Policy for Ensuring Effective Communications with Individuals with Disabilities

It is the policy of Essex Savings Bank (ESB) to ensure that communications with individuals with disabilities are as effective as communications with individuals without disabilities, consistent with the requirements of title III of the Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12181 – 12189, and the regulation implementing title III, 28 C.F.R. pt. 36. To meet this obligation, ESB will provide, free of charge, appropriate auxiliary aids and services, whenever necessary, to ensure that individuals with disabilities have an equal opportunity to participate in, and benefit from bank services, facilities, privileges, advantages, or accommodations. 28 C.F.R. §§ 36.301(c), 36.303.

1. What Are Appropriate Auxiliary Aids and Services?
Appropriate auxiliary aids and services include a wide variety of equipment, materials, and services that may be necessary to ensure effective communication for people with disabilities.
For people who are blind or have low vision, appropriate auxiliary aids and services include, but are not limited to, qualified reader; printed information provided in Braille, in large print, in electronic format, or through audio recordings; oral descriptions of action and visual information to ensure the accessibility of proceedings and presentations; note takers; assistance in filling out forms or accessing materials in computer database; screen reader software or text magnification software to make computer displays accessible; electronic information technology (for example, accessible websites); or an assistant to guide a person to find his or her way to an unfamiliar location or along an unfamiliar route.
For people who are deaf, are hard of hearing, or have speech impairments, appropriate auxiliary aids and services include, but are not limited to, qualified oral/sign language interpreters (including on-site and video remote interpreting (VRI) services); written notes; note taker; computer-assisted real-time transcription services; video text displays; amplified and hearing aid compatible telephones; assistive listening system; open or closed captioning and caption decoders; teletypewriters (TTYs); telecommunications relay service (TRS) call acceptance; computer terminals equipped for video communication; and other effective methods of making information or materials delivered using sound available to individuals who are deaf or hard of hearing.
The Bank recognizes that persons may have other disability-related needs and will evaluate disability-related requests on a case-by-case basis.

2. What does the term “qualified interpreter” mean?
The term “qualified interpreter” includes “sign language interpreters,” “oral interpreters,” or other “interpreters” who, via video remote interpreting (VRI) service or an on-site appearance, are able to interpret competently, accurately, and impartially, both receptively and expressively, using any specialized terminology necessary for effective communication with an individual who is deaf or hard of hearing or who has a speech impairment, given that individual’s language skills and education. Not all interpreters are qualified to interpret in all situations. For example, an interpreter who is qualified using American Sign Language (ASL) is not necessarily qualified to interpret orally. Also, someone who has only a rudimentary familiarity with sign language or finger spelling is not a “qualified sign language interpreter.” Likewise, someone who is fluent in sign language but who does not possess the ability to interpret medical or legal terminology; process spoken communication into the proper signs; or observe someone signing and translate their signed or finger-spelled communication into spoken words is not a qualified sign language interpreter. An interpreter who knows tactile interpreting may be the only interpreter who is qualified to interpret for someone who is both deaf and blind. Although an interpreter may be certified, a certified interpreter is not necessarily “qualified.” Similarly, certification is not required in order for an interpreter to be “qualified.”

3. What is a “qualified reader” and when might a qualified reader be required?
A “qualified reader” is a person who is able to read effectively, accurately, and impartially using any necessary specialized vocabulary. For example, a qualified reader may assist a person who is blind or has low vision in reading and filling out forms. When assisting a person in reading documents or completing forms that involve confidential personal, medical, or financial information, the assistance must be provided in a private area in order to preserve the privacy of the individual who is being assisted.

4. What does the term “video remote interpreting service” mean?
“Video remote interpreting service (VRI)” means an interpreting service that uses video conference technology over dedicated lines or wireless technology offering high-speed, wide-bandwidth video connection that delivers high-quality video images meeting the following requirements:
a) Real-time, full-motion video and audio over a dedicated high-speed, wide-bandwidth video connection or wireless connection that delivers high-quality video images that do not produce lags, choppy, blurry or grainy images, or irregular pauses in communication;
b) A sharply delineated image that is large enough to display the interpreter’s face, arms, hand, and fingers, and the participating individual’s face, arms, hands and fingers, regardless of his or her body position;
c) A clear, audible transmission of voices; and
d) Adequate training to users of the technology and other involved individuals so that they may quickly and efficiently set up and operate the VRI.

5. Can ESB employees ask or require family members or friends of individuals who are blind or have low vision to read for them?
Generally, no. ESB shall not require an individual with a disability to bring another individual to interpret for him or her. In addition, ESB shall not rely on an adult accompanying an individual with a disability to interpret or facilitate communication, except (i) In an emergency involving an imminent threat to the safety or welfare of an individual or the public where there is no interpreter available; or (ii) Where the individual with a disability specifically requests that the accompanying adult interpret or facilitate communication, the accompanying adult agrees to provide such assistance, and reliance on that adult for such assistance is appropriate under the circumstances.

6. Can ESB charge an individual with a disability for the cost of providing an auxiliary aid or service needed for effective communication?
No. People with disabilities must not be asked to pay or be charged for the cost of an auxiliary aid or service needed for effective communication.

7. Are there specific procedures for requesting auxiliary aids and services?
Whenever possible, requests for auxiliary aids and services should be directed to the ADA Coordinator/HR Manager or the Chief Administration Officer. Call 860-767-4414 or write to essexsavings@essexsavings.com and in the subject line, insert “ADA Request” to request auxiliary aids and services. An individual with a disability who needs the auxiliary aids or services or someone acting on that individual’s behalf can make requests. Requests can be made either orally or in writing. Requests should be made in advance in order to enable ESB to address the communication needs of the individual. ESB will address all requests for auxiliary aids and services promptly and in accordance with ADA requirements.

