be corrected and a copy of the correction will be sent to individuals who have received the mistaken personal information. If Best Behaviour Inc. does not agree that a mistake has been made, a statement of disagreement may be put in the file and sent to individuals who has received the mistaken personal information.

 Questions or Concerns

• Best Behaviour Inc. welcomes feedback on these Privacy Policies and Procedures. Our Information Officer is Sophia Catania. Sophia would be happy to discuss any concerns about this policy. She can be reached at (226) 755-0015 or sophiacatania@bestbehaviour.ca.

• A formal complaint or inquiry may be submitted in writing to the attention of Sophia Catania. She will acknowledge the complaint/inquiry, investigate it promptly, and send notification in writing of the outcome of the decision and the reasons behind the decision. If the notification does not satisfy the complaint, a complaint may be sent to either 1) the Privacy Commissioner of Canada or 2) our regulatory body, the BACB. Contact information is as follows:

1. Office of the Privacy Commissioner of Canada

• 112 Kent Street, Pace de Ville, Tower B, 3rd Floor, Ottawa, Ontario, K1A 1H3

• (613) 947-1698 or (800) 282-1376

• privcom.gc.ca

2. Behaviour Analyst Certification Board

• 7950 Shaffer Parkway, Littleton, Colorado, 80127, USA

• 1-720-438-4321

• bacb.com

Updated: February 2023

Best Behaviour Inc. is committed to meeting its current and ongoing obligations under the Ontario Human Rights Code(“OHRC”) and the Accessibility for Ontarians with Disabilities Act, 2005(“AODA”). Best Behaviour Inc. understands that the AODA does not substitute or limit its obligations under the OHRC or obligations to people with disabilities under any other law.

Best Behaviour Inc. is committed to excellence in serving all clients and team members, including people with disabilities. The following policies are consistent with the principles of independence, dignity, integration, and equal opportunity for people with disabilities.

Assistive Devices

• People with disabilities may use personal assistive devices when accessing or providing services at Best Behaviour Inc. In cases where the assistive device presents a significant and unavoidable health or safety concern or may not be permitted for other reasons, other measures will be used to ensure the person with a disability can access or provide services.

• Best Behaviour Inc. will ensure that team members are trained and familiar with various assistive devices within their place of work.

Communication

• Best Behaviour Inc. will communicate with people with disabilities in ways that consider their disability, and work collaboratively to determine what method of communication works for them.

Service Animals

• Best Behaviour Inc. welcomes people with disabilities and their service animals. Service animals are allowed in places of work that are open to the public.

• A service animal can be identified through visual indicators, such as wearing a harness or vest, or helping the person perform certain tasks for reasons relating to their disability. If an animal is not easily identified as a service animal, Best Behaviour Inc. may ask the person with a disability to provide documentation from a regulated health professional. A regulated health professional is defined as a member of one of the following colleges: College of Audiologists and Speech-Language Pathologists of Ontario, College of Chiropractors of Ontario, College of Nurses of Ontario, College of Occupational Therapists of Ontario, College of Optometrists of Ontario, College of Physicians and Surgeons of Ontario, College of Physiotherapists of Ontario, College of Psychologists of Ontario, College of Registered Psychotherapists, and Registered Mental Health Therapists of Ontario.

• If service animals are prohibited by another law, or due to other environmental constraints, Best Behaviour Inc. will explain why the animal is excluded and discuss with the person another way of accessing or providing services.

Support Persons

• A person with a disability who is accompanied by a support person will be allowed to have that person accompany them to the place of work. Fee/fare will not be charged for support persons.

• In certain cases, Best Behaviour Inc. may require a person with a disability to be accompanied by a support person for the health or safety of the person with a disability or others. Before deciding, Best Behaviour Inc. will consult with the person with a disability to understand their needs, consider the health or safety reasons based on available evidence, and determine if there is no other reasonable way to protect the health or safety of the person or others.

