Pelmorex Accessibility Plan 2023-2026
June 1, 2023
Contents
1.1. Provide feedback request an alternative format or contact us
1.2. Accessibility Summary
1.3. Introduction
2.1. Employee feedback
2.2. Customer feedback
2.3. Consultation by Optimal Performance Consultants Inc.
3.1. Employment
3.2. The Built Environment
3.3. Information and Communication Technologies
3.4. Communication, Other than ICT
3.5. The Procurement of Goods, Services and Facilities
3.6. The design and delivery of programs and services (Website and Apps)
3.7. Transportation
3.8. Licence Conditions and Requirements Under the Broadcasting Act
1. General
1.1 Provide feedback request an alternative format or contact us
Pelmorex’s Director, Regulatory, Government and Affiliate Relations is responsible for receiving feedback on accessibility barriers and helping to ensure such barriers can be addressed.
If you have a disability or impairment and are experiencing difficulty accessing or enjoying our services as a result, you can contact us by mail, phone or email as indicated below.
Mail:
Attn: Accessibility Coordinator
Pelmorex Corp.
2655 Bristol Circle
Oakville, ON L6H 7W1
Telephone:
905-829-1159 extension # 1329
Email:
If you include your name in your email, name and phone number in a voicemail, or a return address or other contact information with a posted letter we will acknowledge that we have received your feedback. Any personal information that you provide will only be used to address the issue for which you contacted us and once the issue is resolved your personal information will be deleted.
If you prefer to remain anonymous, simply do not include your name in your email, phone number in a voicemail or any contact information in a posted letter and we will not contact you. All personal information will be kept confidential unless you authorize us to share it with others.
1.2 Accessibility Summary
We are pleased to introduce Pelmorex’s Accessibility Plan for 2023-2025, which sets out a focused and committed roadmap to ensure Pelmorex as an organization is constantly identifying and removing any barriers that may prevent:
- our current or future employees from maximizing their potential; our customers from fully enjoying and benefiting from our weather and entertainment services; and our visitors and partners from being fully accommodated when visiting our facility or engaging with our business.
Pelmorex understands that equity means more than treating persons in the same way, but rather that all people should be provided the measures and accommodation they require in order to participate equally, whether as a customer, employee, visitor or client. With that in mind, we undertook a variety of internal and external consultations with persons with disabilities to ensure that barriers of all varieties were identified and we could develop action plans to remove these barriers going forward. These consultations represent a renewed commitment to soliciting and accepting feedback and recommendations from our employees, customers and accessibility professionals.
This accessibility plan is guided by and conforms to the requirements of both the federal Accessible Canada Act (hereinafter “ACA”), and the provincial Accessibility for Ontarians with Disabilities Act (hereinafter “AODA”). Progress reports will be provided annually and the plan will be updated every three years.
We believe we have developed a strong foundation to addressing existing barriers and to establishing an accessibility-first process for all new initiatives. We are proud of our historical commitment to accessibility and accommodation, but recognize that, as with everything, there is always opportunity to improve and strive for excellence.
1.3 Introduction
Pelmorex Corp., founded in 1989, is an international weather information, and data management company. Pelmorex owns and operates the weather brands The Weather Network, MétéoMédia, Eltiempo.es, Clima, and Otempo.pt. It also operates Canada’s National Alert Aggregation and Dissemination System, part of Alert Ready. Through constant innovation and entrepreneurship, Pelmorex has grown to reach consumers around the globe, has become one of the world’s largest weather information providers and has broken new ground in providing data solutions and insights to businesses. Through harnessing the value of weather, Pelmorex is driven to make the world smarter and safer for consumers and businesses.
Pelmorex reaches more than 60 million people per month, worldwide, with its critical weather and warnings services on television, Web and apps, and is committed to ensuring everyone can access and enjoy our services equitably. In 2020, Pelmorex renewed and strengthened its commitment to diversity, equity and inclusion by forming what would eventually become its IDEAS (Inclusion, Diversity, Equity, Awareness and Solidarity) Community. This initiative is led by a full-time IDEAS Operations lead, a core 13-member committee, and five pillar teams, and has spearheaded internal and external initiatives aimed at providing a space where all employees can bring their full selves to the workplace. Among the training initiatives, we have undertaken to provide our Talent Acquisition team and Hiring Managers with bias training to better understand and overcome biases as they pertain to outreach, recruitment, interviewing and assessing candidates. This accessibility plan will also be fully integrated into the future work of our IDEAS Community.
