Toronto Seniors Housing Corporation (TSHC)

Elections Policy

Policy Sponsor: Director, Engagement, Partnerships, and Communications

Approver: Board of Directors

Initial Approval Date: May 18, 2022

Date of Last Revision, if applicable: N/A

Effective Date: June 1, 2022

Policy Statement

Toronto Seniors Housing Corporation (TSHC) is committed to working with tenants, candidates, political parties, and public officials at all three levels of government to facilitate elections and election activities on TSHC-managed property, in accordance with applicable legislation, by-laws, and TSHC policies.

During municipal, provincial, and federal election campaigns, TSHC will:

• ensure tenants’ personal information is kept private and confidential, in accordance with applicable legislation and internal protocols
• ensure that TSHC resources are not used to promote or give advantage to any candidate, political party or registered third party
• ensure that inquiries from candidates, political parties, or their agents are managed by the Communications Team
• support employee participation in political activities by granting unpaid leave to those seeking election

Policy Objectives

The objectives of this policy are to:

• outline TSHC’s responsibilities during elections
• outline how TSHC resources can and cannot be used during election campaigns, and which requests can and cannot be accommodated
• guide the conduct of TSHC’s employees and Board members during election campaigns in compliance with applicable legislation, by-laws and TSHC policies
• guide the conduct of TSHC’s employees and Board members seeking political office

Scope

The Elections Policy (Policy) governs election-related activities on TSHC-managed property and the actions of TSHC’s employees and Board members related to elections.

The Policy applies to:

• municipal (including school board), provincial or federal elections, or by-elections and to questions on the ballot
• all TSHC employees, Board members, and tenants, including those running for political office
• TSHC resources, including, but not limited to, employees, events, facilities, funds, information, and infrastructure

Definitions

Campaign/Campaigning: any activity by or on behalf of a candidate, political party, registered third party or in support or opposition to a question on a ballot, meant to elicit support during the election period. Campaigning does not include the appearance of elected officials, other candidates or registered third parties at an event in their personal capacity without the display of any signage or graphic which identifies the individual as a candidate or registered third party and without the solicitation of votes.

Campaign Materials: Any advertising or promotional materials intended to influence persons to vote for or against a candidate, political party, or a question on a ballot. Materials may include literature, banners, posters, pictures, buttons, clothing, etc. Election materials also include materials in all media, including websites or social media.

Elected Official: An individual elected to the House of Commons, the Legislative Assembly of Ontario, Toronto City Council, or a school board.

Election: An election or by-election at the municipal, provincial, or federal level, or the submission of a question on a ballot to the electors.

Election Officials: Employees of Elections Canada, Elections Ontario, Toronto Elections, or their agents.

Election Period: The official campaign period of an election.

• For municipal elections, the election period commences on May 1 of an election year and ends on election day.
• For provincial and federal elections, the election period commences the day that the election writ is issued and ends on election day.
• For by-elections, the election period commences when the by-election is called and ends on election day.
• For a question on a ballot, the election period commences when the respective level of government passes legislation or a by-law to put a question to the electorate. It ends on election day.

Employee: Includes management and exempt employees, contract-managed employees, and all members of TSHC bargaining units.

Leadership Team (LT): Team of senior leaders responsible for the strategic management of the corporate and operational functions of TSHC.

Official Election Materials: Any materials provided to voters by Elections Canada, Elections Ontario, Toronto Elections, or their agents to facilitate voting.

Personal Information: As defined in the Municipal Freedom of Information and Protection of Privacy Act, includes recorded information about an identifiable individual.

Political Office: The elected offices of municipal, provincial, or federal government.

Question on a Ballot: Any question submitted to electors by the municipal, provincial, or federal government.

Registered Third Party: In relation to a municipal election, an individual, corporation, or trade union that is registered with the City Clerk, in accordance with the Municipal Elections Act, section 88.6, whose purpose is to promote, support, or oppose a candidate for office, or an issue on a question on a ballot, and is not under the direction of a candidate.

Toronto Seniors Housing Corporation (TSHC) Resources: Including, but not limited to, employees, funds, events, facilities, information, and infrastructure, as defined below:

• “Election Day” means the day on which an election is held. This is the day most people go to vote.
• “Events” means events funded or organized by TSHC, including events that may be jointly organized with tenants, community organizations, and/or external sponsors.
• “Facilities” means common areas or grounds of any facility which is managed by TSHC.
• “Information” means any information in the custody and control of TSHC, including databases that may be the repository of names, contact information, business records, financial information, personal information, or other identifiers compiled and used by TSHC employees to carry out TSHC business. This information is considered TSHC property, and in most cases, it is not known to the public and may be confidential. It must not be used or disclosed without proper authorization, and in accordance with the Municipal Freedom of Information and Protection of Privacy Act.
• “Infrastructure” means any physical or technological systems and equipment that support the operation of TSHC, including, but not limited to, fleet vehicles, computer networks, telecommunications systems, wireless equipment, mobile phones, computer hardware, software and peripherals, internet, and intranet.

Roles and Responsibilities

• Communications Team: As policy owner, the Communications Team is responsible for the administration of this policy. All issues with respect to this policy and guidelines should be directed to the Communications Team.
• Department Leads: Department Leads are responsible for the application of this policy and guidelines to TSHC resources, facilities, and employees they manage.
• TSHC Employees: Employees are responsible for understanding and applying the Elections Policy and guidelines and for seeking clarification and advice from Department Leads if required.

Policy Content

The Elections Policy provides detailed information in the following areas:

• election activities on TSHC-managed property
• election signs
• protection of tenant privacy
• election-related inquiries
• use of TSHC resources during an election campaign
• workplace conduct during an election campaign
• employees seeking political office

Election Activities on TSHC-Managed Property

TSHC employees must ensure that:

• election officials, candidates, and their agents provide proper identification and display that identification to gain access to TSHC-managed property for election-related work
• election officials, candidates, and their agents have reasonable access to TSHC-managed property to perform their duties in accordance with the Residential Tenancies Act

TSHC employees will not:

• discard or tamper with official election materials (e.g., voter registration, voter identification cards, polling location information, etc.) delivered to tenants by election officials or their agents
• discard or tamper with campaign materials (e.g., pamphlets, flyers, letters, etc.) delivered to tenants by candidates, political parties, registered third parties or their agents

Election Signs

The City of Toronto’s Municipal Code provides rules and regulations regarding election signage that candidates must observe for any election in the City of Toronto.

• Signs cannot be illuminated or attached to trees.
• Signs cannot be placed between the curb and the sidewalk.
• Signs cannot interfere with the safe operation of vehicular traffic or with the safety of pedestrians.
• Signs cannot be located adjacent to a voting place.
• Signs may only be erected with the consent of the tenant.
• Signs may be higher than two meters above ground level provided they are displayed indoors. They cannot be attached to the outside of a balcony or terrace.
• No person is allowed to deface or willfully cause damage to a lawfully erected election sign.

Election signs may be erected on TSHC-managed property subject to compliance with the City’s rules and the following conditions:

• Tenants are permitted to post election signs anywhere considered to be within their personal unit. This includes fenced-off yards and ground-level fences attached to their unit.
• Tenants are not permitted to post election signs on their balconies.
• Election signs cannot be posted in common areas.

TSHC employees are required to remove election signs from common or prohibited areas, or signs that do not comply with City rules.

Protection of Tenant Privacy

TSHC is committed to protecting personal information consistent with the principles outlined in the Municipal Freedom of Information and Protection of Privacy Act and the Housing Services Act. TSHC employees must not provide tenant lists or other personal information about tenants to election officials, candidates, political parties, registered third parties, or their agents.

Election-Related Inquiries

• All election-related inquiries to employees or Board members from political parties, candidates, registered third parties, and/or their agents must immediately be directed to the Communications Team. Employees should also inform their managers of the inquiry.
• TSHC will share information with candidates, political parties, and/or their agents provided it contains no confidential information or personal information about tenants.
• Information that is provided by TSHC to one candidate or political party during an election period will be provided to all others, either by posting the information online or through other means.
• Requests made by a candidate, political party, or registered third party for a personal meeting or tour with an Officer, Board member, Leadership Team member or other TSHC employee during an official election period will not be accommodated.

Use of Toronto Seniors Housing Corporation (TSHC) Resources

• Elected officials may attend TSHC events and/or events held at TSHC facilities in their capacity as elected officials; however, they may not solicit votes, display election signs, or distribute campaign material.
• Candidates, representatives of political parties, and registered third parties may attend TSHC events and/or events held at TSHC-managed facilities as private citizens but may not campaign while in attendance. They may not solicit votes, display election signs, or distribute campaign material.
• Once the writ is issued for Provincial or Federal elections, Members of Parliament (MPs) and Members of Provincial Parliament (MPPs) are no longer elected officials and should not be invited to attend TSHC events in their capacity as elected officials.
• TSHC cannot make a contribution including money, goods, and services to any candidate, political party, or registered third party.
• TSHC resources cannot be used to promote one candidate, political party, or registered third party over another during an election period.
• TSHC supports tenant engagement in elections. To facilitate this engagement, all-candidates meetings may be held at TSHC-managed facilities, where practicable, provided that all registered candidates are invited to attend.
• After August 1 in a municipal election year, TSHC will not reference the name of members of City Council in:
  • advertising and other communications materials paid for or distributed by TSHC
  • event signage, including banners and posters
  • media releases issued by the Communications Team
• If it is necessary to reference a specific member of City Council or the Mayor in TSHC communications or media materials after August 1 in a municipal election year, the generic term “Councillor Ward XX” or “Mayor of Toronto” must be used.
• TSHC communications materials, including websites or domain names funded or administered by TSHC, and social media, blogs, or other new media created and managed by TSHC employees, whether for internal or public distribution, must not:
  • profile (name or photograph), refer to, and/or identify any individual as a candidate, or any individual or entity as registered third party, in any election
  • profile any slogan or symbol associated with a candidate, political party, or registered third party during the election period
  • advocate for or against a particular candidate, political party, or ballot question position during an election period
• Photographic or video materials created by TSHC employees or with TSHC resources cannot be used in any campaign materials.
• TSHC’s logo cannot be used in any campaign material.

Workplace Conduct During an Election Campaign

TSHC recognizes the right of employees to participate in political and election activities balanced against the corporation’s legitimate interest in both being and appearing to be non-partisan.

TSHC employees are not permitted to:

• use or allow the use of TSHC resources for campaign activities. TSHC resources include, but are not limited to, employee time, as well as events, facilities, funds, information, and infrastructure.
• engage in campaign activities during working hours. Working hours do not include vacation time or time on leaves of absence.
• display election campaign items at work.
• attend campaign events or undertake campaign activities while in TSHC clothing.
• solicit funds for a candidate from co-workers, either at work or outside of work.

The Chief Executive Officer of TSHC and members of the Leadership Team are not permitted to campaign for a candidate or political party before or during municipal, provincial, and federal elections.

Employees Seeking Political Office

TSHC employees seeking to run for political office must first declare a potential conflict in writing to their Department Lead and receive authorization prior to filing their candidacy. The employee must provide written notice to their manager at least two weeks in advance of their intention to take unpaid leave.

• For municipal elections, the leave must start the next working day after the employee files their candidacy.
• For provincial and federal elections, the leave must start the next working day after the employee receives the nomination.

Conflict of Interest

• Employees on an approved leave of absence from TSHC remain employees of the organization and are bound by all TSHC policies.
• While campaigning, employees on political leave must clearly state at all times that the views they express are personal views, and not those of TSHC.

Salary and Benefits

• Political leave is unpaid, and benefits can be continued at the employee’s expense.
• For management and exempt employees, continuous service and vacation entitlement are not affected by a leave without pay, where the leave is for twenty (20) business days or less.
• Bargaining unit employees are subject to the provisions in their existing collective agreement.

Election to Political Office

• An employee who is elected to political office within the geographical boundaries of the City of Toronto must resign from TSHC.
• An employee who is elected to political office outside of the geographical boundaries of the City of Toronto must resign from TSHC if the political office will interfere with their ability to perform their regular duties, as determined by their Department Lead.
• The resignation must take effect no more than two weeks after the election and prior to the commencement of the term of office.

Rehiring

• TSHC has no obligation to rehire employees who have resigned their position to take political office. Rehiring would be subject to TSHC’s hiring policies.

Board Members Seeking Political Office

TSHC Tenant Directors (Board members) seeking political office should refer to the rules set out in the Board of Directors Conflict of Interest Policy.

Related Legislation, Regulations, and TSHC Policies:

Legislation and Regulations

• Federal Elections Act
• Election Act
• Municipal Elections Act
• City of Toronto Municipal Code
• Residential Tenancies Act
• Housing Services Act
• Municipal Freedom of Information and Protection of Privacy Act
• Personal Information Protection and Electronic Documents Act

TSHC Policies and Procedures:

• Board of Directors Conflict of Interest Policy
• Board of Directors Code of Ethics and Conduct Policy
• Employee Code of Conduct Policy
• Employee Conflict of Interest Policy
• Guidelines for Elections Policy
• Media and Issues Protocol
• Voluntary Leave without Pay Policy

Amendments (Revision History):

N/A

Next Scheduled Review Date: 2027

This policy will be reviewed once every 5 years.

Policy Contact

Manager, Communications and External Affairs

Appendices

Guidelines for Elections Policy

Toronto Seniors Housing Corporation (TSHC)
Accessibility Policy

Policy Sponsor: Director, Strategy and Business Management

Approver: Board of Directors

Initial Approval Date: May 17, 2022

Effective Date: June 1, 2022

Organizational Statement of Commitment

Toronto Seniors Housing Corporation (TSHC) is committed to providing an inclusive environment to tenants and employees with disabilities in accordance with the core principles of accommodation, dignity, independence, integration and equal opportunity outlined in the Human Rights Code, R.S.O. 1990, c.H.19 and the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c.11, and the complimentary legislation of the Employment Standards Act, 2000, S.O. 2000, c.41, the Ontario Building Code, O. Reg. 332/12, and the Integrated Accessibility Standards, O. Reg.191/11.

Policy Statement

Toronto Seniors Housing Corporation recognizes the need to identify and remove barriers faced by people with disabilities and will achieve greater accessibility by aligning with a culture that recognizes the dignity and worth of every individual.​

This policy provides an overview of all of Toronto Seniors Housing Corporation’s policies, plans and programs as they relate to accessibility. While components of this policy are intended to address the corporation’s compliance with legislation, Toronto Seniors Housing Corporation’s commitment to accessibility extends beyond legislative compliance. As Toronto Seniors Housing Corporation continues to achieve accessible social housing and employment, this policy requires Toronto Seniors Housing Corporation staff to incorporate best practices in accessibility through all aspects of its business. Toronto Seniors Housing Corporation will engage and consult with stakeholders, tenants, and employees with disabilities in the development of its accessibility policies, plans, and programs.

Definitions

​​Accessible formats: ​Formats that are an alternative to standard formats and are accessible to people with disabilities. Accessible formats may include, but are not limited to, large print, recorded audio and electronic formats, braille and other formats usable by persons with disabilities.

​Communication supports: Supports that individuals with disabilities may need to access information. These include, but are not limited to, captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications.

Disability: From the Ontario Human Rights Code, R.S.O. 1990, c. H. 19:

• any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness;
• a condition of mental impairment or developmental disability;
• a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoke language;
• a mental disorder; or
• an injury or disability for which benefits were claimed or received under the Workplace Safety and Insurance Act, 1997, S.O. 1997, c. 16 sche. A, or Ontario Disability Support Program.

​In addition, the definition of disability under the Ontario Human Rights Code, R.S.O. 1990, c. H. 19, may include but is not limited to:

• Acquired Brain Injury
• Deaf, deafened, hard-of-hearing
• Low vision or blind
• Chronic health conditions (cancer, epilepsy, heart disease, etc.)

Accessibility Lead: The member of the leadership team who has been designated as the lead for this policy and all related accessibility initiatives.

Toronto Seniors Housing Corporation staff: All Toronto Seniors Housing Corporation employees, whether full or part-time, temporary or permanent, including secondees. ​

Volunteers: Any individual who works for or on behalf of Toronto Seniors Housing Corporation on an unpaid basis, or for nominal consideration, including, but not limited to, volunteers, tenant volunteers, interns, and students.

Scope

This policy applies to all Toronto Seniors Housing Corporation staff, volunteers, and third party contractors who interact with tenants or staff on behalf of Toronto Seniors Housing Corporation.

​Core Principles

In keeping with our values of respect, inclusion, accountability and innovation, Toronto Seniors Housing Corporation will implement this policy in accordance with the following principles:

Dignity

Tenants and staff are treated in a respectful manner.

Independence

Services, opportunities, programs, and facilities for persons with disabilities will support their independence while respecting their right to safety and personal privacy. Service delivery will consider the nature of the service and alternative accommodation that may be required.