Notice of Temporary Disruption

• In the event of a planned or unexpected disruption to services for persons with disabilities, Best Behaviour Inc. will notify the affected individual(s) promptly. This clearly posted notice will include information about the reason for the disruption, its anticipated length of time, and a description of alternative arrangements if available. The notice will be distributed electronically, and via paper copies upon request, to the affected individual(s).

Training

• Best Behaviour Inc. will provide accessible service training to all team members, anyone involved in developing policies, and anyone who provides services or facilities to clients and team members on Best Behaviour’s behalf. Training on accessible service will be provided for those entering into any contractual agreement. Training will include the purpose of the AODA, service standards, policies related to service standards at Best Behaviour Inc., how to interact and communicate with people with various types of disabilities, how to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person, how to use the equipment or devices available that may help with providing services to people with disabilities, and what to do if a person with a disability is having difficulty in accessing services at Best Behaviour Inc. Training will also be provided when changes are made to accessible service policies.

Notice of Availability of Documents

• Best Behaviour Inc. will notify the public that documents related to accessible service are available upon request by posting a notice at www.bestbehaviour.ca. Documents will be made available electronically, and via paper copies upon request. Best Behaviour Inc. will provide this document in an accessible format or with communication support upon request. The person making the request will be consulted to determine the suitability of the format or communication support. The accessible format will be provided in a timely manner, at no additional cost.

Modifications to This or Other Accessibility Policies

• Policies at Best Behaviour Inc. that do not respect and promote the principles of dignity, independence, integration, and equal opportunity for people with disabilities will be modified or removed.

Questions or Concerns

• Best Behaviour Inc. welcomes feedback on these Accessibility Policies and Procedures. Our Accessibility Officer is Sophia Catania. Sophia would be happy to discuss any concerns about this policy. She can be reached at (226) 755-0015 or sophiacatania@bestbehaviour.ca.

• A formal complaint or inquiry may be submitted in writing to the attention of Sophia Catania. She will acknowledge the complaint/inquiry, investigate it promptly, and send notification in writing of the outcome of the decision and the reasons behind the decision. If the notification does not satisfy the complaint, a complaint may be sent to the Government of Ontario. Contact information is as follows:

1. Government of Ontario

• 1-866-515-2025 or by TTY: 1-800-268-7095

Updated: November 2021

1. Terms

By accessing this website, you are agreeing to be bound by these terms of service, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws. If you do not agree with any of these terms, you are prohibited from using or accessing this site. The materials contained in this website are protected by applicable copyright and trademark law.

2. Use License

Permission is granted to temporarily download one copy of the materials (information or software) on Best Behaviour Inc.'s website for personal, non-commercial transitory viewing only. This is the grant of a license, not a transfer of title, and under this license you may not: modify or copy the materials, use the materials for any commercial purpose, or for any public display (commercial or non-commercial), attempt to decompile or reverse engineer any software contained on Best Behaviour Inc.'s website, remove any copyright or other proprietary notations from the materials, transfer the materials to another person or "mirror" the materials on any other server. This license shall automatically terminate if you violate any of these restrictions and may be terminated by Best Behaviour Inc. at any time. Upon terminating your viewing of these materials or upon the termination of this license, you must destroy any downloaded materials in your possession whether in electronic or printed format.

3. Disclaimer

The materials on Best Behaviour Inc.'s website are provided on an 'as is' basis. Best Behaviour Inc. makes no warranties, expressed or implied, and hereby disclaims and negates all other warranties including, without limitation, implied warranties or conditions of merchantability, fitness for a particular purpose, or non-infringement of intellectual property or other violation of rights. Further, Best Behaviour Inc. does not warrant or make any representations concerning the accuracy, likely results, or reliability of the use of the materials on its website or otherwise relating to such materials or on any sites linked to this site.

