Translation and Interpretation Policy

Translation and Interpretation Policy Version 1 Ratified By NHS West Cheshire Clinical Commissioning Group Governing Body Date Ratified 16 th November 2017 Author(s) Jonathan Taylor Responsible Committee / Officers NHS West Cheshire Clinical Commissioning Quality Improvement Committee Date Issue November 2017 Review date November 2019 Intended Audience Impact Assessed 9 th August 2017 Stakeholders of NHS West Cheshire Clinical Commissioning Group, NHS West Cheshire Clinical Commissioning Group members, governing body and employees. For publication on our web site Translation and Interpretation Policy 1

Further information about this document: Document name Translation and Interpretation Policy Category of Document in The Policy Schedule Corporate Author(s) Contact(s) for further information about this document Jonathan Taylor Head of Communication and Engagement This document will be read in conjunction with Not applicable Published by Copies of this document are available from NHS West Cheshire Clinical Commissioning Group 1829 Building Countess of Chester Health Park Liverpool Road Chester, CH2 1HJ Website: www.westcheshireccg.nhs.uk Copyright NHS West Cheshire Clinical Commissioning Group, 2017. All Rights Reserved Version Control: Version History: Version Number Reviewing Committee / Officer 1.0 NHS West Cheshire Clinical Commissioning Group Governing Body Date Translation and Interpretation Policy 2

Translation and Interpretation Policy 3

Translation and Interpretation Policy 4

Contents 1. Introduction... 6 2. Definitions... 6 3. Purpose of this Policy... 7 4. Interpreting... 7 5. Accessible Information Standard... 9 6. Use of Clinical Commissioning Group Staff... 9 7. Events, engagement and consultation... 9 8. Mail outs and consultation... 9 9. Surveys and Reviews... 10 10. Providing translated material to an individual or small group... 10 11. Translation & Easy Read... 10 12. Recording... 11 13. Emergencies... 11 14. Standards... 11 15. Responsibility for interpreters... 11 16. Training... 12 17. Clinical Commissioning Group Staff... 12 18. Identifying and Monitoring Resources... 12 19. Audit and review.... 12 Appendix 1 Intelligence Plan 13 Appendix 2 Using translation and interpretation Service....17 Translation and Interpretation Policy 5

1. Introduction 1.1 This policy is designed to support NHS West Cheshire Clinical Commissioning Group to involve, engage and communicate with all its population, irrespective of race and or disability and ensure that as commissioners we meet our statutory duty to ensure equality of access in developing services and not to directly or indirectly discriminate. 1.2 The clinical commissioning group usage of translation and interpretation is more of an ad hoc arrangement when compared to Primary or Secondary Care Services who have formal contract arrangements with translation and interpretation providers to carry out clinical assessments and treatments with patients. Typically the clinical commissioning group may need to use this policy to enable access for people who require translation and interpretation to access:- Public Meetings such as the Governing Body Public engagement events Communications on health campaigns Formal consultations The Patient Advice and Liaison/Patient Experience service 1.3 Also this policy can be used to support the clinical commissioning group with information to access local translation and interpretation services, or provide guidance on how to make communications, meetings and events more accessible. 2. Definitions 2.1 This policy is aimed at addressing the formal process of interpreting or translation. It is not intended to prevent a member of staff from generally communicating with another person in a different language or through British Sign Language. Interpreting 2.2 Is the oral transmission of meaning from one language to another, which is easily understood by the listener. This includes interpretation of spoken language into British Sign Language, (which is a recognised language in its own right) or the use of a palantypist. Interpreting can be provided face to face or by telephone. Interpreting is different from advocacy and should not be used as a form of advocacy. Translation and Interpretation Policy 6