Equity/Equality of Outcome

Tenants and staff with disabilities will be provided the same access to our programs, services, opportunities, and facilities as all other tenants and staff.

Integration

Tenants and staff with disabilities will fully benefit from the same programs, services, opportunities, and facilities, in the same places and in the same or similar way as all other tenants and staff. An emphasis on inclusion will focus on eliminating barriers for people with disabilities.

Governance and Legislation

Toronto Seniors Housing Corporation will meet or exceed the following legislative requirements:​

Accessibility for Ontarians with Disabilities Act, 2005 (AODA)

The AODA came into effect in 2005. It permits the Ontario government to establish Accessibility Standards to remove or prevent barriers for Ontarians with disabilities by 2025. For details on Toronto Seniors Housing Corporation’s compliance with the AODA and associated legislation refer to the relevant policies as listed in the Policy Details.

Employment Standards Act, 2000 (ESA)

The ESA sets out the minimum standards for working in Ontario and defines the rights and responsibilities of employees and employers. Toronto Seniors Housing Corporation is committed to complying with the standards outlined in the ESA as they relate to accessibility and accommodation on the basis of disability.

Ontario Human Rights Code (OHRC)

The OHRC was enacted in 1990 and ensures the rights of all people to be treated equally and without discrimination based on race, colour, gender identity, sex, sexual orientation, disability, creed and age. Toronto Seniors Housing Corporation is committed to upholding the OHRC in its entirety.

Integrated Accessibility Standards (IASR)

The IASR was enacted under the AODA in 2011, with phased implementation requirements commencing January 1, 2012 through to January 1, 2021.
​The IASR addresses three specific areas of relevance to Toronto Seniors Housing Corporation: accessible employment practices; accessible information and communication supports; and design of the built environment. Provisions that guide staff in complying with the IASR can be found in a number of policies, programs and standards and are noted in the Policy Details below.

Toronto Seniors Housing Corporation tracks the implementation of the IASR in its multi-year Accessibility Plan. The plan is posted on Toronto Seniors Housing Corporation’s website and is made available in accessible formats upon request. The plan is updated on an ongoing basis and is fully reviewed every five years.

Ontario Building Code (OBC)

The OBC is a set of mandated building design and construction standards aimed at minimizing the risk to the health and safety of the occupants of a building and to provide for the barrier-free access to buildings. Toronto Seniors Housing Corporation follows the standards set out in the OBC in order to make sure that the design and construction of all new buildings, and changes and additions to existing buildings serve to increase accessibility for tenants and meet legislative requirements by 2025.

​Accessibility Focus Areas

Accessible Customer Service

Toronto Seniors Housing Corporation will develop best practices to provide accessible customer service in a respectful and transparent manner. The relevant policies and programs are summarized below and the details can be found in the documents themselves.

• Accessible Customer Service Policy: outlines our commitment to provide customer service that is inclusive, barrier free and meets the unique needs of persons with disabilities.
• Communication Standards/Accessible Formats and Communications Supports:outlines the standards that Toronto Seniors Housing Corporation follows in all communications to tenants. These standards include the Information and Communications Standards as outlined in the IASR.
• Human Rights, Harassment & Fair Access Policy:Includes proactive measures to eliminate harassment and discrimination in accommodation, employment, delivery of services, and in all other contract arrangements. It reflects the requirements of the OHRC and policies established by the City of Toronto.
• Self-Service Kiosk Standards:Toronto Seniors Housing Corporation will ensure accessibility for persons with disabilities when designing, procuring and acquiring self-service kiosks, as indicated in the IASR.
• Tenant Transfer Policy:formalizes Toronto Seniors Housing Corporation’s commitment to priority transfers of persons who have a medically documented need for accessible accommodation.
• Tenant Complaints Process:ensures that complaints are heard, the facts of the complaints are established, and where required, remedial actions are taken. The primary objective of this process is to outline a simple process which is accessible to all.

Accessible Homes

Toronto Seniors Housing Corporation will ensure that tenants with disabilities can live in units, buildings and communities that accommodate their needs. The relevant policies and programs are summarized here and the details can be found in the documents themselves.

• Accessibility in the Built Environment Policy:TSHC strives to treat all individuals in a manner that allows them to maintain their dignity and independence and is committed to providing an inclusive environment to tenants with disabilities as outlined in the Human Rights Code, the Accessibility for Ontarians with Disabilities Act, and the complimentary legislation of the Ontario Building Code, and the Integrated Accessibility Standards. As the buildings TSHC manages are owned by Toronto Community Housing Corporation (TCHC), TSHC uses the TCHC’s Build Standards to provide guidance as they apply to minor accessibility modifications that TSHC may make to tenants’ units. TSHC’s Accessibility Plan sets out TSHC’s policy on how we will achieve accessibility generally, as well as in the built environment.
• Accessibility Program: Capital Planning:TSHC participates in TCHC’s capital planning and implementation process for planned capital improvements.
• Accessibility Program: Tenant Request Unit Modifications:includes standards and a process for accessibility-related unit modifications based on tenant request and documented medical need.

Accessible Workplaces

Toronto Seniors Housing Corporation will ensure that employees with disabilities are accommodated in a respectful and transparent manner. The relevant policies and programs are summarized here and the details can be found in the documents themselves.

• Hiring Policy:Outlines Toronto Seniors Housing Corporation’s commitment to meeting its statutory obligations in the hiring process, and ensures that employment accommodation is provided to all candidates in accordance with the OHRC and the ESA.
• Human Rights, Harassment & Fair Access Policy:Includes proactive measures to eliminate harassment and discrimination in accommodation, employment, delivery of services, and in all other contract arrangements. It reflects the requirements of the OHRC and policies established by the City of Toronto.
• Individualized Workplace Emergency Response Information:Individualized workplace emergency response information will be prepared for employees with disabilities where the disability is such that the individualized information is necessary and Toronto Seniors Housing Corporation is aware of the need for accommodation due to the employee’s disability. This will be prepared as soon as practicable after Toronto Seniors Housing Corporation becomes aware of the need for accommodation due to the employee’s disability. A detailed process can be found as part of Toronto Seniors Housing Corporation’s Workplace Accommodation Policy.
• Workplace Accommodation Policy:Facilitates effective responses to accommodation issues that arise in the workplace and ensures Toronto Seniors Housing Corporation meets its duty to accommodate under the OHRC.

Supports for Policy Implementation

• Staff Training:Toronto Seniors Housing Corporation will ensure that accessibility training is provided to all employees and persons who participate in developing our policies.

The training will consist of requirements under the IASR; the parts of the OHRC that pertain to people with disabilities.

​The training will be appropriate to the duties of the person being trained and will be provided as soon as practicable. A record will be kept of the dates of the training and the number of individuals trained.

Toronto Seniors Housing Corporation will also provide training on an ongoing basis when changes are made to the policies and programs listed above, and to new employees as part of the on-boarding process.

• Tenant & Staff Engagement:Toronto Seniors Housing Corporation will consult and work with tenants with disabilities and stakeholders in the development of the above accessibility policies, plans, and programs. Toronto Seniors Housing Corporation will consult with appropriate stakeholders, which may include tenants with disabilities, tenant accessibility advocacy groups, experts in the field of accessibility, and Toronto Seniors Housing Corporation staff when undertaking formal reviews of this policy and any other Toronto Seniors Housing Corporation policies related to accessibility.
• Procuring Goods and Services:Toronto Seniors Housing Corporation’s Procurement Department shall incorporate accessibility criteria and features into its procurement process, procurement documents shall specify the desired accessibility standards to be met and the related submission requirements, except where it is not practical to do so. Where it is impractical to incorporate accessibility criteria and features into the procurement process, the Procurement Department will provide an explanation upon request. The Procurement Department will also ensure that all selected vendors, where applicable, comply with the AODA and its regulations when providing accessible goods and services to Toronto Seniors Housing Corporation.​

Compliance and Monitoring

Accessibility Reviews

All new or revised policies and procedures will be reviewed to ensure legislative compliance. When developing, revising and implementing Toronto Seniors Housing Corporation’s policies and strategies, authorized Toronto Seniors Housing Corporation staff will conduct an accessibility review. This review will consider and address accessibility, with a particular focus on reducing barriers faced by people with disabilities and ensuring the principles guiding this policy are upheld.

Reporting

The accessibility lead will report regularly to the leadership team. Accessibility is an integral component of Toronto Seniors Housing Corporation’s business, and metrics on accessibility improvements will be reported  regularly to the Toronto Seniors Housing Corporation Board of Directors and annually through the annual report.

Related Legislation, Regulations, and TSHC Policies:

• Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11
• Employment Standards Act, 2000, S.O. 2000, c. 41
• Human Rights Code, R.S.O. 1990, c. H. 19
• Integrated Accessibility Standards, O. Reg. 191/11
• ​Ontario Building Code, O. Reg. 332/12
• TSHC Accessible Customer Service Policy
• TSHC Hiring Policy
• TSHC Human Rights Policy – staff
• TSHC Human Rights, Harassment & Fair Access Policy – tenants
• TSHC Workplace Accommodation Policy

Amendments (Revision History):

NA

​Next Scheduled Review Date:

This policy will be reviewed once every five years.

Policy Contact

Director, Strategy and Business Management

Toronto Seniors Housing Corporation Multi-Year Accessibility Plan

(the “Accessibility Plan”)

(Ontario Regulation 191/11) of the Accessibility for Ontarians with Disabilities Act, 2005

Introduction

The Integrated Accessibility Standards Regulations (“IASR”) under the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”), require that Toronto Seniors Housing Corporation (TSHC) establish, implement, maintain, and document its accessibility policies and multi-year accessibility plan (the “Accessibility Plan”), which outlines TSHC’s strategy to prevent and remove barriers for persons with disabilities and to meet its requirements under the IASR.

The Accessibility Plan will be available in an accessible format upon request. The Accessibility Plan will be reviewed and updated, if applicable, at least once every five years.

Application

The Accessibility Plan applies to all employees, tenants, and clients of TSHC, and, where indicated, to any independent contractor representatives working for the company.

Our Commitment

In fulfilling our mission, TSHC strives to treat all individuals in a manner that allows them to maintain their dignity and independence. TSHC promotes integration and equal opportunity and is committed to meeting the needs of people with disabilities in a timely manner. We will seek to achieve this by preventing and removing barriers to accessibility and by meeting accessibility requirements under the AODA. This Accessibility Plan sets out TSHC’s policy on how we will achieve accessibility generally, as well as in employment, information and communications, and the design of public spaces (built environment).

Under the IASR, the following accessibility strategies set out the requirements that are applicable to TSHC:

• Workplace Emergency Response Information
• Training
• Information and Communication
• Employment
• Design of Public Spaces Standards

Accessibility Standards for Customer Service

TSHC is committed to compliance with the Accessibility Standards for Customer Service Regulation (O.Reg.429/07) under the AODA, which involves providing its services in ways that respect the dignity and independence of people with disabilities.

TSHC’s employees who are involved in providing customer service to its customers and the general public have been trained on TSHC’s Accessible Customer Service Policy, and all new employees hired to provide such services will receive such training as part of their orientation with the company.

Copies of TSHC’s Accessible Customer Service Policy will be made available to members of the public and third parties on request and is available on the TSHC website here.

Integrated Accessibility Standards Regulations (IASR)

The following sets out how TSHC is committed to complying with the IASR.

1. Workplace Emergency Response Information

Where TSHC is aware that an employee has a disability and that there is a need for accommodation, individualized workplace emergency response information will be provided to the employee as soon as practicable if such information is necessary given the nature of the employee’s disability.

Action Taken:

TSHC will be implementing the following measures to address Emergency Response for employees who have disabilities:

• individualized workplace emergency response information procedures will be developed for employees with disabilities where required.
• where employees disclose a disability and are being accommodated according to their disabilities, workplace emergency response information forms will be prepared where required.
• where required, TSHC provides assistance to specific disabled employees, with the disabled employees’ prior consent, to help them evacuate the workplace in case of an emergency or disaster. Plans for providing assistance will be set out in individualized emergency plans for the employees.
• individualized emergency plans will be communicated to the employees’ respective managers and safety personnel on an ‘as needed’ basis.
• on an ongoing and regular basis, and as per the applicable terms of the IASR, TSHC will review and assess general workplace emergency response procedures and individualized emergency plans to ensure accessibility issues are addressed.

Compliance Date: June 2022

2. Training

TSHC is committed to providing training on the requirements of the accessibility standards referred to in the IASR and on the Human Rights Code, as it pertains to persons with disabilities.

Planned Action:

In accordance with the IASR, TSHC will:

• determine and ensure that appropriate training on the requirements of the IASR and on the Human Rights Code as it pertains to persons with disabilities, is provided to all employees, independent contractor representatives, volunteers, third-party service providers who provide services related to products, services, and facilities on TSHC’s behalf, and persons participating in the development and approval of TSHC’s policies.
• ensure that the training is provided to persons referenced above as soon as practicable.
• keep and maintain a record of the training provided, including dates the training was provided and number of individuals to whom it was provided.
• ensure training is provided on any changes to TSHC’s policies on an ongoing basis.

Anticipated Compliance Date: March 2024

3. Information and Communication

TSHC is committed to making company information and communications accessible to persons with disabilities. TSHC will incorporate new accessibility requirements under the information and communication standards to ensure that its information and communications systems and platforms are accessible and are provided, upon request, in accessible formats that meet the needs of persons with disabilities.

a. Feedback, Accessible Formats, and Communication Supports

Planned Action:

In accordance with the IASR, TSHC will:

• ensure that existing and new processes for receiving and responding to feedback are accessible to persons with disabilities by providing or arranging for the provision of accessible formats and communication supports, upon request and in a timely manner.
• more broadly, as a general principle where accessible formats and communication supports for persons with disabilities are requested:
  • provide or arrange for the provision of such accessible formats and communication supports.
  • consult with the person making the request to determine the suitability of the accessible format or communication support.
  • provide or arrange for the provision of accessible formats and communication supports in a timely manner that takes into account the person’s accessibility needs due to disability, and at a cost no more than the regular cost charged to other persons.
• notify the public about the availability of accessible formats and communication supports.

Compliance Date: January 2023

b. Accessible Websites and Web Content

Planned Action:

In accordance with the IASR, TSHC recognizes its obligation to provide web content which conforms with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG 2.0) Level AA.

Any website hosted by TSHC shall meet the requirements set out in the IASR.

Compliance Date: September 2023

4. Employment

a. Recruitment

TSHC is committed to fair and accessible employment recruiting practices that attract and retain employees with disabilities. This includes providing accessibility at all stages of the employment cycle.

Planned Action:

In accordance with the IASR, TSHC will do the following:

(i) Recruitment General

TSHC will notify employees and the public of the availability of accommodation for applicants with disabilities in the recruitment process. This will include:

• review and, as necessary, modification of existing recruitment policies, procedures, and processes.
• specifying that accommodation is available for applicants with disabilities, on TSHC’s website and on job postings.

Anticipated Compliance: March 2024

(ii) Recruitment, Assessment, and Selection

TSHC will notify job applicants, when they are individually selected to participate in an assessment or selection process and inform them that accommodations are available upon request in relation to the materials or processes to be used in the assessment/selection process. This will include:

• review and, as necessary, modification of existing recruitment policies, procedures, and processes.
• inclusion of availability of accommodation notice as part of the script in the scheduling of an interview and/or assessment.
• consultation with the applicant and arrangement for provision of suitable accommodations in a manner that takes into account the applicant’s accessibility needs due to the disability where a selected applicant requests accommodation.

Compliance Date: June 2022

(iii) Notice to Successful Applicants

When making offers of employment, TSHC will notify the successful applicant of its policies for accommodating employees with disabilities. This will include:

• A review and, as necessary, modification of existing recruitment policies, procedures, and processes.
• inclusion of notification of TSHC’s policies on accommodating employees with disabilities in offer of employment letters.

Compliance Date: June 2022

b. Informing Employees of Supports and General Provision of Accessible Formats and Communications Supports

In accordance with the IASR, TSHC will inform all employees of policies that support employees with disabilities, including, but not limited to, policies on the provision of job accommodations that take into account an employee’s accessibility needs due to a disability.

This will include:

• informing current employees and new hires of TSHC’s policies supporting employees with disabilities, including, but not limited to, policies on the provision of job accommodations that take into account an employee’s needs due to disability.
• providing information as soon as practicable after the new employee begins employment, specifically in the orientation process.
• keeping employees up to date on changes to existing policies on job accommodations with respect to disabilities.
• where an employee with a disability so requests it, TSHC will provide or arrange for provision of suitable accessible formats and communications supports for:
  • information that is needed in order to perform the employee’s job.
  • information that is generally available to employees in the workplace.
• in meeting the obligations to provide the information that is set out above, TSHC will consult with the requesting employee in determining the suitability of an accessible format or communication support.