2. Consultations
Pelmorex tries at all times to maintain an open dialogue with its employees about all aspects of their employment experience, including barriers and accessibility. We also communicate regularly with our viewers, and web and app users, through customer service to better understand barriers they may be facing. That said, we have taken additional targeted steps with our employees, customers, and through a third-party inclusion and human factors design firm to fully understand what barriers may be experienced by those who engage with Pelmorex.
2.1 Employee feedback
Pelmorex constantly gathers feedback from its entire staff through Pulse surveys, which can seek feedback on the company overall, as well as from certain departments or on specific initiatives. Since launching our IDEAS Community we have conducted two IDEAS Pulse Surveys, with the most recent one taking place in January 2023. This survey is designed to collect information and sentiment from our employees on all of our DEI efforts, which includes gauging comfort levels around having open conversation with managers, bringing our whole selves to work, feeling valued as well as sentiment around diversity and representation within teams/departments.
2.2 Customer feedback
While Pelmorex has always welcomed feedback from its customers, it launched its Accessibility Feedback[1] Process in May 2022 to establish and provide a specific location and process to provide feedback and receive – if desired – a response regarding barriers to enjoying our services.
Since then, we have received roughly 10 comments from customers experiencing barriers to using and enjoying our services, including the colour scheme of our website, accessing the closed captioning on our online videos, the described video forecast included with their The Weather Network television service, and how to interpret various symbols used in our digital forecast products. Although we have received a small number of complaints, they have been instrumental in helping to immediately address these barriers or to prioritize their removal in our multi-year plan.
As our ultimate goal is to serve our Canadian customers it is critical that we receive targeted feedback from them directly about any barriers they are experiencing. But more than that, as our television services are distributed by a variety of cable and satellite providers we rely solely on customer feedback to know whether customers are in fact receiving the tools like the described video local forecast product that we make available to our affiliates.
2.3 Consultation by Optimal Performance Consultants Inc.
Pelmorex engaged Optimal Performance Consultants (OPC) Inc.[2], a National Inclusion and Human Factors Design firm, to conduct an accessibility audit of Pelmorex’s products, service and processes as they relate to the principles of the ACA and the AODA, and as they relate to the priority areas defined by the ACA. This audit included a review of Pelmorex’s products and services as well as consultations with Pelmorex staff. The consultation findings and recommendations helped to put the principles of the ACA into action and ensure that Pelmorex is in compliance with the AODA, including the laws and regulations, policies, programs, committees, services, and strategies to ensure at all levels of the organization, both people with disabilities and people who are ageing are taken into account no matter the function or service.
Serving clients since 1991, OPC specializes in optimizing human performance in the workplace by applying the science of ergonomics and human factors design to the workplace. OPC employees, auditors and consultants all have lived-experience, as well as having expertise in accessibility policy, strategy and performance. OPC assisted Pelmorex with its consultations with its employees, senior level executives and managers, as well as with external stakeholders by reviewing feedback received through Pelmorex’s Accessibility Feedback Process. The consultations and audit helped identify recent past, current and potential future accessibility barriers and to build this Accessibility Plan to not only remove those barriers but to move Pelmorex towards weaving inclusion of people with disabilities and age into all aspects of the business.
OPC had previously been engaged by Pelmorex to conduct return to work accommodations and ergonomic assessment and was able to leverage this prior relationship as part of its overall accessibility audit. For the audit, OPC initially asked Pelmorex’s relevant departments about their perception of past and current accessibility barriers as well as opportunities to remove those barriers. OPC further requested its auditors to listen to, watch, and interact with Pelmorex television programming and digital products to understand what these interactions are like for them. The auditors have a range of disabilities from age related disabilities to deafened, blind, motor/movement related disorders, which provided practical and expert accessibility knowledge.
All aspects of the consultation and audit informed the development of Pelmorex’s accessibility plan and the prioritization of actions to remove barriers and work towards a barrier-free operation. The final plan was also reviewed and approved by OPC’s team of accessibility experts. The findings and planned actions by priority area identified in the ACA are presented below.
3. Areas of Accessibility
This section describes the barriers identified and the planned actions to eliminate these barriers in the six areas of accessibility defined in the ACA, as well as for Pelmorex as a broadcasting licensee. The planned actions will be categorized as being prioritized for year one, two or three of this three-year plan.