Interpreter 2.3 An interpreter is someone who is (at least) bilingual but also has the ability and training to be able to work between two languages and facilitate communication between people. Translation & Easy Read 2.4 Is the written transmission of meaning from one language to another, which is easily understood by the reader. This might include the conversion of written information into Braille, the production of visual formats (palantypist) or the transfer of information using British Sign Language. 3. Purpose of this Policy 3.1 The clinical commissioning group is committed to ensuring that all people have equal access to its services irrespective of barriers that may be in place due to language or impairment. Interpreting and translation services are therefore essential in achieving this objective. The provision of interpreting and translation services will ensure; effective communication, safe support and care of people who use clinical commissioning group services and minimise barriers that may be faced by people who's first language is not English or who have an impairment. 3.2 Any service provided or commissioned by the clinical commissioning group must take account of potential barriers and consider how these may be addressed. The flow chart in appendix 3 of this policy can assist clinical commissioning group staff to assess these needs. It is the responsibility of all staff to ensure that there is consistency and continuity in the provision of interpreting and translation services. 4. Interpreting 4.1 When to use an interpreting service 4.2 Any person who is responsible for the commissioning/delivery of a service or interacting with stakeholders must consider the provision of interpreting - taking account of the needs of the individual or group. Methods of interpreting 4.3 Face to face language interpretation - this will be the method of choice for people Clinical Commissioning Group services in face to face meetings/events Translation and Interpretation Policy 7

4.4 British Sign Language Interpretation and Palantypist - this will be the method of choice for ensuring effective communication with people who are Deaf/hearing impaired. People who have a hearing impairment may prefer other forms of communication to British Sign Language these choices should be considered with the person as part of an assessment of need. 4.5 Conventionally the use of the word deaf (with a lowercase d ) refers to any person with a significant hearing loss, whereas Deaf (with a capital D ) refers to a person who s preferred language is BSL) ref Association of Sign Language Interpreters 4.6 Telephone Interpreting - This will not usually be the first or most appropriate form of interpreting, however it may be useful in some circumstances. Procedures for accessing interpreters 4.7 Procedures for accessing interpreters will be developed and kept up to date to ensure that services are accessible and accountable. Use of carers, relatives or friends to provide interpreting services 4.8 Carers, relatives or friends should not normally be asked or expected to interpret. The reasons for this are that a people may wish to communicate confidential information and they have a right for confidentiality to be respected. In addition carers, family or friends may not be able to communicate information on an impartial basis. 4.9 It may sometimes be appropriate (e.g. in an emergency situation) for a carer, friend or family member to communicate basic information, however all people must be provided with information on how access to interpreting services at the earliest opportunity. 4.10 If a person refuses to use a professional interpreting service then this decision should be confirmed (through a telephone interpreting service or face to face with and interpreter) and recorded. Children, Young People and Vulnerable Adults 4.11 Point 4.4 applies equally to children and young people the child or young person must be offered the use of a professional interpreter. If there are issues related to child protection or vulnerable adults then a professional interpreter must always be used even to communicate basic information. 4.12 Children (under 18 years) must not be used to interpret at all. The need for a professional interpreter in these circumstances should be conveyed to the person via a telephone interpreting service if a professional interpreter is not easily accessible. A child may communicate very basic information in an Translation and Interpretation Policy 8

emergency however telephone and face to face interpreting should be arranged as a matter of urgency. 5. Accessible Information Standard 5.1 The NHS has an accessible information standard (Specification for the standard and supporting documents) which will help guide the need for interpretation and producing material. 5.2 For further information regarding clinical commissioning group communications please also refer to the Communications and Corporate House Style standard operating procedures. 6. Use of Clinical Commissioning Group Staff 6.1 Staff with language skills may be asked to communicate basic information to a person, however as a general rule staff should not be used to provide interpreting services in lieu of professional interpreting provision (unless they are contracted specifically to do that task or are professionally remunerated for their skill). 7. Events, engagement and consultation 7.1 The need for and use of British Sign Language, palantypist and language interpreting should always be considered at an early stage when planning events aimed at the public, service users or carers to ensure that these events are accessible. Preparation materials i.e. handouts should be made available to interpreters in good time so that they can review these. 8. Mail outs and consultation 8.1 As a general rule, the availability of translated materials should be brought to the attention of participants through a standard insert in mail outs. These should be sent in a timely manner so that arrangements can be made to obtain a translated copy of the material if this is requested. 8.2 Arrangements for all consultations must include consideration of the need to provide information in a range of formats to ensure that it is accessible to all potential participants. 8.3 Clear information should be sent out with consultations on how to access a version in an alternative format, this should include information provided on the Clinical Commissioning Group website and other types of publicity materials (e.g. posters). Translation and Interpretation Policy 9