Compliance Date: June 2022

c. Documented Individual Accommodation Plans/Return to Work Process

TSHC will incorporate new accessibility requirements under the IASR to ensure that barriers in accommodation and return to work processes are eliminated and corporate policies surrounding accommodation and return to work are followed, where applicable.

Planned Action:

TSHC’s existing policies include steps that TSHC will take to accommodate employees with disabilities and to facilitate employees’ return to work after absence due to disability.

TSHC will review and assess the existing policies to ensure that they include a process for the development of documented individual accommodation plans for employees with disabilities, if such plans are required.

In accordance with the provisions of the IASR, TSHC will ensure that the process for the development of documented individual accommodation plans includes the following elements:

• information regarding the manner in which the employee requesting accommodation can participate in the development of the plan.
• information regarding the means by which the employee is assessed on an individual basis.
• information regarding the manner in which TSHC can request an evaluation by an outside medical or other expert, at TSHC’s expense, to assist TSHC in determining if and how accommodation can be achieved.
• steps to protect the privacy of the employee’s personal information.
• information regarding the frequency with which individual accommodation plans will be reviewed and updated and the manner in which this will be done.
• the reasons for a denial where an individual accommodation plan is denied.
• information regarding the means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs,
• the following will be included if individual accommodation plans are established:
  • any individualized workplace emergency response information that is required.
  • any information regarding accessible formats and communication supports that have been provided for or arranged, in order to provide the employee with:
    • information that is needed in order to perform the employee’s job.
    • information that is generally available to employees in the workplace.
• identify any other accommodation that is to be provided to the employee.

TSHC will ensure that the return-to-work process as set out in its existing policies outlines:

• the steps TSHC will take to facilitate the employee’s return to work after a disability-related absence.
• the development of a written individualized return to work plan for such employees.
• the use of individual accommodation plans, as discussed above, in the return-to-work process.

Compliance Date: June 2022

d. Performance Management, Career Development and Redeployment

TSHC will take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans:

• when using its performance management process in respect of employees with disabilities.
• when providing career development and advancement to employees with disabilities.
• when redeploying employees with disabilities.

Planned Action:

In accordance with the IASR, TSHC will:

• review, assess and, as necessary, modify existing policies, procedures, and practices to ensure compliance with the IASR.
• take the accessibility needs of employees with disabilities and, as applicable, their individualized accommodation plans, into account when:
  • assessing performance
  • managing career development and advancement
  • redeployment is required
• review, assess and, as necessary, include in performance management workshops, accessibility criteria.
• take into account the accessibility needs of employees with disabilities when providing career development and advancement to its employees with disabilities, including notification of the ability to provide accommodations on internal job postings.
• take into account the accessibility needs of employees with disabilities when redeploying employees, including review and, as necessary, modification of the employee transfer checklist.

Compliance Date: June 2022

Integrated Accessibility Standards Regulations – Design of Public Spaces

While TSHC has no plans to engage in new construction or redevelopment which would be captured by the requirements of the IASR concerning the Design of Public Spaces, TSHC recognizes its obligations under the relevant sections of the Regulation and is committed to incorporating barrier-free design principles into any public spaces that are newly constructed and redeveloped on or after January 1, 2017.

Toronto Seniors Housing Corporation manages the Landlord and Tenant relationship.  All 83 of the TSHC-managed buildings are owned by the Toronto Community Housing Corporation.

Feedback:

For more information on this Accessibility Plan or for accessible formats of the Accessibility Plan, please contact:

Grant Coffey, Director of Strategy and Business Management

Email: Grant.Coffey@torontoseniorshousing.ca

Telephone: 416-981-4548

Plan version:  August 2024

Toronto Seniors Housing Corporation (TSHC)
Accessible Customer Service Policy

Policy Sponsor: Director, Strategy and Business Management

Approver: Board of Directors

Initial Approval Date: May 17, 2022

Effective Date: June 1, 2022

Policy Statement

Toronto Seniors Housing Corporation (TSHC) recognizes that accessibility for persons with disabilities is an important issue that needs to be addressed throughout our portfolio. Toronto Seniors Housing Corporation is committed to the principles of accommodation outlined in the Accessibility for Ontarians with Disabilities Act, 2005 (AODA), the Accessibility Standards for Customer Service, Ontario Regulation 429/07 (the Customer Service Standard), and the Ontario Human Rights Code. The Accessibility Standards for Customer Service, Ontario Regulation 429/07 (the Customer Service Standards) is an accessibility standard created under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA).

Toronto Seniors Housing Corporation will continue to provide customer service for persons with disabilities in a manner that respects their dignity and independence while allowing them the same opportunity as any other customer to access and benefit from our services.

As additional standards identified in the AODA pass into regulation, this policy will be adjusted to include these new standards.

Policy Objectives

In fulfillment of its obligations under the Customer Service Standards and in keeping with its values, this policy outlines Toronto Seniors Housing Corporation’s commitment to provide customer service that is inclusive, barrier free and meets the unique needs of persons with disabilities.

The purpose of this policy is to lay out Toronto Seniors Housing Corporation’s commitment to providing accessible customer service. This policy sets out key customer service commitments in several areas relating to accessibility.

Guidelines will set out detailed procedures and protocols that guide Toronto Seniors Housing Corporation in applying this policy. The policy and Guidelines will inform tenants and the public of our commitment and will guide them in requesting accommodation in service and providing feedback about our services.

Scope

This policy applies to all persons who interact with tenants, members of the public or third parties on behalf of Toronto Seniors Housing Corporation, as an employee, contractor, volunteer, member of the Board of Directors or otherwise.

Key Values

Toronto Seniors Housing Corporation shall provide accessible customer service in accordance with the following key principles:

Dignity

Service is provided in a respectful manner consistent with the needs of the individual.

Independence

Services for persons with disabilities shall support their independence while respecting their right to safety and personal privacy. As such, service delivery shall consider the nature of the service and alternative accommodation that may be required.

Equity/Equality of Outcome

Customers with disabilities will be provided with the same opportunity to access our services as all other customers.

Integration

Customers with disabilities shall fully benefit from the same services, in the same place and in the same or similar way as all other customers.

Definitions

Under the Customer Service Standards (O.Reg. 429/07):

Assistive Device: A device used to assist persons with disabilities in carrying out activities of daily life or accessing the services provided by Toronto Seniors Housing Corporation including, but not limited to, wheelchairs, walkers, canes, note-taking devices, portable magnifiers, recording machines, personal oxygen tanks and devices for grasping.

Barrier: Anything that prevents a person with a disability from fully participating in all aspects of society because oftheir disability, including a physical barrier, an architectural barrier, an information or communications barrier, an attitudinal barrier, a technological barrier, a policy a practice.

Disability: (a) any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co- ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device, (b) a condition of mental impairment or a developmental disability, (c) learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language, (d) mental disorder, or (e) an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

Service Animal: An animal trained specifically to assist an individual with a disability, either where it is readily apparent that the animal is a service animal or where a letter has been provided by a doctor or nurse confirming that the person requires the animal for reasons related to a disability.

Support Person: Someone who accompanies a person with a disability and assists them with communication, mobility, personal care, medical needs or with access to goods or services.

Customer Service Commitments

Training

Toronto Seniors Housing Corporation will provide training to all Board Members, employees, volunteers and others who interact with the tenants, the public or other third parties on its behalf, and all those who are involved in the development and approvals of customer service policies and procedures. Training will include the following:

The purposes of the AODA; the requirements of the customer service standard; and any subsequent legislation.

Instruction on Toronto Seniors Housing Corporation’s policies, and procedures pertaining to the provision of goods and services to persons with disabilities, including the customer service standard.

How to interact and communicate with persons with various types of disabilities.

What to do if a person with a disability is having difficulty accessing Toronto Seniors Housing Corporation’s goods and services.

New staff will be trained upon their initial orientation. Following initial training, existing staff will receive training on a regular basis and when changes are made to these policies and procedures or regulations.

Service Animals

Toronto Seniors Housing Corporation is committed to welcoming persons with disabilities who are accompanied by a service animal on the parts of our premises that are open to the public.

If a service animal is excluded by law, Toronto Seniors Housing Corporation will suggest appropriate alternatives and provide assistance in order to ensure that the person is able to access, obtain, use or benefit from Toronto Seniors Housing Corporation’s services where possible.

Support Persons

Any person with a disability who is accompanied by a Support Person will be allowed to access any services provided by Toronto Seniors Housing Corporation with their Support Person. At no time will Toronto Seniors Housing Corporation prevent a person with a disability who is accompanied by a Support Person from having access to their Support Person.

Where there are barriers to access or attendance by a Support Person at sponsored meetings, consultations or events, Toronto Seniors Housing Corporation will seek to facilitate access so as to ensure the participation of persons with disabilities.

Assistive Devices

Persons with disabilities shall be permitted to obtain, use or benefit from goods or services through the use of their own assistive devices. Staff will be trained so as to be familiar with various assistive devices that may be used by customers with disabilities while accessing services.

In the event a person with a disability is hindered from accessing any goods or services offered, Toronto Seniors Housing Corporation will seek to accommodate the person by offering the use of another assistive device that is available or an alternative way of delivering the same service.

Toronto Seniors Housing Corporation will ensure that staff know how to use assistive devices available in their various locations for customers and inform customers of the assistive devices that are available.

Notice of Temporary Disruptions

Toronto Seniors Housing Corporation is aware that the operation of its services and facilities is important to its customers. However, temporary disruptions in services and facilities may occur.

Toronto Seniors Housing Corporation will provide its customers with notice of any disruption to its services, including information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if any, that may be available.

Notice of service disruptions will be provided as soon as staff is aware of the disruption, or in advance in the case of planned disruptions. Notice will be provided by a variety of methods, depending on the circumstances, and may include postings in conspicuous places at the affected premises, in other Toronto Seniors Housing Corporation facilities, on Toronto Seniors Housing Corporation’s website or by any other means that will ensure that the notice reaches those persons potentially affected by the temporary disruption in a manner that is accessible to them.

Feedback Policy

The goal of Toronto Seniors Housing Corporation is to meet and surpass expectations while providing services to customers with disabilities. Feedback on our services and whether expectations are being met are welcome and appreciated. Feedback may be provided by a person with a disability in the manner deemed most convenient to them, such as in person, by telephone, in writing, by email or otherwise. All feedback will be kept in strict confidence and used to improve customer service. In addition, the author of the feedback will be provided a response in the format requested (or the most appropriate format where no request was made) outlining actions taken. Where an individual is not satisfied with Toronto Seniors Housing Corporation’s response to their feedback, staff will direct their complaint to the appropriate individual to respond.

Related Legislation, Regulations, and TSHC Policies:

• Accessibility for Ontarians with Disabilities Act, 2005 (AODA)
• Accessibility Standards for Customer Service, Ontario Regulation 429/07
• Ontario Human Rights Code
• TSHC Human Rights and Harassment Policy – Tenants
• TSHC Accessibility Policy
• TSHC Multi-year Accessibility Plan
• TSHC Tenant Complaint Procedure
• TSHC Accessibility Customer Service Policy Guidelines (to be reviewed)

Amendments (Revision History):

NA

Next Scheduled Review Date: 2025

This policy will be reviewed once every 5 years.

Policy Contact

Director, Strategy and Business Management

Selection and Appointment Process for Board Committee Membership and Committee Chair

(Approved by TSHC Board on August 3, 2023)

Selection and Appointment Process for Committee Members

1. The Board Chair will invite Board members to indicate their preferences in being a member of the three Committees and express their interest in serving on more than one Committee.
2. The Board Chair, in consultation with the Vice-Chair, shall take into account members’ preferences, areas of expertise and experience, and bring forward a recommendation on the Committee composition to the Board for approval.
3. The Terms of Reference for each Committee will also be considered, wherein for example Committee size and criteria for specific Committee membership are also articulated:

• Audit, Finance and Risk Committee Terms of Reference
• Quality and Tenant Engagement Committee Terms of Reference
• Corporate Governance and Human Resources Committee Terms of Reference

Selection and Appointment Process for Committee Chair

1. The Board Chair will invite Board members to express their interest in the Committee Chair position for the Committee(s) they are members of.
2. The Board Chair will meet with each candidate to ascertain interest and understand their qualifications and relevant experience. The Board Chair may canvas members who are not pursuing Committee Chair positions to obtain input.
3. The Board Chair, in consultation with the Vice-Chair, will recommend a nominee for each Committee Chair position and bring forward the recommendations to the Board for approval.

In nominating a member of the Board to serve as a Committee Chair, the following qualities should be considered:

• Proven breadth and depth of leadership experience;
• Willingness to dedicate sufficient time to Committee affairs during their term;
• Ability to chair a meeting in a way that is sensitive to group and individual dynamics with excellent facilitation skills;
• Ability to act impartially and without bias;
• Readiness to hold all Committee members accountable for their performance;
• Solid understanding of effective governance principles;
• Demonstrated commitment to diversity and inclusion;
• Effective communication skills.

Toronto Seniors Housing Corporation (TSHC)
Workplace Harassment Policy

Policy Sponsor: Director, People and Culture

Approver: Leadership Team

Initial Approval Date: May 18, 2022

Date of Last Revision, if applicable: February 7, 2024

Effective Date: February 7, 2024

Policy Statement

The Toronto Seniors Housing Corporation (TSHC) Workplace Harassment Policy outlines a transparent and consistent approach to be followed when a workplace harassment complaint is received.

Policy Objective(s)

Toronto Seniors Housing Corporation is committed to providing a work environment free of harassment in which all workers are treated with respect and dignity. In accordance with the Occupational Health and Safety Act, workplace harassment will not be tolerated from any person including tenants, other workers, supervisors, and members of the public.

Scope

This policy is in effect at all Toronto Seniors Housing Corporation Workplaces. Workers, contractors, tenants, visitors, volunteers, and persons engaged in business with Toronto Seniors Housing Corporation are expected to uphold this Policy.

Definitions

Workplace Harassment: engaging in a course of vexatious comment or conduct against a worker in a workplace that is known or ought reasonably to be known to be unwelcome.

Reasonable action taken by the employer or supervisor relating to the management and direction of workers or the workplace is not workplace harassment.

Workplace sexual harassment:

• engaging in a course of vexatious comment or conduct against a worker in a workplace because of sex, sexual orientation, gender identity or gender expression, where the course of comment or conduct is known or ought reasonably to be known to be unwelcome, or
• making a sexual solicitation or advance where the person making the solicitation or advance is in a position to confer, grant or deny a benefit or advancement to the worker and the person knows or ought reasonably to know that the solicitation or advance is unwelcome.

Roles and Responsibilities

Workers: are encouraged to report any incidents of workplace harassment  to the appropriate person. Workers may file a formal complaint of harassment in writing to People and Culture. If the complaint involves a member of the People and Culture team, the complaint should be directed to the Director, People and Culture or the Chief Executive Officer. If the complaint involves the Director, People and Culture the complaint should be directed to the Chief Executive Officer.

Management: will investigate and deal with all complaints of incidents of workplace harassment in a fair, respectful, and timely manner. Information provided about an incident or about a complaint will not be disclosed except as necessary to protect workers, to investigate the complaint or incident, to take corrective action, or otherwise as required by law.

Workers, contractors, tenants, visitors, volunteers, and persons engaged in business with Toronto Seniors Housing Corporation are expected to adhere to this policy and will be held responsible by the employer for not following. Workers are not to be penalized or disciplined for reporting an incident or for participating in an investigation involving workplace harassment.

If a worker needs further assistance, he or she may contact their union representative, Joint Health and Safety Committee representative, People and Culture Business Partner, or Employee and Family Assistance Program Provider.

Violation of this policy will result in appropriate remedial action, legal action, or disciplinary action up to and including immediate termination of employment for cause. In the case of a contractor or vendor, non-compliance can lead to termination of their contract.

Related Legislation, Regulations, and TSHC Policies:

• Occupational Health and Safety Act
• Ontario Human Rights Code
• Workplace Safety and Insurance Act
• Criminal Code of Canada
• Workplace Harassment Program (HSW1820)
• Workplace Violence Policy (HSW1800)
• Accident/Incident Reporting Procedure (HSW1500)
• Workplace Violence and Harassment Prevention and Crisis Resource Manual (HSW1806)
• Code of Conduct (Employees)
• Human Rights Policy (Staff)
• Human Rights Policy : Procedure for Staff Complaints
• Human Rights, Harassment, and Fair Access Policy – Tenants
• Tenant Representative Code of Conduct
• Accessibility Policy

Amendments (Revision History):

Initial policy approved by Corporate Governance and Human Resources Committee on May 18, 2022.

Policy reviewed on February 6, 2024 with the following revisions, approved by Leadership Team on February 6, 2024:

• Revision 1 – update of position titles and People and Culture department name.