The work to identify barriers across these many areas of accessibility, and across Pelmorex’s many areas of business, made clear the frequent interdependence of various Pelmorex departments to removing such barriers. For example, while the People Operations (HR) department is often the front line for assessing a need for accommodation, actioning that accommodation could – and is likely to – involve a variety of other departments such as facilities, IT, finance and procurement. As well, the communications department plays a role to ensure Pelmorex employees know the policies and processes in place to ensure equitable accommodation.
Accessibility Committee
Although all departments at Pelmorex are committed to removing barriers and being fully accessible, they cannot operate in isolation if this goal is to be accomplished company-wide. To address this interdependence and need for collaboration, Pelmorex established a new Accessibility Committee, which induces senior level representatives from key departments, including: Regulatory; Video, Editorial and Alerting; People Operations; Legal; Product and Marketing; Communications; and Technology. This Accessibility Committee formally kicked off with a workshop with OPC on March 2, 2023 and will be responsible for maintaining progress on the plan below.
3.1 Employment
Pelmorex’s People Operations team plays a pivotal role in ensuring accessibility at Pelmorex. People Operations is the first point of contact for virtually all prospective employees and retains responsibility for ensuring accessibility is embedded in the recruitment, hiring, onboarding, employment and retention processes. Developing and spearheading most internal and external-facing candidate and employee accessibility policies and programs, and implementing those policies with the help of other departments, is the responsibility of People Operations. Identifying and removing employment-related barriers and ensuring that all current and future employees have the same opportunities, regardless of their disabilities, is therefore a critical component of integrating accessibility into all aspects of Pelmorex’s business.
Barriers and opportunities
While Pelmorex has worked to ensure any employment-related barriers are or can be removed, examining current practices through the lens of accessibility professionals and persons with disabilities highlighted areas where barriers were not removed through past efforts and can therefore be improved to further accommodate current and prospective employees. Pelmorex’s “choose your own adventure” flexible remote work policy provides additional opportunities for employees to work without barriers. However, a large remote workforce can also add additional barriers, including those related to video-conferencing quality, meeting scheduling, and the lack of company control over ergonomics.
Currently, Pelmorex employees require more detailed knowledge about accessibility, including the broad scope of disabilities and various potential needs for accommodation, as well as what accommodations are currently available for employees and how an employee would go about accessing an accommodation. Similarly, while accommodations are always provided when asked for, staff do not all, as a rule, proactively ask if accommodations are needed, whether for interviews, meetings, gatherings or everyday work. Pelmorex’s recruitment process is also not barrier free as some external recruitment platforms used by Pelmorex are not fully accessible – and can therefore not be used to apply for a job – by all persons with disabilities. Persons with disabilities are also not currently being actively sought out through targeted recruitment services. Finally, some employees, and possibly some prospective employees, remain reluctant to disclose a disability and/or need for accommodation, which inherently results in ongoing employment barriers.
Action steps
| Action | Planned Completion |
Review and update policies, procedures, practices related to accessibility and accommodation and communicate to all employees.
|
Year One |
| Identify options for employee accessibility and accommodation training that: embeds a broad understanding of persons with disabilities for all staff; is tailored to address the ways accessibility practices affect all of Pelmorex’s internal and external stakeholders; identifies the benefits of creating a fully accessible and inclusive workplace; and that includes a schedule for updates that keeps accessibility and accommodation top of mind. | Year One |
| Implement the accessibility and accommodation training. | Year Two |
| Ensure all staff have received the accessibility and accommodation training. | Year Three |
| Throughout the three-year plan review and assess the impacts of the above measures, including whether more staff are comfortable disclosing a disability and/or need for accommodation. Determine whether the intended barriers have been removed or more measures are required. | Year Three |
3.2 The Built Environment
An accessible built environment is essential to ensure equitable access to and use of Pelmorex’s facilities. Pelmorex’s offices (in Oakville and Montreal) are not open to the public, and do not serve a customer-facing function, but are used by employees and invited visitors, including clients, partners, stakeholders and occasional tour groups. Ultimately, everyone should be able to fully perform their intended activities and functions without facing barriers within our facilities.
Barriers and opportunities
Pelmorex’s Facilities Management has consistently worked to create welcoming and barrier-free premises, including adjustable workstations, large monitors and ergonomic chairs for employees. This work has also included creating an overall inclusive workspace based on the objectives and work of Pelmorex’s IDEAS Community.