9. Surveys and Reviews 9.1 When planning and undertaking surveys the Clinical Commissioning Group must ensure that surveys are accessible to all potential participants. Surveys which are being sent to individuals must include details of how to obtain a translated version of the survey, alternative formats and/or how to access support to complete the survey. Consideration should also be given to signed surveys (i.e. providing the survey in a visual format of British Sign Language). 10. Providing translated material to an individual or small group 10.1 When considering providing written translations or easy read material the person responsible for developing the material and support of the individual should consider with them carefully their ability to use translated material and consider the most effective way of ensuring that a person has the information and is able to access it and review it (see 4.6). 10.2 Translated material could include: Written translation Braille or Large Print Spoken translation (i.e. a CD recording) Visual format British Sign Language Palantypist Easy read 10.3 When using or procuring translations staff should consider how the information will be used and the ability of the person receiving the information to use this in the proposed format. The clinical commissioning group will ensure that all staff have information available to them about how to obtain the range of translated material described above. 11. Translation & Easy Read 11.1 There are certain circumstances where providing translated information is a specific requirement, (e.g. procedures under the Mental Health Act, Reasonable adjustment under the Equality Act 2010) in such cases copies of translated materials will be procured and made accessible to all relevant people in either paper and or electronic format. Provision of translated material should be considered in all cases where the provision of care and or support involves providing written information to the person in receipt of such support. 11.2 Easy read material needs to be considered and produced in all consultation exercises and when communicating specifically with people with learning difficulties. Translation and Interpretation Policy 10

12. Recording 12.1 The requirement for an interpreter should be clearly recorded on relevant records and this information made clear in any referral process irrespective of whether the particular referral form requires this. The preferred language of the person should also be recorded. 13. Emergencies 13.1 Where there is a need to communicate information to someone as a matter of urgency telephonic interpreting services may be used. 14. Standards 14.1 All interpreters or interpreting and translation services must meet agreed minimum standards. Service Providers are responsible for: Ensuring that interpreters are of the required level (level 3 for foreign language interpretation and British Sign Language level 4) Ensuring that interpreters have a successful and up-to-date Enhanced Disclosure and Barring Service (DBS) check Providing any training necessary 14.2 When procuring interpreting services the ability of the interpreter to interpret for people with mental ill-health is also relevant. Procedures will be reviewed regularly and updated in light of any changes that may take place from time to time. Services should only be accessed from providers who can demonstrate acceptable standards. If a service is accessed from a source other than one suggested through clinical commissioning group procedures then the accountability for using that services and ensuring that they meet recognised standards will lie with the senior manager responsible for the service requiring interpreting. 15. Responsibility for interpreters 15.1 Any member of staff using the services of a professional interpreter is responsible for supporting the interpreter and for taking reasonable steps to ensure the safety of the interpreter whilst they are undertaking this role. If a member of staff is unclear of how they can fully support an interpreter they should seek advice from their line manager or through professional lines of accountability. Translation and Interpretation Policy 11