Next Scheduled Review Date: February 1, 2025

This policy will be reviewed annually, or as often as necessary, to ensure it remains effective.

Policy Contact

Director, People and Culture

Toronto Seniors Housing Corporation (TSHC)
Workplace Violence Policy

Policy Sponsor: Director, People and Culture

Approver: Leadership Team

Initial Approval Date: May 18, 2022

Date of Last Revision, if applicable: February 7, 2024

Effective Date: February 7, 2024

Policy Statement

The Toronto Seniors Housing Corporation (TSHC) Workplace Violence Policy outlines a transparent and consistent approach to be followed when a workplace violence situation occurs.

Violence in the workplace is unacceptable from anyone. This policy is in effect at all Toronto Seniors Housing Corporation workplaces and applies to workers, contractors, tenants, visitors, volunteers, and persons engaged in business with Toronto Seniors Housing Corporation. Everyone is expected to uphold this policy and to work together to prevent workplace violence.

Policy Objective(s)

Toronto Seniors Housing Corporation is committed to providing a safe work environment and is ultimately responsible for workplace safety. In accordance with the Occupational Health and Safety Act workplace violence will not be tolerated. TSHC will take whatever steps are reasonable to protect our workers from workplace violence from all sources.

Scope

This policy is in effect at all Toronto Seniors Housing Corporation Workplaces. Workers, contractors, tenants, visitors, volunteers, and persons engaged in business with Toronto Seniors Housing Corporation are expected to uphold this Policy.

There is a workplace violence program that implements this policy. It includes measures and procedures to protect workers from workplace violence, a means of summoning immediate assistance and a process for workers to report incidents or raise concerns. The Program also includes measures for addressing domestic violence in the workplace and for communicating known risks of violence to workers.

Toronto Seniors Housing Corporation, as the employer, will ensure this policy and the supporting program are implemented and maintained. All workers and supervisors will receive appropriate information and instruction on the contents of the policy and program.

Definitions

Workplace violence means:

• The exercise of physical force by a person against a worker, in a workplace, that causes or could cause physical injury to the worker.
• An attempt to exercise physical force against a worker, in a workplace, that could cause physical injury to the worker.
• A statement or behaviour that it is reasonable for a worker to interpret as a threat to exercise physical force against the worker, in a workplace, that could cause physical injury to the worker.

Roles and Responsibilities

All workers, tenants, visitors and contractors are expected to refrain from violence or threats against workers of Toronto Seniors Housing Corporation and will adhere to this policy and supporting program.

Management: Management is responsible for ensuring that measures and procedures are followed by workers and that workers have the information they need to protect themselves.

Management pledges to investigate and deal with all incidents and complaints of workplace violence in a fair and timely manner, respecting the privacy of all concerned as much as possible. Reporting and investigation of workplace violence incidents must be conducted in accordance with Accident/Incident Reporting Procedure HSW1500.

Workers:  All workers are encouraged to raise any concerns about workplace violence and to report any violent incidents or threats to their supervisor.

Compliance and Monitoring

Violation of this Policy will result in appropriate remedial action, legal action, or disciplinary action up to and including immediate termination of employment for cause. In the case of a contractor or vendor, non-compliance can lead to termination of their contract.

Toronto Seniors Housing Corporation prohibits reprisals against persons who, in good faith, report incidents of workplace violence or who act as witnesses during investigations. Management will take all reasonable and practical measures to prevent reprisals or threats of reprisal.

Related Legislation, Regulations, and TSHC Policies:

• Occupational Health and Safety Act
• Workplace Safety and Insurance Act
• Criminal Code of Canada
• Workplace Violence Program (HSW1820)
• Accident/Incident Reporting Procedure (HSW1500)
• Workplace Violence and Harassment Prevention and Crisis Resource Manual (HSW1806)
• Code of Conduct (Employees)
• Tenant Representative Code of Conduct
• Working Alone Policy (HSW1801)
• Workplace Violence Risk Assessment and Control Evaluation Procedure (HSW1803)

Amendments (Revision History):

Initial policy approved by Corporate Governance and Human Resources Committee on May 18, 2022.

Policy reviewed on February 6, 2024 with the following revisions, approved by Leadership Team on February 6, 2024:

• Revision 1 – update of position titles and People and Culture department name.

Next Scheduled Review Date: February 1, 2025

This policy will be reviewed annually or as often as necessary to ensure that it remains effective.

Policy Contact

Director, People and Culture

Toronto Seniors Housing Corporation (TSHC)
Community Activities Fund Policy

Policy Sponsor: Director, Engagement, Partnership and Communications

Approver: Board of Directors

Initial Approval Date: December 8, 2023

Effective Date: April 1, 2024

Policy Statement

The Community Activities Fund Policy outlines how funds for tenant-led initiatives are allocated by the Toronto Seniors Housing Corporation (TSHC), with appropriate controls in place for oversight and accountability.

This Policy:

• Supports tenant-led activities and events within their communities.
• Specifies the criteria for initiatives that are eligible for funding.
• Outlines the standards that initiatives must meet to qualify for funding.

Scope

This Policy applies to all tenant communities and staff of TSHC. It outlines the activities that can be financially supported and explains the process of funding activities for tenants.

Out of Scope

This Policy does not apply to:

• Tenant expenses related to private events.
• Projects and events that are part of Community Programs and Partnerships’ tenant engagement work (e.g., refreshments for building meetings).
• Events that are exclusively faith-based.
• Events exclusively for members of a tenant association.

Implementing this policy should not only meet the requirements listed in the policy but also adhere to the corporation’s values of respect, inclusion, accountability, and innovation.

TSHC Values

• Respect – Our culture is built on respect, trust, and open, honest communication among tenants, staff, and service providers. We respect each tenant’s independence and privacy. We will assist tenants to find the services and supports they prefer.
• Inclusion – Quality of life for seniors is enhanced by living in vibrant and diverse communities. We strive for inclusion and equity.
• Accountability – We are accountable to our tenants, our shareholder (the City of Toronto), and the public. We are committed to transparency. We are clear on our goals. We set targets and report our results. We demonstrate integrity and responsible use of our resources.
• Innovation – We are creative, innovative, adaptive, and flexible to meet the needs of our current and future tenants. We are a catalyst for positive change, energizing communities and partners to join us to achieve our mandate.

Definitions

• Building: A structure that is designed and constructed to provide living spaces for individuals or families to use as their home.
• CAF (Community Activities Fund) Coordination Table: Members of this group will include Regional Managers, the Manager of Community Programs and Partnerships, and the Community Programs and Partnerships Clerk. The group will ensure that funds are managed and distributed equitably and timely across all buildings based on applications from all regions.
• Community Activities Fund (CAF): Funds set aside by TSHC for events or activities to bring tenants together and purchase supplies and smaller equipment that can be enjoyed in shared spaces.
• Community: Tenants belonging to a TSHC building or adjacent TSHC developments.
• Community Services Coordinators (CSCs): The Community Services Coordinator is a frontline member of the Community Programs and Partnerships team. They assist in developing and managing programs and partnerships, community and tenant engagement, and support TSHC’s efforts to build strong and vibrant communities.
• Event(s): A one-time or re-occurring activity that is open to all tenants within a given community.
• Larger Equipment: A tangible long-term asset that benefits the broader tenant community (e.g., exercise machines and recreational equipment such as pool tables). Equipment must have a minimum lifespan of two years and come at a price of $1,500 or more.
• Quarter: A quarter (calendar) is a calendar that breaks the year into four parts. Each part is three months. It helps to remember important dates and plan events. It is used to plan budgets and goals and manage time. For example, the year’s first quarter includes January, February, and March. The second quarter includes April, May, and June. The third quarter includes July, August, and September. The fourth quarter includes October, November, and December.
• Smaller Equipment: Materials, items, supplies, or equipment needed to implement community programs or activities.
• Tenant: A person who holds a residential lease agreement with Toronto Seniors Housing Corporation or a Toronto Seniors Housing Corporation-approved sub-landlord and lives in a Toronto Seniors Housing Corporation building.

Standards

• Community Activities Fund (CAF) initiatives must be identified at the building’s priority-setting meeting each year.
• The Community Services Coordinators (CSCs) are required to support an Annual Building Planning Process with tenants including priority-setting meetings at buildings at the beginning and where required throughout the year to help tenants throughout the CAF application.
• All equipment purchased through CAF is the property of TSHC.
• All events that are funded by the CAF budget must be accessible to all tenants in a given building/community.
• All tenants (over 15,000) will have an opportunity to participate in the decision-making process for activities, events, and equipment through the Annual Building Planning Process, to be within the CAF funds allocated to each building.

Community Activities Fund (CAF)

The Community Activities Fund Policy outlines how funds for tenant-led initiatives are allocated by the Toronto Seniors Housing Corporation. Every year, funding will be allocated to each building based on its size. All tenants will be encouraged to participate in a building meeting to set priorities. With staff support, tenants will decide on the events, activities, and equipment they want to have at their building for the coming year. Applicants must submit a form to TSHC to proceed with an event. If funds are still available mid-year (July), the Community Programs and Partnerships team will inform tenants of surpluses. All tenants in the buildings will be able to apply for extra funding if they are available. The deadline for submitting applications to use the remaining funds for the year is September 30.

Eligibility Criteria for CAF

TSHC tenants can request funds for initiatives that foster community development. Such initiatives include tenant-led activities and events that enhance tenant participation in their communities.

At the start of the year, the Community Services Coordinators (CSCs) will host an annual building meeting as part of the Annual Building Planning Process. Building tenants will be encouraged to gather and discuss the events, activities, and equipment they would like to have in their building for the upcoming year. Once priorities are set, the CSCs will work with the tenants present at the meeting to complete the application forms. Adjustments may be required throughout the year; CSCs will work with local volunteers to understand those, noting that volunteers will need to ensure that all tenants have had an opportunity to have input into the additional or new choices. Additional meetings with tenants will be undertaken as well if required.

Applications should be submitted for the current calendar year based on the submission deadlines listed in the Procedures document. Tenants must submit their applications no later than one month before the event or before the quarterly submission deadline, whichever comes first, as per the Procedures document. For example, if a tenant plans to organize an activity on April 15, they will need to submit the application before March 15 of the calendar year. All funding is managed annually. Funding for next year’s events will come from that year’s CAF allocation for each building. Tenants will need to work with their local CSCs. If there is a tenant volunteer or volunteers in a building, they should be made aware of the application.

Eligible Expenses through CAF Funding

• Smaller equipment that supports social recreational programming and enhancing community (e.g., gaming supplies, craft supplies)
• Food/refreshments for community events and re-occurring community gatherings (e.g., monthly social tea, BBQs)
• Event-related supplies (e.g., cutlery, trolleys or serving platters)
• Audio-visual supplies and smaller equipment for recreational room activities (e.g., microphone, projector)
• Tools and gardening supplies (for products related to food supply)
• Decorative items and seasonal décor
• Recreational smaller equipment (e.g., mahjong tables, foosball tables, and ping pong tables)

Ineligible Expenses through CAF Funding

• Alcohol or gifts
• Supplies or equipment which are for private use
• Items that are not accessible to the wider community (e.g., video game consoles)
• Duplicating items which can be provided by partner agencies or TSHC staff (e.g., mop, bucket, vacuum cleaner)
• Gardening products (e.g., soil, seeds, and plants for ornamental gardens as Operations will be funding these based on approved annual budgets)
• Costs to maintain activities beyond the funding term
• Items for events outside the building premises
• Larger equipment that exceeds $1500 and has a life span of two years or more (e.g. pool table, larger exercise equipment/treadmill which can be funded through the Operations team)

Allocation and Oversight for CAF

The CAF Coordination Group oversees the global budget for use of CAF funds. As such they are responsible for ensuring that funds are well managed and provided in a timely manner to all buildings based on applications from all regions. This administrative table approves all CAF requests to ensure Procurement and Finance and the Community Activities Fund policies are being followed.

Equity Impact Statement

Toronto Seniors Housing Corporation is committed to providing an inclusive living environment free of discrimination and harassment consistent with principles outlined in the Ontario Human Rights Code, and the Accessibility for Ontarians with Disabilities Act.

The Community Activities Fund is there to help tenant communities meet their unique equity needs, taking into account their diverse linguistic and cultural backgrounds. Tenants may use these funds for language or cultural events but must invite all building tenants to participate. If food is served at a CAF event, organizers must provide options that cater to various cultural dietary restrictions.

Conflict of Interest

A conflict of interest occurs when personal or business interests affect a tenant’s ability to fairly and objectively represent the best interests of all tenants. The interest may benefit the tenant, family, friends, or a business enterprise with which the tenant is associated.
Tenants:

• Should avoid using paid services from friends or family members.
• Must use a trusted, reputable vendor.
• Must not use Toronto Seniors Housing Corporation materials or facilities for personal gain. For example, renting out Toronto Seniors Housing Corporation office space or equipment or using Toronto Seniors Housing Corporation office space for own business or commercial activities is not allowed. (Personal gain also means gains for a family member or a friend).

Other

• For TSHC to fund events organized through CAF, all events must be fully accessible to tenants. Tenants cannot charge an additional fee for the event.
• Gratuities (tips) for any vendor must be included within the event budget and cannot exceed 15 per cent of the total invoice.

Compliance and Monitoring

The Community Programs and Partnerships team at TSHC will maintain clear and transparent records of all applications, decisions, delivery of goods, and reconciliation of funds for the projects.

The CAF Coordination Group will ensure that the funding spent on approved CAF requests follows TSHC’s policies, procedures, and guidelines and the building’s priorities.

The Finance team will review the annual reconciliation and will conduct random audits of the submissions to confirm compliance with this Policy. The CAF Coordination Group will provide the Finance Department with quarterly reporting on CAF submissions.

Related Legislation, Regulations, and TSHC Policies:

• TSHC Expense Reimbursement Policy
• TSHC Human Rights, Harassment and Fair Access Policy – Tenants
• TSHC Tenant Representative Code of Conduct
• TSHC Non-Residential Use of Space for Tenants and Tenant-Led Groups Policy

Amendments (Revision History):

Initial policy approved by Board of Directors on December 8, 2023, effective April 1, 2024.

This Policy replaces the former Tenant Funds Distribution Policy to be retired on April 1, 2024, and the Distribution of Tenant Council Funds Policy to be retired on December 31, 2023.

Next Scheduled Review Date: December 2026

This policy will be reviewed once every three (3) years.

Policy Contact

Manager, Community Programs and Partnerships

Appendices

Community Activities Fund Procedure

Toronto Seniors Housing Corporation (TSHC)
Eviction Prevention Policy for Non-payment of Rent (Arrears)

Policy Sponsor: Director, Operations

Approver: Board of Directors

Initial Approval Date: April 28, 2022

Effective Date: June 1, 2022

Policy Statement

This is a policy on eviction prevention related to the non-payment of rent. Tenants are responsible for paying their full rent on the first of every month and reporting changes in income or household composition so that their rent is calculated properly.

Toronto Seniors Housing Corporation is committed to working with tenants so that they meet these responsibilities and, wherever possible, prevent tenants from losing their housing.

Toronto Seniors Housing Corporation will work with tenants and external supports or service agencies where possible, to keep tenants housed and to ensure that rent is paid and eviction is the very last resort.

The policy is established within the context of the Shareholder Direction from the City of Toronto, the Housing Services Act, 2012 and the Residential Tenancies Act 2006.

Policy Objective

The purpose of the policy is to ensure rent is collected as required and to evict as few tenants as possible for not paying their rent.

Scope

This policy applies to:

• the non-payment of rent;
• all residential tenants in TSHC managed buildings, including rent-geared-to-income (RGI), affordable housing and market tenants.

Out of Scope

Tenants can be evicted for other reasons. These are described in a separate policy: TSHC Evictions for Cause Policy.

Values

Toronto Seniors Housing Corporation is committed to supporting successful tenancies and ensuring that tenants meet their rental responsibilities. We will:

• recognize tenants as responsible and able participants in maintaining their own tenancy and paying their rent;
• work with tenants to try to identify solutions, recognizing that tenants sometimes face barriers to maintaining their tenancy through lack of support or access to services;
• ensure all procedures regarding tenancies at risk are fair, open and equitable (procedural fairness);
• recognize the right of each individual to be treated fairly, with respect and without discrimination;
• collect rent on time, because lost revenue means there is less money for building maintenance and other services for all tenants.