The complete audit performed by OPC identified some remaining barriers related to the lack of wayfinding in areas inside and outside of the Pelmorex office, limited accessibility of the entry barriers and doors, the need for more clearly marked accessible parking spaces and the need for more accessible sink/refreshment stations and automatic door openers. Some existing barriers are also non-fixed and are related to employee work-arounds. OPC provided Pelmorex with a complete audit, including photos, of barriers to be addressed in the coming years. In the interim, processes for accommodating facility users should be put in place.
Action steps
| Action | Planned Completion |
| Establish and communicate, internally and to visitors, human processes for accommodating facility users where the existing built environment does not provide full accommodation. | Year One |
| Address all non-fixed barriers and communicate proper accessible procedures to employees. | Year One |
| Add/improve wayfinding inside and outside of the Pelmorex offices where needed. | Year One |
| Ensure at least one accessible sink/refreshment station on each floor of Pelmorex facilities. | Year Two |
| Install and improve existing automatic door openers where needed. | Year Three |
| Work with IDEAS Community to coordinate and develop fully accessible and inclusive spaces within the Pelmorex office. | Year Three |
3.3 Information and Communication Technologies
This section focuses on the use of Information and Communication Technologies within Pelmorex, typically as provided by the IT Department or the Communications Team. Barriers and actions related to our externally-facing Information and Communications Technologies are outlined under the area of accessibility related to the Design and Delivery of Programs and Services. Pelmorex’s IT department is responsible for sourcing for, and providing to, Pelmorex staff the ICT products and services they need, including those that are required to accommodate a disability. As such, it is an important piece of ensuring overall accessibility at Pelmorex.
Barriers and opportunities
The IT department works to accommodate employees’ technical needs as required. The most significant barrier identified by the audit was that this generally ad hoc process has not instilled the institutional knowledge, processes and resources needed to make Pelmorex barrier free. There is therefore an opportunity to develop more concrete resources and knowledge that will more efficiently and effectively accommodate employees with disabilities.
Action Steps
| Action | Planned Completion |
| Develop or acquire – and keep up to date – a catalogue of accessibility functions and assistive technology and promote it to staff. | Year One |
| Identify and train an internal point of contact for support in working with Accessibility, Accommodation, and Adaptive Computer Technology. | Year One |
| Develop a process or procedure for updating PDFs and other documents to accessible versions. | Year Two |
3.4 Communication, Other than ICT
Pelmorex’s Communications team is responsible for internal (staff) and external (customers, viewers, Web and app users) communications and therefore plays an important supporting role in promoting accessibility and accommodation.
Barriers and opportunities
The most direct barrier identified with respect to communications at Pelmorex is a lack of training for customer-facing staff on how to interact and communicate with people with various disabilities. The Communications team has an opportunity to contribute significantly to the removal of barriers by communicating key information to staff and customers, but will rely on other departments to provide the information it needs to then disseminate. The Communications team can also play a lead role in embedding accessibility and accommodation into everyday life at Pelmorex.
Action Steps
| Action | Planned Completion |
| Identify training specific to communicating with people with disabilities. | Year One |
| Provide communication training to any staff who are likely to communicate with people with disabilities as part of their role. | Year Two |
| Working with the IDEAS Community, develop and launch an initiative to embed accessibility and accommodation into everyday life at Pelmorex. | Year One |
| Working with the Accessibility Committee, communicate all new resources and initiatives to Pelmorex staff once available. | Year One
and Ongoing |
3.5 The Procurement of Goods, Services and Facilities
Procurement at Pelmorex takes place on a department-by-department and case-by-case basis, with the Facilities Management, IT and broadcast engineering departments undertaking the majority of procurement annually. Certainly, the goods, services and facilities procured by the organization can have a significant and direct impact on the current level of accessibility and accommodation within Pelmorex.
Barriers and opportunities
As with ICT, the most significant barrier related to procurement at Pelmorex is that the current ad hoc process does not instill the institutional knowledge, processes and resources that will be needed to make Pelmorex barrier free. Also, while budget allocations for accessible products and services tend to be made available when needed, the lack of a fixed accessibility budget means that necessary spending may not be guaranteed each year. That said, centralized and fixed annual budgets for accessibility can be limiting in years where additional spending by multiple departments is required, so any such policy needs to be properly considered and framed. There is therefore an opportunity to establish procedures that will more efficiently and effectively accommodate employees with disabilities. As well, ensuring newly acquired goods and services are accessible can save on potential future spending.