4. Limitations

In no event shall Best Behaviour Inc. or its suppliers be liable for any damages (including, without limitation, damages for loss of data or profit, or due to business interruption) arising out of the use or inability to use the materials on Best Behaviour Inc.'s website, even if Best Behaviour Inc. or a Best Behaviour Inc. authorized representative has been notified orally or in writing of the possibility of such damage. Because some jurisdictions do not allow limitations on implied warranties, or limitations of liability for consequential or incidental damages, these limitations may not apply to you.

5. Accuracy of Materials

The materials appearing on Best Behaviour Inc.'s website could include technical, typographical, or photographic errors. Best Behaviour Inc. does not warrant that any of the materials on its website are accurate, complete or current. Best Behaviour Inc. may make changes to the materials contained on its website at any time without notice. However, Best Behaviour Inc. does not make any commitment to update the materials.

6. Links

Best Behaviour Inc. has not reviewed all of the sites linked to its website and is not responsible for the contents of any such linked site. The inclusion of any link does not imply endorsement by Best Behaviour Inc. of the site. Use of any such linked website is at the user's own risk.

7. Modifications

Best Behaviour Inc. may revise these terms of service for its website at any time without notice. By using this website you are agreeing to be bound by the then current version of these terms of service.

8. Governing Law

These terms and conditions are governed by and construed in accordance with the laws of Ontario and you irrevocably submit to the exclusive jurisdiction of the courts in that State or location.

Updated: November 2021

Best Behaviour Inc. is committed to meeting its current and ongoing obligations under the Employment Standards Act (“ESA”) and the Occupational Health and Safety Act (“OHSA”). Best Behaviour Inc. values the health and well-being of its employees, by providing a supportive workplace that promotes and supports stress-reduction and mental health. Best Behaviour Inc. encourages a healthy work-life balance, including the fair and consistent accrual and usage of paid vacation time, and the freedom to disconnect from work.

This Vacation and Right to Disconnect Policy applies to all employees of Best Behaviour Inc.

Definitions

• Employee: Any person working for Best Behaviour Inc. who has signed an Employment Agreement.

• Vacation pay: Paid out each pay period, as a percentage of hours worked (as defined by the ESA). For example, at least four per cent of the gross wages (excluding any vacation pay) earned in the 12-month vacation entitlement year or stub period (where that applies) for employees with less than five years of employment.

• Working hours or work time: It is understood that employees may have different working hours depending on their position and caseload at Best Behaviour Inc. Working hours are determined by the employee and their supervisor, and/or as outlined in their Employment Agreement. Standard working hours are available at https://www.bestbehaviour.ca/contact-us, however, due to the nature of our services, these may vary based on individual client needs.

• Time off: Time in which the employee is not on work time, or has disconnected from work.

• Disconnecting from work: Not engaging in work-related tasks or communications (including emails, telephone calls, video calls or sending or reviewing other messages), and to be free from the performance of work.

• Remote work: Time in which the employee is working from a location that is far enough away from their home that they would not be available for in-person work during this time. This may include working from home if one's ability to work in-person as needed is restricted. This does not include when an employee is working from their home, the centre, or from any other location that still allows them to complete any required in-person work as needed.

Employee Responsibilities

• Employees are expected to follow the guidelines outlined in this policy.

• Employees are expected to respect the working hours of fellow employees, and will not penalize them for communications (or lack thereof) outside of those hours.

• Employees are expected to speak to their supervisor if they have concerns about their mental health, right to time off, or ability to disconnect from work. Supervisors are expected to listen and provide support.

• Employees understand that occasionally working outside of working hours is necessary.

Requesting Time Off and Remote Work

• To ensure that the guidelines in this policy are not compromised, Best Behaviour Inc. needs to be aware of when employees are on work time and when they are not.

• Employees are expected to regularly update their Google Calendar with times they will out of office or unavailable, and log their work time accurately so it reflects this time off.