Standards

• Tenants must pay their rent each month. Eviction prevention cannot be an incentive not to pay rent on time and in full.
• Staff are required to make a minimum of three (3) documented attempts to make personal contact with the tenant or one successful contact before filing an Application to Evict a Tenant for Non-payment of Rent and to Collect Rent the Tenant Owes (L1) at the Landlord and Tenant Board.
• At least one reasonable and accessible opportunity for a face- to-face meeting must be given to the tenant during the eviction process.
• Efforts and results of communications with tenants during the eviction process will be documented.
• Clear information on how rent is calculated and rental account status will be made available to tenants.
• A fair and transparent process will be available to tenants for review of RGI decisions and calculations, by a person or a panel independent from the original decision maker.
• Notices to evict will include information on the supports available to tenants to help them pay their rent, including information about local legal clinics.
• Tenants will be informed of the services offered at the Landlord and Tenant Board including mediation, duty counsel and interpretation services if applicable.
• Tenants who are evicted by the Sheriff will be informed of services offered by external organizations to assist them in finding other accommodation and support.

Policy Details

Many people living in Toronto Seniors Housing Corporation have nowhere else to go for secure, permanent housing. At times, some tenants will have trouble paying rent. Toronto Seniors Housing Corporation recognizes this and tries to prevent tenants from losing their housing because of unpaid rent.

The primary strategy for eviction prevention is effective rent collection. Efforts to collect rent and to support tenants facing eviction will continue after an order to evict has been issued by the Landlord and Tenant Board and up to the point where the unit is being re-rented.

Eviction Prevention Strategies

Staff have the flexibility and discretion to choose appropriate strategies for different situations.

Rent Collection

• Focus on collecting the rent on time.
• Provide a range of flexible rent payment options.
• Inform tenants about steps to take if they are unable to pay rent, and offer to help tenants develop plans for staying housed.
• Negotiate reasonable repayment agreements that best fits the tenant’s circumstances.
• Explain that tenants are required to indicate changes in income and household composition promptly so that rent calculation is based on the most up to date information.

Education

• Educate tenants about their rights and responsibilities and about the Eviction Prevention Policy at lease signing, at regular intervals, and when they are having trouble paying their rent.
• Train staff in eviction prevention strategies when they are hired and at regular intervals.

Communication

• Communicate directly with tenants at key stages before issues escalate, and document all attempts to communicate.
• Communicate in a timely fashion and in plain, clear, respectful language.
• Ensure documents related to eviction prevention adhere to our standards of translation and interpretation. Make staff available to talk to tenants in confidence about their situation.

Early Intervention

• Identify households that appear to be vulnerable or at a higher risk of eviction, during our interactions with tenants (e.g. unit inspections, annual rent review process).
• Monitor households that appear to be vulnerable or at a higher risk of eviction and respond accordingly.
• Intervene early when rent payment is late to help prevent tenants from falling further into arrears.

Partnerships and Referrals

• Develop partnerships with organizations that can provide supports to tenants.
• Inform tenants about, and connect them to, external organizations and community agencies that can help them maintain a successful tenancy.

Compliance and Monitoring

To ensure compliance:

• Toronto Seniors Housing Corporation will verify compliance on every file that proceeds to the Landlord and Tenant Board and will conduct random audits.
• Operational performance related to the range of eviction prevention strategies and rent collection practices will be monitored and gaps will be identified for further action.
• Eviction prevention performance reports will be submitted to the Board quarterly.

Related Legislation, Regulations, and TSHC Policies

• Residential Tenancies Act
• Housing Services Act
• Municipal Freedom of Information and Protection of Privacy Act
• Ontario Human Rights Code
• TSHC Human Rights, Harassment & Fair Access Policy – Tenants

Amendments (Revision History):

Initial policy approved by Board of Directors on April 28, 2022, effective June 1, 2022.

Next Scheduled Review Date: 2025

This policy will be reviewed once every three years.

Policy Contact

Manager, Business Operations and Compliance

Appendices

Arrears Collection Process

Toronto Seniors Housing Corporation (TSHC)
Evictions for Cause Policy

Policy Sponsor: Director, Operations

Approver: Board of Directors

Initial Approval Date: April 28, 2022

Effective Date: June 1, 2022

Policy Statement

Toronto Seniors Housing Corporation is committed to promoting successful tenancies while making sure that tenants can live together in strong, safe, and healthy communities.

The Eviction for Cause Policy outlines Toronto Seniors Housing Corporation’s approach and guides decision-making when individual behaviours impact others in Toronto Seniors Housing Corporation communities and are grounds for eviction for cause under the Residential Tenancies Act, 2006 (the RTA).

In implementing this policy, Toronto Seniors Housing Corporation is committed to making sure that individual rights under the Ontario Human Rights Code (the “Code”) are upheld, and that all tenants can live together in strong, safe, and healthy communities.

Toronto Seniors Housing Corporation will manage all tenancies in accordance with:

• The RTA;
• The Ontario Human Rights Code;
• Terms of the tenancy agreement (the “Lease”); and
• Toronto Seniors Housing Corporation policies, procedures, standards and protocols including but not limited to:
  • Human Rights, Harassment and Fair Access Policy – Tenants;
  • The established tenant complaint process.

While Toronto Seniors Housing Corporation recognizes the gravity and impact of eviction, it is prepared to pursue eviction when the legal grounds for eviction exist and the problem cannot be resolved in the interest of the community without pursuing eviction.

Policy Objective

The goal of the policy is to promote successful tenancies while maintaining safe and harmonious communities.

As a landlord, Toronto Seniors Housing Corporation is responsible for ensuring the maintenance and repair of buildings it manages is completed, and does not interfere with the rights of tenants as defined by the RTA.

The policy outlines principles and standards Toronto Seniors Housing Corporation will use to deal with actions and behaviours that result in tenants not complying with their responsibilities, interfere with the rights of other tenants or the landlord, or undermine community safety.

Scope

This policy applies to all residential tenants directly managed by Toronto Seniors Housing Corporation, including rent-geared-to-income (RGI), affordable housing and market tenants. It also applies to occupants, visitors, and guests insofar as tenants are responsible for the conduct of all occupants, guests, and visitors who they invite onto the residential complex^[1].

The policy is concerned with behaviours that could lead to eviction under the RTA and applies to the following stipulated causes for eviction:

• substantial interference with reasonable enjoyment or with other rights, interests or privileges;
• damage to property;
• impairment of safety;
• fraud and misrepresentation of income;
• illegal sublet unauthorized occupancy;
• ending the tenancy and/or relocation for demolition, conversion, repairs or sale of the property;
• illegal acts.

Out of Scope

This policy does not apply to the following:

• arrears; or
• ceasing to qualify for social housing.

Definitions

Guests: Persons who require temporary accommodation with a tenant (guests do sleep in the tenant’s unit but only for a maximum of 30 days within any 12-month period unless under the special circumstances as defined by the Visitor and Guest Policy and approved by TSHC). Guests are not part of the tenant’s household. Guests maintain a home address outside the tenant’s unit.

Occupants: For Rent-Geared-to-Income (RGI) tenancies, an occupant is a person who is a declared member of an RGI household, who has been added to the household with Toronto Seniors Housing Corporation’s consent, but who has not signed a lease with Toronto Seniors Housing Corporation.

For market rent tenancies, an occupant is a person who has been added to a market household, with Toronto Seniors Housing Corporation’s consent, but has not signed the lease, or an undeclared person who is living in a market rent unit together with the tenant.

Occupants have no right to live in the tenant’s unit once the tenant moves out.

Tenants: Persons who have signed a lease and have all tenant rights and responsibilities related to the tenancy.

Visitors: Persons who visit a tenant and do not require temporary accommodation with the tenant.

Visitors are not part of the tenant’s household. Visitors maintain a home address outside the tenant’s unit.

Values

Toronto Seniors Housing Corporation, its staff and tenants are committed to promoting successful tenancies while maintaining harmonious, safe, healthy and livable communities.

In making decisions about evictions for cause, we will:

• recognize the right of each individual to be treated fairly, with respect and without discrimination. Toronto Seniors Housing Corporation will not accept harassment or discrimination towards any tenant, or employee;
• recognize tenants as responsible and able participants in maintaining their own successful tenancy and healthy communities;
• recognize that some tenants may face barriers in maintaining a successful tenancy as the result of vulnerabilities, including but not limited to mental health issues, or disabilities. We will abide by our duty to accommodate under the Ontario Human Rights Code;
• make decisions based on what we believe to be reliable information; full and fair consideration of complaints; objective assessment of the facts; and, judgment of what will best solve the issue for the community.

Standards

Toronto Seniors Housing Corporation will:

1. use sufficient, relevant and objective facts to support decisions in the eviction process;
2. discuss the situation with the tenant prior to making an application to evict with the Landlord and Tenant Board. Sometimes it is not reasonably possible or appropriate to meet with the tenant. In these cases, clear documentation of the circumstances is required;
3. issue only the appropriate notices of termination, which clearly describe for the tenant the conduct and legal grounds that justify the notice;
4. inform tenants of the services offered through legal aid clinics as well as the need for translation services upon Toronto Seniors Housing Corporation issuing a Notice to Terminate a Tenancy; and,
5. ensure that, where an order to terminate a tenancy has been issued by the Landlord and Tenant Board, tenants are sent information on supports that may be available to them including information about shelters.

Toronto Seniors Housing Corporation will not pursue evictions for complaints or incidents that occurred more than three (3) years earlier unless there are extremely compelling reasons to do so such as:

• the incident is part of a pattern of behaviour that continues to impact the community;
• similar or related incidents have occurred since the original incident;
• Toronto Seniors Housing Corporation was not aware of the incident and it has the potential to seriously impact the community; or,
• other reasons set out in the procedures.

 Policy Details

Toronto Seniors Housing Corporation handles incidents that could lead to eviction in a balanced manner, taking into consideration the specific fact situation; a tenant’s individual circumstances; Toronto Seniors Housing Corporation’s responsibilities to all tenants and staff; and, Toronto Seniors Housing Corporation’s responsibility to respect human rights, procedural fairness and transparency.

A Balanced Approach

Apply a balanced approach to maintaining harmonious healthy communities as well as individual tenancies – the key consideration is what will best solve the problem for the community.

Use a problem-solving approach, including alternative resolution methods, giving the tenant an opportunity to correct the problem and negotiating agreements where appropriate.

Facilitate separate third party support services when a tenant faces barriers or difficulties maintaining their own successful tenancy and healthy communities.

Fair Review and Resolution

Toronto Seniors Housing Corporation will ensure that complaints are addressed and investigated in a consistent, fair and timely manner to reduce escalation.

When a tenant does not abide by the terms of the lease, and/or the RTA, Toronto Seniors Housing Corporation will provide and communicate clear, enforceable and progressive consequences that reflect the severity and persistence of the behaviour.

Circumstances Warranting Eviction

While Toronto Seniors Housing Corporation recognizes the seriousness of eviction and the impact it can have on some tenants for whom Toronto Seniors Housing Corporation is the only source of secure permanent housing, we will pursue eviction when:

• despite all efforts to resolve the problem, the actions of a tenant, household, pet, guest or occupant continue to negatively impact tenants, staff or the community, and the circumstances constitute grounds for eviction under the RTA;
• eviction may be pursued immediately in very serious situations, generally involving serious impairment of safety or serious criminal activity.

Compliance and Monitoring

Toronto Seniors Housing Corporation will:

• develop and maintain procedures to assist staff in interpreting and applying this policy;
• ensure clear documentation practices are in place;
• monitor the effectiveness of this policy in responding to and reducing incidents and behaviours that negatively impact the health of communities; and,
• provide quarterly reports to the Board on eviction rates.

Related Legislation, Regulations, and TSHC Policies:

• Residential Tenancies Act, 2006
• Housing Services Act, 2012
• Municipal Freedom of Information and Protection of Privacy Act
• Ontario Human Rights Code
• TSHC Guide to Contacting Tenants, Documentation and Record Keeping
• TSHC Human Rights, Harassment and Fair Access Policy – Tenants
• TSHC Tenant Complaint Process
• TSHC Visitor and Guest Policy

Amendments (Revision History):

Initial policy approved by Board of Directors on April 28, 2022, effective June 1, 2022.

Next Scheduled Review Date: 2025

This policy will be reviewed once every three years.

Policy Contact

Manager, Business Operations and Compliance

Appendices

• TSHC Evictions for Cause Procedures (under review)

^[1] The tenant is also responsible for the conduct of any visitor or guest that an occupant of their unit has invited onto the residential complex.

Toronto Seniors Housing Corporation (TSHC)
Visitor and Guest Policy

Policy Sponsor: Director, Operations

Approver: Board of Directors

Initial Approval Date: April 28, 2022

Effective Date: June 1, 2022

Policy Statement

This policy explains the way Toronto Seniors Housing Corporation will manage visitors and guests of all Toronto Seniors Housing Corporation tenants. Tenants may have visitors or guests in their homes. Toronto Seniors Housing Corporation and other social housing providers know that from time to time tenants may have guests who stay with them in their homes for a number of days at a time. These might include out-of-town guests, or persons who tenants have personal relationships with and are not part of their households.

 A tenant may have a guest in their home for a maximum of 30 days, in total, within a 12-month period. The 30 days may be consecutive or non-consecutive days and applies to any one individual that stays in the tenant’s unit. In special cases, as defined below, guests may stay in a unit longer than 30 days.

Tenants are responsible for the actions and behaviours of anyone that they invite onto the residential complex including their visitors and guests.

This policy defines Toronto Seniors Housing Corporation’s practice for dealing with visitors and guests. It supports Toronto Seniors Housing Corporation’s commitment to equitable and quality service and meets legislative requirements.

Policy Objectives

The purpose of this policy is to make sure that all tenants understand their responsibilities related to visitors and guests, and for Toronto Seniors Housing Corporation to meet the following objectives:

• explain when a person is considered a visitor or a guest;
• explain when a market rent household is required to inform Toronto Seniors Housing Corporation of changes to their household composition as required by this policy;
• explain when a rent-geared-to-income household is required to inform Toronto Seniors Housing Corporation of changes to their household composition as required by this policy;
• establish the maximum length of time tenants can have guests;
• establish exceptions to the maximum permitted time for guests;
• balance the tenant’s right to use their home and Toronto Seniors Housing Corporation’s requirement to assess household eligibility for housing;
• make sure that subsidies are based on the true household income, including anyone who moves into the unit;
• help to make sure that subsidies are available to households that qualify; and
• ensure that residential units are not improperly transferred or

Scope

This policy applies residents in Toronto Seniors Housing Corporation households.

Out of Scope

Live-in caregivers are not covered by the scope of this policy. If a member of a household requires a live-in caregiver, the tenant must make the request in writing to have the live-in caregiver stay in their unit through their Regional office.

Definitions

Guests: Persons who require temporary accommodation with a tenant (guests do sleep in the tenant’s unit, but only for a maximum of 30 days within any 12-month period unless they are a special case as defined below). Guests are not part of the tenant’s household. Guests maintain a home address outside the tenant’s unit.

Live-in caregivers: Persons who provide support services needed because of a household member’s disability or medical condition. They are not considered tenants, visitors or guests.

Occupants: For rent-geared-to-income tenancies, an occupant is a person who is a declared member of a rent-geared-to-income household, who has been added to the household with Toronto Seniors Housing Corporation’s consent, but who has not signed a lease with Toronto Seniors Housing Corporation. For market rent tenancies, an occupant is a person who has been added to a market household, with Toronto Seniors Housing Corporation’s consent, but has not signed the lease, or an undeclared person who is living in a market rent unit together with the tenant.

Occupants have no right to live in the tenant’s unit once the tenant moves out.

Tenants: Persons who have signed a lease and have all tenant rights and responsibilities related to the tenancy [1].

Toronto Seniors Housing Corporation staff: This includes, but is not limited to, all Toronto Seniors Housing Staff.

Unauthorized occupants: Any person who is not a tenant, occupant, visitor, guest, or live-in caregiver as defined by this policy. An unauthorized occupant has no lawful authority to be at a Toronto Seniors Housing Corporation residential complex and has no rights to the rental unit in question.

Visitors: Persons who visit a tenant and do not require temporary accommodation with the tenant (visitors do not sleep in the tenant’s unit). Visitors are not part of the tenant’s household. Visitors maintain a home address outside the tenant’s unit.

Roles and Responsibilities

Toronto Seniors Housing Corporation staff are responsible for:

• investigating cases where tenants appear to have guests staying with them for more than 30

Tenants are responsible for:

• the actions and behaviours of their occupants, visitors and guests;
• telling their guests and visitors that they may be asked to prove that they have a home address outside of the unit they are visiting;
• reporting a person that they wish to add to their household composition as outlined in the Addition to Household Composition Directive; and
• complying with this

Policy Content

Visitors

Visitors may come to the unit as often as the tenant invites them. Frequent visitors may be asked to prove that they have a home address outside of the unit they are visiting. Tenants are responsible for telling all visitors about this rule.

Guests

Tenants may have a guest stay in their unit for a maximum of 30 days in total, within a 12-month period and are encouraged to report to Toronto Seniors Housing Corporation all persons staying in the unit for safety and emergency purposes.