Action Steps
| Action | Planned Completion |
| Investigate and discuss approaches to accessibility procurement budgets. | Year One |
| Develop a procurement checklist to ensure accessibility is considered for all acquired goods and services. | Year One |
| Formalize and implement an approach to accessibility procurement budgets. | Year Two |
| Establish a supplier diversity program. | Year Two |
3.6 The design and delivery of programs and services (Website and Apps)
Pelmorex’s most popular and most used services are its The Weather Network and MétéoMédia websites and mobile and tablet applications, which are the most popular digital weather services in Canada. The reliance on our services for important, and often critical, weather information presents Pelmorex a significant opportunity to reduce barriers in Canada. At the same time, it bestows on us an additional responsibility to serve Canadians equitably.
Barriers and opportunities
Over the past few years Pelmorex has developed user experience (UX) and user interface (UI) accessibility standards for its digital products. These standards are being implemented in a staged process, particularly as The Weather Network and MétéoMédia websites are being updated to a new web format on a section-by-section basis. The OPC useability audit identified a number of useability barriers audit associated with the website, but fortunately these barriers are largely being addressed as during this overall web update. A cross-functional analysis further identified that digital product useability barriers can only be fully addressed for the long term if potential barriers inherent in the underlying software are also uncovered and addressed.
In terms of consumer/user feedback, the most common barrier identified is a perceived lack of closed captioning available with the videos on our websites and apps. As Pelmorex includes captioning for effectively all videos on all platforms, we realize that the barrier relates to how easily captioning can be turned on, regardless of platform. Finally, users and staff have also identified that font size limitations, particularly on the smaller mobile device screen, creates barriers to reading weather forecasts and articles on our services.
Action Steps
| Action | Planned Completion |
| Continue to address website usability barriers through the ongoing website update. Address any additional barriers identified by the OPC audit. | Year One |
| Develop a user guide for accessing the closed captioning on digital videos for all digital properties across all operating systems and browsers. Make available and share with the Communications team. | Year One |
| Research and identify options for a complete accessibility audit and scan of the underlying software of Pelmorex digital properties. | Year One |
| Examine options for increasing the accessibility, particularly font size, of on screen text on Pelmorex apps. | Year One |
| Select a vendor and implement the software audit. | Year Two |
| Resolve barriers/issues identified by the software audit. | Year Two |
3.7 Transportation
Pelmorex does not offer transportation services and therefore has nothing to report for this area of accessibility.
3.8 Licence Conditions and Requirements Under the Broadcasting Act
As a broadcast licensee Pelmorex, via The Weather Network and MétéoMédia discretionary services, is subject to and complies with a variety of conditions of licence and other requirements, expectations and encouragements aimed at removing barriers and ensuring our television services are accessible.
3.8.1 Conditions of licence
The Weather Network and MétéoMédia are subject to the following conditions of licence that assist with removing barriers to its television services:
Audio Description
- The licensee shall provide audio description for all the key elements of information programs, including news programming, with the exception of the local forecasts that are broadcast every ten minutes. For those local forecasts, as a substitute for audio description, the licensee shall provide six secondary audio program (SAP) channels that will broadcast audio of one national and five regional weather overviews during the text segments of its local forecasts. For the purposes of this condition of licence, “audio description” refers to announcers reading aloud the textual and graphic information that is displayed on the screen during information programs.[3]
Closed Captioning
The licensee shall caption 100% of the programs broadcast over the broadcast day, consistent with the approach set out in A new policy with respect to closed captioning, Broadcasting Public Notice CRTC 2007-54, 17 May 2007.[4]
The Weather Network must adhere to the English-language closed captioning mandatory quality standards and have its captioning evaluated using the Canadian NER Evaluation Guidelines.[5]
MétéoMédia must adhere to the requirements set out in the appendix to Quality standards for French-language closed captioning – Enforcement, monitoring and the future mandate of the French-language Closed Captioning Working Group, Broadcasting Regulatory Policy CRTC 2011-741-1, 21 February 2012.[6]
It is expected of Pelmorex that when programming with closed captioning on traditional platforms is made available on non-linear online platforms, the closed captioning is included.[7]
Described Video
- If the licensee broadcasts four hours or more per broadcast week of English- or French-language programming drawn from any of the program categories listed below, it shall, by the beginning of the fourth year of the first licence term during which this condition of licence applies, provide a minimum of four hours of described video per broadcast week for that programming.
