Sign Safe run by Capita?

imageThis blog has long recorded the effects privatisation on the interpreting industry. We know that one of the so-called big four companies who run the infrastructure of the UK, Capita, has made inroads into the interpreting market after buying out a small company, ALS, and taking on the MoJ contract in 2011, a mere four months after the contract was awarded.

We saw last year a surprise leak about Capita’s shocking charges to the MoJ for interpreting services, only a fraction of which gets paid to its suppliers – the interpreters who fulfil the contract for them.

One of the known problems, that still reoccurs in government contracting, is a reluctance to recognise the already existing registers of interpreters. Both ALS and Capita, believed they could create their own register with little knowledge of the interpreting industry. Their version of a register was little more than a list of names of people who had self-declared they could interpret rather than having qualifications and experience.

Why is this relevant now? The subject needs to be raised of the independence of existing registers/regulators and statutory regulation. NRPSI (National Registers of Public Service Interpreters) went through a tricky time prior to its independence in 2011 from its then owners, the Chartered Institute of Linguists. ALS had paid to subscribe to the register and used these details to falsely inflate the number of interpreters on its books in order to win the MoJ contract. NRPSI is clearly independent now and operates in a different way. What about NRCPD (National Registers of Communication Profesisonals for Deaf and Deafblind People)? It is still tied to Signature A.K.A CACDP who have used all sorts of excuses not to be independent (litigation – insurance covers that and costs – see lack of transparency of accounting practices).

NRCPD, despite admitting they could not pass the standards put in place by the PSA who oversee voluntary registers, is now chasing statutory regulation. This goes against the government’s agenda. One fact sheet states:

“The Government’s view is that high standards for these occupational groups and others can be assured without imposing statutory regulation, with a key role to be played by employers. That is why, in the wider context of supporting providers, we are creating, through the Health and Social Care Act, a system of external quality assurance.” Support Worker Regulation Factsheet, April 2012

Let’s return to another subsidiary of Capita: Capita Gas Registration and Ancillary Services Limited who runs the Gas Safe Register. How has it come to run the register? In 1998, the government passed legislation regarding gas safety: Gas Safety Regulations. The Health and Safety Executive reports CORGI ran the register of accredited gas engineers until 2008 when Capita bid and won the second generation contract to run the register for ten years. Even Wiki states that standards fell when Capita took over and profits meant that candidates now just passed a qualification whereas with CORGI they also had to pass an interview held by an inspector.

This is an example of how you can push through statutory regulation for what people think is the greater good, for public protection, but then your industry lands up in the hands of a private company anyway.

It is an irony that in December 2012 NRCPD decided to name its campaign SignSafe. Or is it?



Signature must release their NRCPD cash cow: part 1

  Although interpreters pay to be regulated, any register does not belong to them, nor do they get a say in how the regulator they use is run. However, they do have a right to see where their money goes and that it indeed goes towards the actual public protection of people who use that regulator. I do not just mean Deaf people but the many people who place their trust in a register to provide them with information on who is qualified or in training, has insurance, is police checked and safe to book for their service/organisation to provide access to Deaf people as per statutory duties.

The holder of the NRCPD registers is Signature which is the trading name of CACDP. Another subsidiary of which is Signature Commercial Limited. A company which declared losses of £96k in the year ending 2013 and £160k for 2014. The accounts show website costs, two employees but barely any more information than that as they have “taken advantage of financial reporting standard 8 whereby subsidiary undertakings do not have to disclose inter-group transactions if 90% or more of their shares are controlled by the group”. Who knows what costs are being squirrelled away in the commercial arm.

This is one example of a lack of transparency. The next accounting practice will be more shocking to those that pay money to the register. Especially for those like myself who have called for independence of NRCPD from Signature and received the answer that it costs too much money to run the register and it could not survive without funding from Signature to keep it afloat.

In the accounting year ending July 2011, the register made a profit of £36k as follows:

Income  130,434    Expenditure  94,478     PROFIT  35,956

In July 2012:

Income  161,394    Expenditure  279,339   LOSS   -117945

In July 2013:

Income  180,810 Expenditure    285,450   LOSS   -104640

In July 2014:

Income  212,409   Expenditure  335,162   LOSS  -122,753

Why the spiralling costs of running a register? There are no separate accounts for NRCPD as CACDP/Signature does not have to provide them. The annual reports for NRCPD reveal nothing but a promise to improve transparency in their finances. A promise yet to be fulfilled.