Guest who stays longer than 30 days – special cases

If Toronto Seniors Housing Corporation staff receive information that a person has been staying in a tenant’s unit longer than 30 days, Toronto Seniors Housing Corporation staff will investigate and request documentation from the tenant explaining the reason for the stay and information about how long the person is staying to ensure that the person qualifies as a special case guest.

Special cases where a guest may stay longer than 30 days might include, but are not limited to:

• an accommodation-related issue as defined in Toronto Seniors Housing Corporation’s Human Rights, Harassment and Fair Access Policy – Tenants and the Ontario Human Rights Code, such as the need for someone to provide short-term supportive care to a person with a disability as prescribed by a qualified licensed healthcare professional; or
• the guest lives outside the country and has travel documents to prove their planned return date and leaves on that

Additional detail about special cases is provided in the Visitor and Guest Policy Guideline.

Limitations to stays longer than 30 days

In all cases other than the special cases outline above, Toronto Seniors Housing Corporation will decline to allow the person to stay with the tenant.

Toronto Seniors Housing Corporation staff may determine a situation is not a special case and a guest is not allowed to stay longer than 30 days for the following reasons including, but not limited to:

• the tenant does not provide appropriate documentation as outlined in the Visitor and Guest Policy Guideline to explain why the guest needs to stay longer than 30 days;
• the guest does not intend to leave at the end of the agreed-to term;
• staff or tenants have complained about the guest’s behaviour, and Toronto Seniors Housing Corporation is satisfied the complaints are well founded; and
• the guest(s)’ stay would result in non-compliance with Occupancy Standards under the Toronto Municipal Code Property Standard [2].

Any person located in a residential unit who is not a tenant, occupant, visitor, guest, or live-in caregiver as defined by this policy is an unauthorized occupant and has no lawful right to be on the premises.

Unreported stay

If a person remains longer than 30 days in breach of this policy, Toronto Seniors Housing Corporation may pursue any legal rights available to it including, but not limited to:

• possible termination of subsidy if it is a rent-geared-to-income household due to failure to notify the landlord of changes in household composition as required by the Housing Services Act, 2011;
• enforcement of any rights available to Toronto Seniors Housing Corporation under the Trespass to Property Act against the unauthorized occupant; and
• any action against the tenancy available to Toronto Seniors Housing Corporation.

If a rent-geared-to-income household loses their subsidy, they will have to pay the market rent for the unit and will no longer qualify for a rent-geared-to-income subsidy. The tenant has the right to request a review of decisions related to their continued eligibility for rental subsidy.

Rights to unit

If the tenant moves out of the unit, all other persons in the unit must also leave. Any occupant, guest, visitor, live-in caregiver, unauthorized occupant, or anyone else found in the unit after the tenant moves out will be:

• ineligible for receipt of the household’s rent-geared-to-income subsidy; and
• identified as

Toronto Seniors Housing Corporation will reclaim the unit.

Market rent households

A market rent tenant:

• may allow a guest to stay in their rental unit. The market rent tenant may not, however, assign or sublet all or any part of the unit [3]
• is required by their lease to report any changes in household composition within 30 days of the change;
• may request to add another tenant to their unit and sign a new lease;
• should report all persons living in the unit even if the tenant does not wish to add the proposed person to their lease as a tenant. It is essential for safety and emergency purposes that Toronto Seniors Housing Corporation knows who lives in its units. Occupants do not have any legal rights or entitlements to a tenant’s

Compliance and Monitoring

The Regional Manager, or designate, will monitor compliance with the policy on an ongoing basis by reviewing a random sampling of tenant files.

Frequency of incidents involving unauthorized occupants will be monitored via reports to the fraud and waste hotline and complaints entered into the HoMES system.

Related Legislation, Regulations, and TSHC Policies:

• Housing Services Act, 2011
• Municipal Freedom of Information and Protection of Privacy Act, 1990
• City of Toronto Occupancy Standards
• Ontario Human Rights Code
• Residential Tenancies Act, 2006
• Trespass to Property Act, 1990
• TSHC Addition to Household Composition Directive
• TSHC Human Rights, Harassment and Fair Access Policy – Tenants
• TSHC Evictions for Cause Policy
• TSHC Tenant Charter

Amendments (Revision History):

Initial policy approved by Board of Directors on April 28, 2022, effective June 1, 2022.

Next Scheduled Review Date: 2027

This policy will be reviewed once every five years.

Policy Contact

Manager, Business Operations and Compliance

Appendices

• Visitor and Guest Policy Agreement

[1] In certain circumstances, as defined by the Residential Tenancies Act, the spouse of a tenant may become a tenant when the tenant dies or vacates the unit. This provision does not apply to some or all of Toronto Seniors Housing Corporation’s rental units. Anyone faced with this situation must speak with their Regional Manager.

[2] CHAPTER 629-25, Occupancy Standards, Toronto Municipal Code Property Standard:

“The maximum number of persons living in a habitable room shall not exceed one person for each nine square metres (96.8 sq. ft.) of habitable room floor area.”

“The minimum floor area of a room used by two or more persons for sleeping shall be four square metres (43 sq. ft.) for each person using the room.”

http://www.toronto.ca/legdocs/municode/1184_629.pdf

[3] Toronto Seniors Housing Corporation reserves the right to take any legal action available against a tenant who has illegally sublet or assigned their tenancy, and reserves the right to take legal action in relation to unauthorized occupancy of a rental unit.

[4] Toronto Seniors Housing Corporation reserves the right to refuse to enter into any tenancy in accordance with its normal leasing practices.

Toronto Seniors Housing Corporation (TSHC)
Relocation Policy

Policy Sponsor: Director, Operations

Approver: Board of Directors

Initial Approval Date: April 28, 2022

Effective Date: June 1, 2022

Policy Statement

Toronto Seniors Housing Corporation (TSHC) is committed to promoting healthy communities and quality of life for tenants. Toronto Seniors Housing Corporation recognizes that relocation may cause hardships for those directly affected and the community.

The purpose of the policy is to minimize the adverse effects of relocation on tenants facing displacement from a TSHC unit, with a goal of tenants being able to continue their life in a Relocation Unit with minimal disruption. This policy provides the framework to govern the relocation of households.

Scope

This policy applies to all residential tenants directly managed by Toronto Seniors Housing Corporation, including rent-geared-to-income, affordable, and market tenants that are required to move out of their units because TSHC needs possession of their unit for any of the following reasons:

• revitalization;
• renovation;
• permanent unit closures;
• emergency situations;
• accessibility upgrades; and
• any other reason that Toronto Seniors Housing Corporation requires a household to transfer from one Toronto Seniors Housing Corporation unit to another.

The Relocation Policy will cover all situations where Toronto Seniors Housing Corporation initiates relocating a current Toronto Seniors Housing Corporation household to a different Toronto Seniors Housing Corporation unit, except in instances of a fire in a unit or building. Reasons for relocation will be limited to the categories defined within the Relocation Policy and in compliance with relevant legislation.

Out of Scope

Tenant-initiated requests for transfer are addressed in Toronto Seniors Housing Corporation’s Tenant Transfer Policy.

Definitions

Accessibility Upgrades: Where a tenant’s unit is undergoing planned accessibility upgrades to accommodate their accessibility needs and it is not possible for them to remain in the unit while the work is taking place.

Emergency Situations: Where an emergency takes place in a unit or building (such as flood, emergency roof repairs, etc.) and occupying the unit would pose an immediate risk to tenants’ health or life safety, and major unplanned rehabilitation is required in the unit or building.

Large-Scale Renovation: Major planned repairs to a unit or building where a household’s unit must be vacant in order for the work to take place.

Permanent Relocation: Where a tenant is required to relocate from their unit and will not return to the same unit.

Permanent Unit Closure: Where units or buildings have deteriorated into a critical state of repair and must be closed because they are no longer safe for tenants to live in, where a building is repurposed for another use, or any other reason that requires a unit be closed.

Relocation Agreement: A written contract between tenants and Toronto Seniors Housing Corporation, which outlines the rights and obligations of both parties during the relocation process.

Relocation Unit: The unit a household is moved to when they must be relocated from their current unit.

Revitalization: The large-scale demolition and rebuild of multiple Toronto Seniors Housing Corporation-managed buildings in one community to elevate the housing conditions and circumstances for tenants.

Right to Return: Tenants who are moved due to revitalization have the right to return to a new unit in a revitalized community, subject to eligibility rules in the Relocation Agreement it signs with Toronto Seniors Housing Corporation.

Temporary Relocation: A temporary move between Toronto Seniors Housing Corporation units initiated by Toronto Seniors Housing Corporation where the household must return to their original unit.

Temporary Shelter Agreement: A written agreement between a household and Toronto Seniors Housing Corporation that outlines the rights and obligations of both parties during a temporary relocation. This only applies to relocation due to accessibility upgrades.

Tenancy in Good Standing: A household is in good standing if:

• none of the members of the household owe money to Toronto Seniors Housing Corporation in relation to a current or former tenancy or if any member of the household does owe money, they have entered into a repayment agreement with Toronto Seniors Housing Corporation and are in compliance with that agreement;
• Toronto Seniors Housing Corporation is not currently taking legal action against the household for any reason; and
• the Landlord and Tenant Board has not ordered termination of the tenancy.

Tenant Relocation Assistance Implementation Plan (TRAIP): A document that sets out the steps that Toronto Seniors Housing Corporation will take to support tenants to relocate units and what tenants can expect from Toronto Seniors Housing Corporation during the moving process such as notice periods, any financial assistance, and other supports to assist with moving.

Standards

Standards Applied to All Relocations

Toronto Seniors Housing Corporation may initiate the relocation of a household for any of the reasons listed above. In all instances, the following standards apply:

• Households may only relocate to a unit for which they are eligible under the Housing Services Act, the City of Toronto’s Occupancy Standards, and any other applicable rules and regulations.
• Toronto Seniors Housing Corporation may choose not to relocate a household if its tenancy is not in good standing.
• Toronto Seniors Housing Corporation will make reasonable efforts to assist each household to address any outstanding tenancy issues and ensure their tenancy is in good standing before relocation.
• Toronto Seniors Housing Corporation will work with community partners and will assist in connecting tenants with community partners and services, where needed.
• The relocation process cannot be used to split rent-geared-to-income tenancies. The rent-geared-to-income household is entitled to relocate to one unit in accordance with the City of Toronto’s Occupancy Standards.
• Toronto Seniors Housing Corporation staff will work with tenants on the selection of a relocation unit for which the household is eligible.
• Toronto Seniors Housing Corporation will provide moving assistance subject to the requirements in any applicable agreements (e.g. a Tenant Relocation Assistance Implementation Plan) and the household qualifying for moving assistance.
• For rent-geared-to-income tenants, rent will continue to be based on income. For all other tenants, rents may change as a result of relocation both in the relocation unit and the unit to which tenants return after the relocation.
• The relocation process will follow the rules in the Residential Tenancies Act and any other applicable rules and regulations.
• Households may waive the right to return, if applicable, and remain in their relocation unit, except in instances of relocation due to accessibility upgrades.

Note: If a unit or building is sold, the household may or may not be required to relocate. The decision to relocate a household will be based on the terms in the Agreement of Purchase and Sale signed with the new owners.

Standards Applied to Relocations due to Permanent Unit Closures or Revitalization

In instances of permanent unit closures or revitalization, the following standards apply:

• An official notice will be issued to each household in writing prior to relocation. Notification will be provided according to the timelines set out in any governing agreements and legislation.
• Toronto Seniors Housing Corporation may be required to develop a Tenant Relocation Assistance Implementation Plan for specific buildings or communities as part of the City of Toronto’s approval process. Where these plans are in place, they will take precedent over the standards in this policy.
• The order in which households will be offered a relocation unit will be established through a random selection draw.
• If a household does not choose a relocation unit by the deadline provided by Toronto Seniors Housing Corporation, Toronto Seniors Housing Corporation may begin the process for terminating the household’s tenancy.
• Once an offer is accepted for a relocation unit, the household must sign a new lease for the relocation unit and an Agreement to Terminate the Tenancy for their existing unit.
• Tenants who are moved due to revitalization have the right to return to a new unit in a revitalized community, subject to eligibility rules in the Relocation Agreement it signs with Toronto Seniors Housing Corporation.
• A household will only receive one offer of a revitalization unit. Once the household has exercised its right to return to a revitalization unit, it is not entitled to transfer to a different revitalization unit, even if the household’s family composition has changed after moving.
• Households may defer their right to return for a later opportunity, if allowed by the applicable Tenant Relocation Assistance Implementation Plan, and any other applicable agreements or plans.
• If a household terminates its tenancy with Toronto Seniors Housing Corporation at any point during the relocation process, it may no longer be eligible to return to the revitalized community subject to the terms of its Relocation Agreement.

Standards Applied to Relocations due to Large-Scale Renovations

In instances of large-scale renovations, the following standards apply:

• Once an offer is accepted for a relocation unit, the household will sign a new lease for that unit and an Agreement to Terminate the Tenancy for its existing unit.
• After the renovation is completed, the household has right of first refusal to return to the renovated unit as long as it gives Toronto Seniors Housing Corporation written notice it will be exercising that right before relocating and complies with any other conditions in the relocation agreement it signs with Toronto Seniors Housing Corporation.
• If a rent-geared-to-income household will be overhoused in the renovated unit at the time when it exercises its right of first refusal and returns to the unit, the household will not be eligible for moving assistance for the move from its relocation unit to the renovated unit.

Standards Applied to Relocations due to Emergency Situations

In instances of emergency situations, the following standards apply:

• Once an offer is accepted for a relocation unit, the household will sign a new lease for that unit and an Agreement to Terminate the Tenancy for their existing unit.
• After the repairs are completed, the household has right of first refusal to return to its previous unit as long as it gives Toronto Seniors Housing Corporation written notice it will be exercising that right before relocating.

Note: Where there is a fire in a unit, refer to the Resident Relocation – Fire Response Procedure.

Standards Applied to Relocations due to Accessibility Upgrades

In instances of accessibility upgrades, the following standards apply:

• Households who are relocated must sign a Temporary Shelter Agreement for their relocation unit.
• Households must return to their original unit after accessibility upgrades are complete.
• Rent-geared-to-income households that temporarily relocate outside of Toronto Seniors Housing Corporation while accessibility upgrades take place in their unit will not lose their rent-geared-to-income subsidy, provided they return to their unit once the work is complete. Where a household can stay with family or friends outside of Toronto Seniors Housing Corporation, this option will be pursued first.

Compliance and Monitoring

The Regional Manager in each Region is responsible for having a process in place to monitor staff compliance with this policy.

Related Legislation, Regulations, and TSHC Policies:

• Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11
• City of Toronto Occupancy Standards
• City of Toronto Property Standards Bylaw
• Housing Services Act
• Ontario Human Rights Code
• Residential Tenancies Act
• TSHC Accessibility Policy
• TSHC Evictions for Cause Policy
• TSHC Eviction Prevention Policy for Non-payment of Rent (Arrears)
• TSHC Human Rights, Harassment and Fair Access Policy – Tenants
• TSHC Tenant Complaints Process
• TSHC Tenant Charter
• TSHC Tenant Transfer Policy
• TSHC Translation and Interpretation Policy
• TCHC-TSHC Emergency Response Plan

Amendments (Revision History):

Initial policy approved by Board of Directors on April 28, 2022, effective June 1, 2022.

Next Scheduled Review Date:

This policy will be reviewed once every five years.

Policy Contact

Manager, Business Operations and Compliance

Appendices

• Relocation Procedure (in development)

TORONTO SENIORS HOUSING CORPORATION (TSHC)

Tenant Complaint Procedure

TSHC Human Rights, Harassment and Fair Access Policy

Tenant Complaint Procedure related to Human Rights 

Policy Owner

Approval

First Approved

Effective Date

This Complaint Procedure covers the following topics:

• Purpose of Complaint procedure
• Scope of Complaints Procedure
• Definition of terms
• How the Complaints Procedure Works
• Step 1 Identify the problem
• Step 2 Gather evidence
• Step 3 Attempt resolution
• Step 4 File formal (written) complaint
• Step 5 Mediation
• Step 6 Investigation of a formal complaint
• Step 7 TSHC management decision
• Step 8 Remedies and Restoration Actions
• Miscellaneous Matters
• Confidentiality and Non-Disclosure
• Who can Complain and Anonymity
• Resources and Representatives
• Time limit for Complaints
• Disclosure of Investigation Results and Final decision
• Completion of Complaint Resolution Process
• Participation and Accommodation
• No Retaliation

Human Rights, Discrimination, Harassment and Fair Access Policy

TSHC will not tolerate, ignore, or condone any form of discrimination, harassment or barrier to services. All employees, contractors, agents, tenants, Board Directors, volunteers and appointees who serve on committees established by TSHC are bound by this policy in their dealings with TSHC. They have a duty to actively promote and support human rights, to remove barriers to equality and to refrain from harassment and discrimination. TSHC is committed to promoting a climate of understanding and mutual respect where each member of TSHC community is able to derive benefits and to participate fully to the development and well being of the community.