15.2 If an interpreter is involved in an incident this must be reported through the clinical commissioning group incident reporting procedures, the person in charge of the service area at the time must be informed and an agreed plan put in place to support the interpreter including liaising with the interpreting services about follow up support. 16. Training 16.1 The Clinical Commissioning Group will ensure that it provides access to training on working with interpreters if needed by staff. When commissioning services training for staff may need to be included in the specification. Any person who regularly uses or potentially uses interpreters must ensure that they arrange to attend a relevant training course on working with interpreters. The need for an individual to access training will also be reviewed through local supervision and thorough personal development reviews. 17. Clinical Commissioning Group Staff 17.1 Staff must not be asked to translate material unless this is a specific aspect of their job role. 18. Identifying and Monitoring Resources 18.1 In order to maintain an overview of overall costs to the organisation Translation and Interpretation Services will be procured against cost centre 630301 (communications budget). 19. Audit and review. 19.1 This policy will be reviewed in 2 years time from the date of its ratification. Translation and Interpretation Policy 12

Appendix 1 1. Intelligence plan List local languages Local provision Albanian Language Solutions 0800 7565210 Polish ApLingo 0800 389 6571 Arabic Language Marketplace 0203 5148801 Bengali Cantonese Gujarati Mandarin Punjabi Urdu List Signers Local provision Deafness Support Network 0333 220 5050 / Text Phone 01606 350823 List Palantypist Local Provision Deafness Support Network 0333 220 5050 / Text Phone 01606 350823 List easy read writers Local provision See Communications 07401 527787 Translation and Interpretation Policy 13

2. Equality Analysis: Purpose of the policy and link to Equality The purpose of the policy is to ensure that any public activity conducted by the Clinical Commissioning Group is effectively communicated to all sections of the community. This will mean that different versions or different processes will be used in order to and enable the process of communication. Also as commissioners developing specifications for services, to remind officers of the need to include factors around different communication needs people have within contract specifications. The policy is directly linked to Public Sector Equality Duty in that it meets and satisfies sections: 1(a) Eliminate discrimination 1 (b) Advancing equality of opportunity 1 (c) Fostering good relations between different persons Protected characteristic Issue mitigation PSED Covered in policy age With older age can often come diminished eye sight and hearing Large print Easy read Induction loops Palantypist PSED met sections: 1 a, 1b, 1c. 3a,3b, 3c 5a, 5b Disability Learning. Mental impairment Physical impairment (deaf/ Blind) May need support in understanding issue, May need signers May need induction loops May need Braille Easy read Signers, Palantypist Material printed in Braille PSED met section: 1 a, 1b, 1c. 3a,3b, 3c 4. 5a,5b Meetings conducted in an inclusive manner Reasonable adjustment for disabled people: section 20 met. Translation and Interpretation Policy 14

Gender reassignment Not engaged Pregnancy & maternity Not engaged race English may not be first langue or fluent in technical areas. English is the national language and business will be conducted in English however, were inclusion is vital ( community meetings/ focus groups) or detailed information is needed from participants then PSED met: 1 a, 1b, 1c. 3a,3b, 3c 5a,5b Alternate language provision must be considered and provided support. Translation services for leaflets and information Interpretation services for face to face communication (telephone support lines) religion Cultural sensitivities It s important to ensure that individuals (especially women) are able to express their views away from chaperons especially when discussing PSED met sections: 1 a, 1b, 1c. 5a,5b 3a,3b, 3c Translation and Interpretation Policy 15

sensitive or difficult issues. This will mean person to person interpretation. UK law applies so consider any safeguarding issues sex Sexual orientation Not engaged Not engaged The policy meets Public Sector Equality Duties. Translation and Interpretation Policy 16

Using Translation and Interpretation Service Yes Is their English adequate to explain their needs and understand advice? Yes Patient wears a hearing aid Normal consultation Use a Hearing Loop Can the person (guardian if the person is a minor) communicate in English? No Person has a sensory disability Person has a learning disability Hearing Visual Patient is profoundly deaf Use Sign Language Interpretation Use alternative format for written communications* Contact Learning Disability Nurse No Person speaks a foreign language Appointment over 40 minutes or delivering bad news Yes No Book a face-to-face interpreter Use telephone interpretation Recommendations for communicating in writing with the visually impaired: Use Arial font size 16 point Justify text to left side Break up paragraphs Use short bullets Do not underline Use bold for important info Translation and Interpretation Policy 17