• Employees are expected to submit a request (via a Google Form) when requesting time off or remote work, in the amount of 1 day or more.

• Before completing this form, the employee must ensure their supervisor(s) have been notified and any required coverage has been discussed. At least 2 weeks' notice is also required, to allow for the request to be reviewed, denied or approved, and any necessary coverage to be arranged if applicable.

• Best Behaviour Inc. will make every effort to ensure time off and remote work requests are approved. In the event that there are a high number of overlapping requests, the first employee to request may get the time off (first come, first served). Other factors may also be considered, such as the reason for the request, each employee's prior request history, and seniority.

• Other reasons that may warrant a denied time off request may be that the request goes against company policy, the employee's absence will have a negative impact Best Behaviour Inc. clients or team members, the length of the time off request is particularly long, or not enough notice has been provided.

• Once a request has been approved, the employee will ensure all parties affected are notified and any necessary coverage is arranged.

• Any conflicts resulting in an employee’s work time not aligning with the service needs of Best Behaviour Inc. clients or team members will be discussed between the employee and their supervisor.

Email

• Employees are expected to respond to emails during their working hours. Best Behaviour Inc. does not expect employees to respond to emails outside of those hours, and employees will not be penalized for emails (or lack thereof) outside of those hours.

• Outside of working hours, employees are expected to check their emails every 24 hours for any time-sensitive communications. This frequency may need to increase or decrease, depending on the employee’s position and caseload at Best Behaviour Inc, the time of day/week/year, and what kind of coverage has been arranged for the employee during their time out of office.

• Responding to time-sensitive emails outside of working hours is necessary.

Phone

• Employees are expected to respond to phone calls and text messages during their working hours. Best Behaviour Inc. does not expect employees to respond to phone calls or text messages outside of those hours, and employees will not be penalized for calls/texts (or lack thereof) outside of those hours.

• Outside of working hours, employees are expected to check their voicemail every 24 hours for any time-sensitive communications. This frequency may need to increase or decrease, depending on the employee’s position and caseload at Best Behaviour Inc, the time of day/week/year, and what kind of coverage has been arranged for the employee during their time out of office.

• Responding to time-sensitive phone calls and text messages outside of working hours is necessary.

Questions or Concerns

• Best Behaviour Inc. welcomes feedback on the Vacation and Right to Disconnect Policy. Sophia would be happy to discuss any concerns about this policy. She can be reached at (226) 755-0015 or sophiacatania@bestbehaviour.ca.

Updated: April 2024

Best Behaviour Inc. provides what is referred to as 'scramble parking'. It applies when there are fewer parking spots than there are team members wishing to use a spot. It also ensures employees do not have any tax liability, given that the CRA considers parking to be a taxable benefit.

Best Behaviour Inc. leases parking spots from St. John's Church (22 Willow St) and has space for 4 cars in the driveway. Parking is provided on a first come first serve basis, however priority is given to those who work at the centre full time.

• The information re: the leased parking spots at St. John's Church is shared with members of the centre team. In order to park there, you must have a valid parking permit issued by St. John's or park in one of our assigned spots.

• As you park in the driveway, please start at the far-right side and fill the parking spaces from right to left to ensure that everyone fits.

If you are unable to get a parking space in the driveway, you are responsible for finding parking elsewhere. There is no visitor parking on site, or on Willow Street. Parking is available in various Uptown parking lots and on some city streets as per signage indicated. The City Centre Lot is the closest.

Drop offs and pick-ups for sessions can happen in the spots at the end of the driveway (behind therapists’ parked cars), on Willow Street, or in nearby city lots.

This Scramble Parking Policy applies to all team members at Best Behaviour Inc. 

Questions or Concerns

• Best Behaviour Inc. welcomes feedback on the Scramble Parking Policy. Sophia would be happy to discuss any concerns about this policy. She can be reached at (226) 755-0015 or sophiacatania@bestbehaviour.ca.

Updated: November 2022