Purpose of Human Rights Complaints Procedure for Tenants

• This complaints procedure explains how a tenant can make a complaint related to a Human Rights issue.
• This procedure also explains what TSHC will do to try to resolve a complaint. TSHC believes that the main purpose of resolving complaints is not to punish people for their actions but to achieve respectful relations, though in some circumstances, a warning to cease certain conduct might be appropriate or it might be necessary for TSHC to terminate its relationship with that individual or cease a particular practice. This complaint procedure implements TSHC’s internal Human Rights, Harassment and Fair Access Policy meets its legal obligations related to the following:

1. Ontario Human Rights Code
2. Tenant Protection Act
3. Social Housing Reform Act

Scope of Complaints Procedure

This policy and supporting procedures covers all TSHC employees including full or part-time, permanent or non-permanent, management or non-management staff. All employees, contractors, agents, tenants, Board Directors, volunteers and appointees who serve on committees established by TSHC are bound by this policy in their dealings with TSHC.

Anyone who is a direct tenant of TSHC, or who is an occupant of a unit leased by a supportive housing provider from TSHC may rely on this procedure for both formal (written) and informal (written or verbal) complaints. A complaint that is processed through this procedure is an “internal” complaint as it will be investigated and resolved by TSHC management or external consultants hired by TSHC.

Definition of Terms

• agent: a person who is authorized by another to act for him or her; one authorized to transact business for his or her principal; TSHC employees who regularly have contact with tenants may be considered agents of TSHC in certain circumstances
• accessible format: various formats to effect communication e.g. large print, Braille, audio and video tape recording
• allegations: this refers to the actions of a person or the adverse effects of a policy that forms the basis of a complaint; they are called “allegations” because they have not been proved
• complainant: the person(s) or group making a complaint
• contractor: contractor includes independent consultants, persons who have entered a business agreement with the Toronto Seniors Housing Corporation to supply goods or perform work, including professional services, and includes employees of the contractors who work on site at TSHC to perform a contract; agencies that have entered into an agreement with TSHC to provide services to tenants and/or occupants are also included in the term “contractor”
• discrimination: any practice or behaviour, whether intentional or not, that has a negative effect on an individual or group based on a prohibited ground e.g. disability, sex, race, and sexual orientation. A decision to deny a benefit that relies on any of these grounds, unrelated to a person’s abilities, is prohibited. Discrimination may arise as a result of differential treatment or it may result from the unequal effect of applying general rules to everyone. In either case, if the effect of the behaviour or practice on the individual is to deny or limit access to housing accommodation, goods, services, facilities, employment, or contracts available to others, it is
• duty to accommodate: whenever applying a general rule has an adverse effect on an individual because of he or she belongs to a group that is identifiable by a prohibited ground, TSHC has a duty to accommodate the individual. TSHC must re-examine the general rule to minimize or eliminate the adverse In some instances, different approaches or an accommodation may be required to achieve equal access to goods, services and opportunities within TSHC. Accommodation could be an adjustment of TSHC rules to eliminate unequal effects, short of causing undue hardship to TSHC.
• employee: unionized or non-unionized, permanent or non- permanent, management or non-management staff who receive pay for working with TSHC
• external complaint: a complaint filed with a body outside TSHC g. Ontario Human Rights Commission, Ontario Rental Housing Tribunal
• ground: the basis for a decision or action. In TSHC’s policy, prohibited grounds of discrimination include race, ancestry, place of origin, colour, ethnic origin, citizenship, creed or religion, sex, sexual orientation, same-sex partnership status, gender identity, age (over 16), marital status, family status, receipt of public assistance, record of offences, political affiliation, disability or English-language proficiency.
• harassment: any comment or conduct that a person knows or ought to know would be unwelcome. Harassment may result from one incident or a series of incidents. Examples of harassment include offensive and embarrassing comments, derogatory remarks, threats, inappropriate jokes, innuendoes and teasing; insulting gestures; practical jokes that result in embarrassment; electronic or physical display of pin-ups, pornography, demeaning or sexually explicit materials; actions that invade privacy; spreading rumours that damage a person’s reputation; threats to disclose that someone is gay or lesbian; physical or verbal attacks on people who are gay or lesbian; refusing to work with person(s) or a group of persons because of their race, sexual orientation etc; condescending or patronizing behaviour; abuse of authority; unwelcome touching; physical assault or sexual assault.
• internal complaint: a complaint that is processed using this procedure for resolution by TSHC management or external consultants hired by TSHC
• investigator: may be a neutral TSHC manager or external consultant who is appointed or hired to investigate a complaint
• mediator: may be a TSHC manager or other trained TSHC staff who acts as a neutral facilitator, or he or she may be an outside consultant who is appointed to facilitate discussion and problem- solving between a complainant and a respondent
• occupant: a member of a household who live in a unit that is leased by a supportive housing provider from TSHC
• party or parties: may refer to the complainant and/or the respondent or both
• representative: a complainant or respondent can ask someone to be a personal advocate or advisor to help them go through the complaints process
• resources: refers to TSHC staff (e.g. Tenant Service Administrators, Seniors Services Coordinators, Community Service Coordinators, Tenant Representatives, Senior Housing Managers), translators/ interpreters and community agencies that provide services to tenants
• respondent: person(s) or group against whom the complaint is made; the respondent may be another tenant, a guest, a contractor, an employee of TSHC; if the complaint is about a policy or practice in TSHC, the respondent may be a manager of a building managed on behalf of TSHC
• retaliate: take action or initiate a proceeding against a person who has made or supported a complaint; cast accusation back upon a person
• systemic discrimination: refers to discrimination that may occur when a policy or practice has a disproportionate negative effect on a particular group of persons who are identified by a prohibited ground. These policies and practices may appear neutral but in fact, may result in barriers and reduced access to opportunities for members of different racial, cultural or other groups identified by a prohibited ground of discrimination
• tenant: includes all individuals in a household who are included in a signed tenancy agreement with TSHC; also includes an applicant who has applied to live in a unit that is managed by TSHC
• work unit: Seniors Housing Units and other discrete teams of employees at the corporate and service offices of TSHC who report directly to a manager who in turn reports to a General Manager
• workplace: all locations where business or social activities of TSHC are including off site locations (e.g. employee’s home is “workplace related” if unwelcome phone calls or visits are made by a tenant or co-worker).

How the Complaints Procedure Works

This procedure requires the full co-operation of the complainant and the respondent to be truly effective. It is an “internal” complaint procedure and is entirely voluntary.

 TSHC requires that managers and external consultants carry out the steps below in a timely manner.

Step 1. Identify the Problem Complaint about individuals

The complainant should:

• Describe in detail the actions or behaviour of the person(s) who is the source of the If there were several incidents, the complainant should describe each one separately.
• The complainant should identify to the Seniors Housing Manager, verbally or in writing:
  • when the action took place
  • where it happened
  • who the complainant believes caused the problem
  • the details of what happened – the speech or behaviour that the complainant believes is discrimination, harassment or unfair treatment
  • any witnesses
• If the complainant wants the complaint to be handled informally through facilitated discussion, the complaint can be made verbally or in writing.
• If the complainant wants the complaint to be formally investigated by TSHC, he or she should prepare, sign and date a written complaint.

 If the complaint relates directly to the conduct of the Seniors Housing Manger, the complaint should be filed with the Office of the Chief Executive Officer of TSHC

Complaint about a TSHC policy or practice

If the complaint is about a practice or policy of TSHC, the complainant should:

• identify the policy or practice that she or he believes is causing
• Identify how the policy affected the complainant
• prepare, sign and date a written complaint
• give the written complaint to his or her Seniors Housing Manager (SHM).

If the complainant requires assistance to write the complaint, the SHM will facilitate the process of putting the complaint in writing.

 Step 2. Gather the evidence

• Complainants should get the names of witnesses and gather as much evidence as possible to support their complaint about another person’s actions. For example, they should collect any physical evidence such as documents, voice mail messages, or other relevant items.
• If the complaint relates to TSHC practice or policy, the complainant should attach any related documents to the complaint. For example, if the person did not get a benefit or a service, the person should attach:

1. copies of notices or advertisements about a service or benefit being available
2. their application for the service or benefit
3. if there is no notice or advertisement, identify or explain which TSHC policy/practice they believe caused the adverse effects
4. the date of any meetings with staff about the service or benefit
5. names of staff
6. any notes from meetings or phone conversations
7. a letter of rejection or refusal
8. the details of the adverse effect(s) of a policy or practice based on a prohibited ground of discrimination
9. any information given to the complainant by TSHC staff about how to appeal the rejection or refusal.

Step 3. Attempt resolution informally between affected individuals

• As a general rule, TSHC urges individuals to first try to resolve their complaints among They can talk to or write to the person who has caused the problem or they can talk to the Seniors Housing Manager to get ideas on how to resolve the problem.
• Complainants and respondents can ask for help in resolving the complaint informally. There is a list of people they can ask for help (see Resources in the definition section).
• The information that is gathered at Steps 1 and 2 above should be shared so that all participants have a good understanding of the issues to assist in brainstorming about solutions. If a solution is reached at this stage, with the assistance of a Seniors Housing Manager or other resource, the matter can be closed.

 Step 4. Filing a formal complaint against an individual or a TSHC policy/practice

• A formal complaint requires the same details as outlined in Step 1 above except that the complaint must be in writing, signed and dated.
• If a complaint is being treated formally, a copy of the written complaint will be given to the respondent.
• The respondent will have the chance to respond to the allegations in the Any complainant who files a formal complaint must be prepared to have his or her name disclosed to the respondent. Only in rare cases, it may be appropriate to not disclose the name of the complainant to the respondent.

Step 5: Mediation

• If a written complaint has been filed and the complainant and respondent are both willing to try to resolve the matter through a mediator, TSHC will facilitate the selection of a mediator to assist the parties. Parties agree on the choice of the mediator. The mediator may be a TSHC staff member or an external person. If the parties cannot agree, a mediator will not be used and the matter will proceed to investigation.
• As in Step 3, the parties should share information with each other and the mediator to facilitate a frank discussion of the issues between With all parties’ agreement to mediation, a mediator may be able to assist with resolving the problem through discussion and avoid going through a formal investigation
• If mediation is successful, an agreement should be put in writing and should be signed by the parties. The agreement will provide a clear record of the terms each party has agreed to . Each party will be given a signed copy of the agreement that is to be treated as confidential between the parties involved.
• All discussions during the mediation process are to remain
• Settlement discussions are “without ” This means that if a settlement is not reached, each party can take a different position in any future investigations.
• If the complaint proceeds to investigation, neither party is allowed to talk to the investigator about the content of the discussions at mediation.

 Step 6: Investigation of a formal complaint

If a complaint has not been resolved either informally (Step 3) or with the help of a mediator (Step 4), TSHC may carry out a formal investigation.

• The investigator will be chosen by TSHC and will be a neutral person with no prior involvement with the parties or the
• Investigation involves interview(s) of the parties and their witnesses and a comprehensive and impartial review of all the relevant information to determine if there has been discrimination or harassment.
• The investigator may speak directly to TSHC employees, examine relevant documents, and enter any work location that is relevant to the complaint provided notice is given to TSHC management. The investigator can review confidential TSHC documents and enter areas that are normally restricted to investigate the TSHC employees cannot unreasonably withhold permission for these actions.

 The investigator requires full the co-operation of tenants and staff who are parties or witnesses for a thorough investigation.

Steps in the investigation include:

• meeting(s) with the complainant at the beginning of the investigation to establish the scope of the complaint and review details that support the allegations in the complaint
• meeting(s) with the respondent to provide him or her with the details of the complaint and a summary of all the supporting facts
• getting information from the respondent for a full response to the allegations
• informing the complainant of any counter-allegations made by the respondent to give the complainant a chance to respond to these new allegations
• providing opportunities for each party to answer to allegations and counter-allegations that arise during the investigation

At the conclusion of the investigation, the investigator will prepare a written report to the manager that includes evidence, findings, reasoning (analysis), recommendations or a plan of action. The investigator will protect or conceal the identities of witnesses to the greatest extent possible in the body of his or her report. If a complaint is upheld, TSHC management makes the decision on the restorative action to be taken.

 Step 7: Decision

• In the event that a complaint is found to have grounds, the investigator will make recommendations on restorative action to the Seniors Housing Manager. In most instances, the local Seniors Housing Manager will make the decision about restorative actions based on the investigator’s recommendations with input from the Solutions when requested by the manager
• A recommendation that may have corporate-wide impact must be referred to senior management
• If the complaint involves the Seniors Housing Manager as a respondent, or if the Seniors Housing Manager has not resolved the investigation in a timely manner, the Chief Executive Officer or delegate will make the decision on restorative action.
• TSHC’s decision is final. No further appeal is possible within TSHC. Parties may decide to pursue external If a party believes that this dispute resolution process has not been followed, he or she may discuss the matter with the manager who was responsible for conducting the investigation or overseeing the work of an external investigator. If the party is still not satisfied, he or she can pursue other recourse, if any, outside of TSHC.

Step 8: Remedies and Restorative Actions

If a complaint of harassment or discrimination is proven, TSHC can take action to correct the problem. Based on the findings and recommendations of an investigator, TSHC may:

• change a policy or practice
• compensate a complainant to put them in the position he or she would have achieved if there had been no discrimination or harassment
• initiate training programs or refresher training
• direct individuals to obtain counseling
• initiate discipline of employees or legal action against a tenant, agent or contractor where necessary

MISCELLANEOUS MATTERS

Confidentiality & Non-disclosure

• Everyone involved in a complaint must keep the allegations confidential. This permits the parties an opportunity to be frank and open so that a positive resolution can be facilitated.
• Every attempt will be made to fully disclose all relevant documents and information to all the Frank disclosure is only possible if all parties keep the matter confidential. There are limits however, if the information relates to health, personnel or other personal information that deserves privacy protection and/or falls under privacy protection legislation.

 Any breach in confidentiality will be treated seriously by TSHC.

Who can Complain & Anonymity

• Only individuals who are directly affected by the alleged discrimination, harassment or unfair treatment can file a complaint. If the person who is directly affected is cognitively impaired, his or her legal substitute decision-maker may file a complaint on his or her behalf.
• Witnesses cannot file complaints for someone However, they may be able to file their own complaints regarding a “poisonous” environment if the actions or behaviours they witnessed are extreme and/or persistent.
• Any member of TSHC’s community who is covered by this policy can file a complaint of systemic discrimination to challenge a TSHC policy or practice.
• TSHC will not process a complaint unless the identity of the complainant(s) is In rare cases, it may be appropriate to not reveal the identity of the complainant to the respondent where personal safety may be compromised.

Resources & Representative

Human Right Complaints are received in a general mailbox, triaged by Solutions and forwarded to the General Manager of Toronto Seniors Housing for investigation and resolution of the matter.

TSHC is available to assist unit managers on matters of Human Rights within the TSHC but will not necessarily be involved in the resolution of every complaint under the policy.

Tenants can get advice and help if they have a complaint and want to do something about it from the Seniors Housing Manager, a Community Service Coordinator, or other staff who work closely with tenants, a trusted tenant, or any other advocate they choose e.g. Legal Aid Clinic. The respondent can also request help from these resource persons to prepare a response to the complaint.

Any of the above TSHC staff will:

• advise the complainant or respondent on TSHC policies and procedures
• assist with the writing of the complaint or the response (the same person cannot help both parties to the dispute)
• provide an interpreter or translated materials or use accessible format (e.g. large print) to facilitate communication
• Both complainants and respondents have the right to have an advisor or representative of their choice. This person can come with them to meetings and generally give them support and advice. The advisor or representative should not have a conflict of interest and must keep the information about the complaint confidential.

Time Limit for Complaints

• A person has 6 months to file an internal complaint under this policy after the alleged discrimination, harassment or unfair treatment took place. TSHC may make exceptions to this deadline if there are special circumstances. Time lapses beyond 6 months generally make it more difficult to conduct a thorough and fair investigation for all parties involved. Often witnesses are no longer available, documentation may be unavailable and recall of details of the incident may be limited.
• The time limit to file an external complaint with the Human Rights Commission is also 6 months after the alleged incident took place. TSHC cannot guarantee that it will resolve an internal complaint before the expiry of this time limit. A complainant who submits a complaint to TSHC for investigation and decision-making can still complain to the Ontario Human Rights Commission or the Ontario Rental Housing Tribunal provided that the complainant acts within the deadlines established by those bodies.