- If the licensee broadcasts less than four hours per broadcast week of English- or French-language programming drawn from any of the program categories listed below, it shall, by the beginning of the fourth year of the first licence term during which this condition of licence applies, provide described video for all of that programming
- These requirements apply to programming drawn from the following program categories set out in Item 6 of Schedule 1 to the Discretionary Services Regulations, as amended from time to time: 2(b) Long-form documentary, 7 Drama and comedy, 9 Variety and 11(a) General entertainment and human interest and 11(b) Reality television, and/or to programming targeting preschool children (0-5 years of age) and children (6-12 years of age).[8]
3.8.2 Provisions of regulations made under subsection 10(1) of the Broadcasting Act
The Discretionary Services Regulations require broadcasters to indicate which programs are accessible by logging programs which contain closed captioning and described video.
Barriers and opportunities
Feedback from the OPC audit identified that some of The Weather Network and MétéoMédia’s on-air hosts lack the training and knowledge on how best to describe what is being displayed on screen and otherwise communicate in a way that is highly accessible, particularly for blind and low vision viewers. This lack of consistent training and knowledge creates inconsistencies and barriers to Pelmorex’s television services being as informative and enjoyable for all as intended. This inconsistency can be exacerbated by the use of technical and not well understood meteorological terms on air. Pelmorex has in the past partnered with the CNIB to provide such training, but it has not been delivered on a schedule consistent to ensure all on-air staff possess this important knowledge.
Pelmorex has also received feedback via its Accessibility Feedback Process identifying instances where our SAP channels are not functioning properly or are providing a forecast for the wrong region. As mentioned in Section 2.2, as our television services are distributed by a variety of cable and satellite providers we rely on customer feedback to know whether customers are in fact receiving the services that we make available to our affiliates, including the correct SAP channel forecast. This customer feedback highlights an opportunity for Pelmorex to better inform its viewers that they can play an important role in helping us to ensure our services are accessible by contacting us or their TV service provider.
Action Steps
| Action | Planned Completion |
| Identify options for training on-air hosts on how to speak in a way that is descriptive and understandable for all viewers. Implement the training for all on-air hosts and develop a schedule for training updates. | Year One |
| Promote to viewers their role in communicating to us or their TV provider if any of our accessibility services (e.g. SAP channel or captioning) are not functioning properly. | Year One |
Appendix - The Principles of the ACA
Section 6 of the ACA sets out the Principles of the Act. They are:
- all persons must be treated with dignity regardless of their disabilities;
- all persons must have the same opportunity to make for themselves the lives that they are able and wish to have regardless of their disabilities;
- all persons must have barrier-free access to full and equal participation in society, regardless of their disabilities;
- all persons must have meaningful options and be free to make their own choices, with support if they desire, regardless of their disabilities;
- laws, policies, programs, services and structures must take into account the disabilities of persons, the different ways that persons interact with their environments and the multiple and intersecting forms of marginalization and discrimination faced by persons;
- persons with disabilities must be involved in the development and design of laws, policies, programs, services and structures; and
- the development and revision of accessibility standards and the making of regulations must be done with the objective of achieving the highest level of accessibility for persons with disabilities.
Notes
[1] https://www.theweathernetwork.com/info/accessibility-and-accommodation "Accessibility and accommodation feedback"
[2] https://www.optimalperformance.ca "Optimal Performance Consultants"
[3] Broadcasting Decision CRTC 2018-342, The Weather Network/MétéoMédia – Licence renewal and renewal of mandatory distribution order https://crtc.gc.ca/eng/archive/2018/2018-342.htm
[4] Broadcasting Decision CRTC 2011-438, The Weather Network/Météomédia – Licence renewal and extension of the mandatory distribution of the service, https://crtc.gc.ca/eng/archive/2011/2011-438.htm
[5] Broadcasting Regulatory Policy CRTC 2019-308, English-language closed captioning mandatory quality standards relating to the accuracy rate for live television programming, https://crtc.gc.ca/eng/archive/2019/2019-308.htm
[6] Broadcasting Regulatory Policy 2016-346, Standard requirements for television stations, discretionary services, and on-demand services, https://crtc.gc.ca/eng/archive/2016/2016-436.htm
[7] Broadcasting Regulatory Policy CRTC 2015-104, Navigating the Road Ahead - Making informed choices about television providers and improving accessibility to television programming, https://crtc.gc.ca/eng/archive/2015/2015-104.htm
[8] Broadcasting Regulatory Policy 2016-346, Standard requirements for television stations, discretionary services, and on-demand services, https://crtc.gc.ca/eng/archive/2016/2016-436.htm