8. How will ESB determine which auxiliary aids and services to provide?
In determining which types of auxiliary aids and services to provide, ESB will consult with the requesting individual whenever possible to determine what type of auxiliary aid may be needed to ensure effective communication. In many cases, more than one type of auxiliary aid or service may facilitate effective communication. However, the ultimate decision as to what measures to take rests with ESB, as long as the method chosen results in effective communication.

9. How will ESB handle requests for auxiliary aids and services?
Upon receipt of notification that any auxiliary aids or services will be necessary, ESB’s personnel will confer with the individual with the disability to ascertain the individual’s needs. ESB will respond promptly to all requests for auxiliary aids and services to ensure that auxiliary aids and services are provided in accessible formats, in a timely manner, and in such a way as to protect the privacy and independence of the individual with a disability. ESB will neither request nor require documentation of the disability.

10. What records will ESB keep regarding auxiliary aids or services?
Except for simple requests that are immediately granted, ESB personnel will maintain records of requests for auxiliary aids or services. These records should include the request date; name of the individual making the request; name of individual for whom the request is made; auxiliary aids and services requested; date of response to request; description of the auxiliary aids and services provided; and date the auxiliary aids and services were provided. If ESB did not provide the requested aids and services, the record must include a description of any auxiliary aids and services provided; the date they were provided; reasons for denying the requested auxiliary aids and services; and the decision makers name and title.

11. What should ESB do if management believes that the provision of requested auxiliary aids or services will result in a fundamental alteration or impose undue financial and administrative burdens on ESB?
ESB is not required to provide a requested auxiliary aid or service if it can demonstrate that doing so would result in a fundamental alteration in the nature of the goods, services, facilities, privileges, advantages, or accommodations being offered or in an undue burden (i.e., significant difficulty or expense). In such circumstances, ESB shall provide an alternative auxiliary aid or service, if one exists, that would not result in an alteration or such burden but would nevertheless ensure that, to the maximum extent possible, individuals with disabilities receive the goods, services, facilities, privileges, advantages, or accommodations offered by ESB.

12. See Exhibit 1 for training materials related to effectively communicating with individuals with disabilities.

13. How often will ESB review this Policy?
The Board of Directors shall review this policy at least annually, making such revisions and amendments as it deems appropriate. Call 860-767-4414 for any questions about this policy.

Exhibit 1

Training Materials Related to Effectively Communicate with Individuals with Disabilities
Effective Communication ensures a person with a vision, hearing or speech disability can communicate with, receive information from, and convey information to Essex Savings Bank employees. The key to communicating effectively is to consider the nature, length, complexity and context of the communication and the person’s normal method(s) of communication (i.e. sign language). Depending on the level of communication needed the appropriate auxiliary aid and/or service should be employed. The following are some of the ways we communicate with persons with disabilities:
For persons who are deaf, are hard of hearing, or have speech disabilities:

    • Online banking customers may communicate with customer service representatives during regular banking hours to assist them in their banking transactions.
    • In our branches, we will communicate by exchanging notes, maintain eye contact for those who read lips, or provide, by appointment, a qualified interpreter for more complex or lengthy discussions.

For persons who are blind or have low vision:

    • Provide assistance in reading and filling out forms.
    • Make available raised line and large print checks.
    • Provide account statements in alternate formats via online banking.
    • Blind or visually impaired customers should be asked if they prefer a Debit or ATM card that is ordered via central issuance versus instant issue. Instant issue cards use flat card technology. Central issue cards have raised (embossed) numbers and letters.

ESB ensures that all our ATMs are ADA compliant with both braille indicators and voice guided instructions.
Staff should always listen attentively and not be afraid or embarrassed to ask the person to repeat a word or phrase they don’t understand and/or to clarify their written question/response. Clear and effective communication is imperative.

Relay Services:
A relay call is a call placed by a person with a hearing or speech disability to a Telecommunications Relay Service (TRS). The TRS operator in turn places an outbound call on behalf of the caller with a disability. The TRS then acts as an intermediary between the party called and the caller with a disability. When a customer calls any Essex Savings Bank office or employee through a relay service, the call must be accepted.

The TRS operator will identify themselves as a relay operator and state the nature of the call. The employee answering the call should ask reasonable questions as is the procedure for any phone call to confirm the identity of the customer. Follow established Know Your Customer procedures for customer identification (i.e. First and Last Name, Keyword, TIN, Date/Amount of last Deposit, Account Number, etc.). The TRS operator will relay the information verbatim back and forth for the entire discussion.
Federal law requires that all relay calls are kept confidential. No records are kept by TRS operators. Conversations are automatically erased from the computers after the end of each call.
If you need to place an outgoing call to a customer that utilizes a relay service simply call 7-1-1 to establish a connection through the TRS operator.

List of Auxiliary Aids maintained at each branch for use by customers requiring assistance:

    • Magnifying Glass
    • Erasable White Board with marker
    • Set of disclosures in 16 point font
    • Headphones

Requests for Auxiliary Aids and Services:
Requests for auxiliary aids and services should be directed to the ADA Coordinator/HR Manager or the Chief Administration Officer at (860) 767-4414. A log of all requests will be maintained at User>User> Accessibility Requests for Auxiliary Aids and Services Log.