Disclosure of investigation recommendations & final decision At the end of an investigation into a formal complaint, the investigator will provide a written report of his or her findings, conclusions and recommendations to the General Manager of Senior’s

Housing . The unit manager or the delegate of the Chief Executive Officer will communicate TSHC’s final decision to the parties in writing and will also be responsible for providing a written summary of the investigator’s recommendations.

Timing of completion of complaint resolution process Formal complaints should be resolved within 90 days, except for cases that have been referred to an agency outside TSHC for mediation or investigation. Informal complaints should generally be resolved within 30 days after the issue is raised with a Seniors Housing Manager.

From time to time, there may be delays because of situations outside the control of the responsible Manager (e.g. witnesses’ unavailability) In this case, the Manager will write to the parties to explain the reasons for the delay. The Manager will also estimate how much time will be needed to resolve the complaint.

Participation & Accommodation

All TSHC staff who are involved with processing a complaint must make sure all parties can participate fully. For example, they may need to meet in the evenings or weekends or at a location that is wheelchair accessible. Or, they may need to arrange for an interpreter or translated materials or make documents available in accessible formats.

No Retaliation

TSHC’s Human Rights, Harassment and Fair Access Policy prohibits any punitive action against individuals who pursue their rights under this policy. This protects individuals who:

• make a complaint that he or she reasonably and honestly believed to be true
• take part as a witness in an investigation
• are associated with either the complainant, the respondent or a witness during the procedure

 TSHC may take corrective measures against any tenant, employee, agent or contractor who retaliates against a complainant. A counter-claim by a respondent may or may not be treated as retaliation.

Toronto Seniors Housing Corporation (TSHC)
Absences from rent-geared-to-income units Guidelines

Guidelines Sponsor: Director, Operations

Approver: Board of Directors

Initial Approval Date: April 28, 2022

Effective Date: June 1, 2022

For a household paying rent-geared-to-income, the City of Toronto’s guideline for social housing sets 90 days as the maximum number of days that all members of the household can be “absent” or not living in their unit while continuing to receive a rent-geared-to-income subsidy. However, there are some exceptions to this rule.

This rule only applies if all members of your household are away at the same time.

Short absences of up to seven days in a row or less are not counted toward the 90-day limit within a 12-month period.

If all members of a household are away for more than 90 days in a row or more than 90 days within a 12-month period, and have not informed Toronto Seniors Housing Corporation, they could lose their rent-geared-to-income (RGI) subsidy. Informing Toronto Seniors Housing Corporation of any absence longer than 90 days will also help us to address safety and repair needs while a tenant is away.

Please tell us if you are in hospital, in rehabilitation, awaiting trial or have documentation to support another valid reason for being away from your unit longer than 90 days.

Learn more by reviewing the City of Toronto Absence from Unit from City Guideline 2013-9 https://www.toronto.ca/community-people/community-partners/social-housingproviders/rent-geared-to-income-administration/

Next Scheduled Review Date: 2027

This policy will be reviewed once every five years.

Guidelines Contact

Manager, Business Operations and Compliance

Appendices

City of Toronto Absence from Unit from City Guideline 2013-9

Who does the guideline apply to?

The guideline applies to tenants who live in a rent-geared-to-income (RGI) unit.

What is the guideline?

The guideline 2013-9 Local Eligibility Rule – Absence from Unit states the maximum number of days that all members of a household can be “absent” or not living in their unit and continue to receive a rent-geared-to-income (RGI) subsidy is 90 days. It also outlines the exceptions to this rule.

The maximum number of days that a household can be away from their unit is 90 days in a row or 90 days within a 12-month period.

This rule only applies if all members of your household are away at the same time. If at least one member of your household will be living in your unit during your absence, this rule does not apply. A member of your household is anyone listed on your Lease Agreement with Toronto Seniors Housing Corporation.

Short absences of up to seven days in a row or less are not counted toward the 90-day limit within a 12-month period.

Will I be eligible for RGI assistance if I am away for more than 90 days?

You will not be eligible for RGI assistance if you are away for more than 90 days unless you have given notice to Toronto Seniors Housing Corporation in writing of the reason you are away and the reason meets one of the exceptions as stated in the City’s guideline.

If you plan to be away for more than 90 days, call the Tenant Support Centre at 416-945-0800, email: support@torontoseniorshousing.ca or visit your Regional Office.

What happens if I lose my subsidy?

If you lose your subsidy, you will not lose your unit, but you will have to pay market rent.

What if I am the only member of my household and I have a medical condition that requires me to stay in hospital or be away from my unit?

If you are the only member of your household and have a medical condition that makes it necessary for you to be away from your unit for 90 days in a row or longer to receive treatment, call the Tenant Support Centre at 416-945-0800, email: support@torontoseniorshousing.ca or visit your Regional Office so we can help you keep your subsidy.

What happens if another member of my household (anyone listed on the Lease Agreement with Toronto Seniors Housing Corporation) has a medical condition and I have to be away from my unit to take care of them?

If all members of your household will be away due to this reason, call the Tenant Support Centre at 416-945-0800, email: support@torontohousing.ca or visit your Regional Office so we can help you keep your subsidy.

Will I be able to keep my subsidy if I am being held in jail while awaiting trial?

Yes. If a household has one member, and the member is absent because they are being held in jail while awaiting trial, they will not be considered absent from the unit. Paperwork/proof of the reason for absence must be provided to your Tenant Services Administrator. However, rent must also be paid while you are away.

What if the condition of my bail does not allow me to live in my unit for 90 days or longer?

If a household has one member, and a bail condition of release prevents the member from living in the unit, the household will not be considered absent from the unit. Paperwork/proof of the reason for absence must be provided to the Tenant Services Administrator. However, rent must be paid while you are away.

Will I lose my unit if I am convicted of a crime and serving a sentence?

If a household has one member, and the member has been convicted of criminal offence, the household will be considered absent from the unit for more than 90 days if the jail time served is greater than 90 days.

Note: Being convicted of a criminal offence does not make someone ineligible for RGI subsidy, unless the conviction is for RGI fraud or misrepresentation.

Someone who is convicted and serves a sentence leading to an absence of 90 days or more will lose their subsidy but not their unit and will have to pay market rent.

What are my options if I lose my RGI subsidy?

You can request a review of your eligibility for RGI subsidy by completing a Request for Review Form:

• in person at your Regional Office;
• by email to support@torontoseniorshousing.ca;
• by phone with a Tenant Services Administrator;
• by mail or fax.

Note: Requests for review must be made within 30 calendar days (plus five mailing days, if the request is mailed by the tenant) after the notice of decision has been given to the household by Toronto Seniors Housing Corporation. When you have completed your form, submit it to:

Toronto Seniors Housing Corporation

Attention: Review Body
423 Yonge St., 2nd Floor, Toronto, ON M5B 1T2

Toronto Seniors Housing Corporation (TSHC)
Addition to Family Composition Directive

Directive Sponsor: Director, Operations

Approver: Leadership Team

Initial Approval Date: May 17, 2022

Effective Date: June 1, 2022

Introduction

Toronto Seniors Housing Corporation (TSHC) recognizes that tenants may request that additional person(s) be added to their household composition from time to time due to changes in circumstances.

The Addition to Household Composition Directive will provide the framework to govern the standard practice and procedure in reviewing these requests, while supporting Toronto Seniors Housing Corporation’s commitment to equitable quality services and adhering to legal requirements as set out in the applicable legislation.

Directive Statement

TSHC is committed to a fair and equitable approval process for assessing tenants’ requests to add members to their household composition.

Application of Directive

This directive applies to all Toronto Seniors Housing Corporation Rent-Geared-to-Income (RGI) and Market Rent households who wish to add new member(s) to their household composition.

Directive Guidelines General Principle

Addition to Household Composition requests should generally be used to reunite families, however, doing so cannot create an underhoused situation that is in breach of the Occupancy Standards set out in the Toronto Municipal Code, Property Standards section.

Household refers to the people who live in a housing unit. Household can refer to one person who lives alone, or to a group of people who live together in a unit.

Rent-Geared-to-Income Households

Households may allow guests to stay with them for up to 30 days, in a twelve-month period, without asking for permission from Toronto Seniors Housing Corporation.

Households must report any guest who wishes to stay longer than 30 days, in a twelve-month period, as per Toronto Seniors Housing Corporation’s Visitor and Guest Policy.

Households requesting person(s) to be added as a Tenant (Leaseholder) or as an Occupant:

• To have guest(s) either become a tenant of an RGI unit or be added as an occupant of an RGI unit, the current tenant(s) must submit a completed Addition to Household Composition Request Form to Toronto Seniors Housing Corporation within 30 days of household composition change.
• The person(s) to be added and existing household members must be willing to provide the information, documentation and authorization necessary to determine whether they are eligible for RGI subsidy.

Limitations

Toronto Seniors Housing Corporation may decline to add an individual to an RGI Household if:

• The person(s) to be added does not meet basic eligibility criteria set out in social housing legislation.
• The addition(s) to the household would result in noncompliance with the Occupancy Standards set out in the Toronto Municipal Code, Property Standards.
• The existing household or the person(s) to be added has an outstanding balance with a social housing provider in Ontario, does not have a repayment agreement and/or is not up to date with repayments.
• The person(s) to be added was evicted from Toronto Seniors Housing Corporation for a non-arrears related issue in the last two (2) years or has been given a trespass notice and is no longer allowed on the property.

Important Note

• As per the current social housing legislation and Toronto Seniors Housing Corporation’s Visitor and Guest Policy, Addition to Household Composition requests must be submitted to Toronto Seniors Housing Corporation within 30 days of a change to the household composition as a result of a guest intending to reside in the RGI unit.
• The Household may become ineligible for RGI subsidy if new and/or existing members of the household do not meet the basic eligibility criteria set out in the social housing legislation.
• Households must not use Addition to Household Composition requests to assist any person to bypass the centralized waiting list or to assign^[1] or sublet^[2] the tenancy to another person.
• Toronto Seniors Housing Corporation may proceed with an application to the Landlord and Tenant Board or Court for an eviction if the addition of new a member was for the purpose of assigning the tenancy to another person.
• All applicable penalties as prescribed under the social housing legislation apply to any person who inappropriately helps another person obtain RGI subsidy.

Decision on Request

Toronto Seniors Housing Corporation will inform the household in writing of whether the addition to household composition request is approved or denied.

Approved

If the request is approved:

• A new lease agreement must be signed by all household members who are 59 or older.
• The rent will be recalculated based on the new total household income.
• The new member(s) will be deemed to be adequately housed and will be removed from the centralized waiting list where applicable, with the exception of new member(s) added to a rooming house household.

Denied

If the request is denied:

The household may appeal to the Regional Manager in writing.

If the person(s) to be added is not eligible for RGI subsidy, but the household continues to allow the person(s) to live in the unit, Toronto Seniors Housing Corporation will begin the Loss of Eligibility process and provide the household with 90 days written notice.

Market Rent Households

A Tenant is a leaseholder that has a contractual relationship with Toronto Seniors Housing Corporation. The Tenant(s) has sole responsibility for the rent, the unit, and is responsible for the actions of all non-tenants whom they permit to be on the Leased Premises.

An Occupant is a non-leaseholder adult who resides in a unit, but has not signed a lease with Toronto Seniors Housing Corporation. An Occupant does not have a contractual relationship with Toronto Seniors Housing Corporation, and has no legal rights, entitlements, or responsibilities to the Leased Premises.

A Market Rent Tenant may allow an Occupant(s) to reside in their rental unit. The Market Rent tenant may not, however, assign or sublet all or any part of the Leased Premises.

A Market Rent Tenant is required by their lease to report any changes in household composition within the same month the change occurs.

A Market Rent Tenant may request to add another Tenant to their unit and sign a new lease. It is up to the current Market Tenant to apply and not the proposed new tenant.

Reporting Occupants

Even where a Market Rent Tenant does not wish to add an Occupant as an additional Leaseholder, it is important that the Tenant reports all persons living with them in their unit. It is essential for safety and emergency purposes that TSHC knows who is living in its units.

Where a Tenant has reported that an Occupant resides in their unit, the Occupant may be entitled to apply for parking at the same rate that the Tenant pays for parking, provided other set of key requirements are met.

Household requesting person(s) to be added as a Tenant (Leaseholder)

• To have a person(s) become an additional Leaseholder, the original Market Tenant must submit a completed Addition to Household Composition Request Form.
• The person(s) to be added must be willing to provide the information, documentation and authorization necessary to determine whether they are eligible to be added to a Market Rent household.

Limitations

Toronto Seniors Housing Corporation may decline to sign a new lease to add an individual as an additional Tenant to a Market Rent household if:

• The person(s) to be added has no legal status in Canada as prescribed by Citizenship and Immigration Canada (i.e. legal status in Canada includes, but is not limited to, having a student visa, work permit, citizenship, permanent residency, being a refugee, etc.).
• The addition(s) to the household would result in noncompliance with the Occupancy Standards set out in the Toronto Municipal Code, Property Standards section.
• The person(s) to be added has an outstanding balance from a current or former tenancy with Toronto Seniors Housing Corporation or Toronto Community Housing Corporation.
• The person(s) to be added was evicted from Toronto Seniors Housing Corporation or Toronto Community Housing Corporation through an order of the Landlord and Tenant Board based on an illegal act (commonly referred to as an “N6”) in the last five (5) years.

Important Note

Toronto Seniors Housing Corporation will not sign a new lease to add an individual as an additional Tenant if either:

• The existing household has an outstanding balance with TSHC; or
• There is an active legal proceeding against the existing household for any arrears or non-arrears issue.

Decision on Request

Toronto Seniors Housing Corporation will inform the household in writing of whether the addition to household composition request is approved or denied.

Approved

If the request is approved to add new member(s) as Market Tenants (Leaseholders):

• A new lease agreement must be signed by all Tenant(s) of the household (existing and new).

If the request is to add a new member as an Occupant and not a Leaseholder, then:

• A new lease agreement is not required, but the Market Tenant may choose to sign a new lease with the new Occupant(s) listed in the “Occupants” section of the lease.
• The Occupant(s) shall have no rights or responsibilities to the unit.
• The existing Tenant(s) continues to be solely responsible for the rent, maintains all legal rights and responsibilities in relation to the unit, and is responsible for Occupant(s)’ actions on the leased premises.
• The Occupant(s) do not have any right to remain in the unit after the Market Tenant(s) (Leaseholder) moves out.

Denied

If the request is denied:

• The household may appeal to the Regional Manager in writing.

Accountability

• The Tenant Engagement and Services Supervisor will monitor application of this directive on an on-going basis.
• Random sampling reviews will be conducted on an annual basis by the Business Operations and Compliance Team.

Related Legislation, Regulations, and TSHC Policies:

• Housing Services Act, 2011
• Municipal Freedom of Information and Protection of Privacy Act
• Occupancy Standards of the Toronto Municipal Code, Property Standards section – Bylaw
• Ontario Human Rights Code
• Residential Tenancies Act, 2006
• TSHC Visitor and Guest Policy
• TSHC Human Rights, Harassment and Fair Access Policy – Tenants
• TSHC Market Rent Tenancy Agreement
• TSHC Rent-Geared-To-Income Tenancy Agreement

Amendments (Revision History):

Directive reviewed on May 17, 2022 by Board of Directions, effective June 1, 2022.

Next Scheduled Review Date: 2027

This policy will be reviewed once every five years.

Directive Contact

Manager, Business Operations and Compliance

^[1] When a Tenant(s) transfers their rights to occupy the rental unit and legal interests to someone else, and the Tenant(s) does not intend to return to the rental unit.

^[2] When a Tenant(s) moves out of the rental unit, lets another person live there for a period of time, but returns to live in the unit before the tenancy ends.

TORONTO SENIORS HOUSING CORPORATION (TSHC)

Unit Condition Follow-up Process

Policy Owner

Approval

First Approved

Effective Date

Toronto Seniors Housing inspects tenant units every year. This is important work. It’s our chance to make sure the units are livable and in a good state of repair. 

Common issues

During annual unit inspections, we find other problems such as:

• excessive clutter
• fire safety violations
• pests
• cleanliness/health hazards concerns

 Sometimes, families, caseworkers, neighbours or staff performing other duties report or flag unit conditions.

How we help

Toronto Seniors Housing staff have been trained on how to support residents with units that have these problems. There are four stages for staff to follow:

• Stage 1: Staff make note of units with concerns.
• Stage 2: Staff inform residents about concerns with their unit.
• Stage 3: Staff support residents to develop a plan to improve their unit.
• Stage 4: Follow-up/resolution. Staff visit unit to ensure the plan is working and the unit condition is maintained.

 This helps staff:

• decide how to respond to urgent problems
• prioritize cases
• work with the City and other external partners
• work with residents towards realistic progress
• use the legal process when working with residents to keep them housed

Review Toronto Seniors Housing policy on evictions for cause.

Toronto Seniors Housing Corporation has adopted this policy as of May 17, 2022 and is in effect for June 1,2022