The only clue is in the way that expenditure is apportioned to each activity in the CACDP/Signature accounts and what this percentage of overheads amounts to as a total of all expenditure. In July 2011 registration was deigned to have cost 6% of all of CACDP/Signature’s expenditure. A fairly reasonable cost which resulted in an overall profit of £36k that was made by CACDP/Signature.

Why the loss of £118k in 2012 despite an income of £161k? A whopping 18% of CACDP/Signature’s expenditure was attributed to the activity “registration” which amounted to £279k. This stayed at 18% for 2013 and has now increased to 21% for 2014.

So CACDP/Signature, with many different activites, apportions 21% of ALL of its costs to registration i.e. NRCPD supposedly costs CACDP/Signature £335k. Put in perspective a much smaller 16% is apportioned to development of examinations, training and materials.

Does it really cost £335,000 to run a register? Only if you apportion 21% of your overheads against registration. 21% of every single staff member at Signature is paid for by the register, despite the fact that not all staff members work for NRCPD.

It is time that the finances of CACDP/Signature were more transparent for registrants and Deaf people alike. It is time for the NRCPD registers to be truly independent at a time when we need them to be, more so now than ever in this political climate. Interpreters, other registrants and Deaf people need to call for independence so we finally make this happen. NRCPD’s so-called independent governance no longer cuts it, it is tied by these accounting procedures. An income of £212k is more than enough for a successful register to survive and furthermore, with not just the financial ties cut from CACDP/Signature, with employees working solely in its interests the register is much more likely to grow and succeed.

Does Signature Support a Lowering of Standards?

For a while now various parties have been pushing for a register of CSWs. This may seem like a sound idea in principle but it is far from it. It seems that this is closer to becoming a reality and Signature is not helping matters:
1) CSWs are not fit for purpose. I started my career with the old EdExcel qualification and saw many people pass that course that should never have worked with Deaf students. Why? A lack of language skills and sound ethical practices. Most of the Deaf students I worked with in colleges and universities needed someone to interpret for them. I never did AtW bookings as I thought I’d be doing a disservice to the Deaf person who surely needed a trained interpreter. As an ex-Chair of ASLI used to explain it: anyone who is listening to English and picks up their hands to relay this into BSL for someone or watches someone produce BSL and relays that information into English is interpreting and therefore should have met the National Occupational Standards (NOS) for Interpreting.2) So why then has Signature created an interpreting unit within the NVQ level 4 BSL qualification? CSW associations have been pushing for an interpreting unit within the EdExcel course for a number of years. ASLI has rightly fought against a lowering of standards. Now Signature has included an interpreting unit which will inevitably be used as a lower benchmark for interpreting, one which is lower than the NOS. All the arguments ASLI has made over the years about the National Occupational Standards are now effectively being ignored. Signature/NRCPD would stand to make funds from both the NVQ qualifications and a CSW register but perhaps has not considered the risks of further alienating interpreters. If this unit becomes a licence to interpret, as it surely will, then quality of interpreting provision will fall substantially. The term level 6 interpreter or level 6 CSW (both misnomers) will be no doubt be banded about and cause further confusion.3) And where is ASLI in all of this? ASLI has got too close to NRCPD to represent its members effectively. It has a place on the practitioners’ forum, which seems to be how NRCPD communicates fixed plans rather than how they get feedback from professionals in order to shape their direction. The ASLI Chair is on the board of NRCPD and has compromised his position in being able to effectively represent his own Association, a position which favours and defends NRCPD registration too heavily to be open to any criticisms ASLI members have of the register.

4) Meanwhile the DWP now seem to be pushing for more CSWs to work in AtW assignments especially for emails and phone calls. I’ve had appalling emails from Deaf people with terrible English grammar written by CSWs and had a plethora of appalling phone calls. Interpreters are not just for meetings. These are skilled jobs where you still need to have achieved the NOS in order to know what you are doing. Why aren’t NRCPD doing more to represent interpreters and the skills they have worked hard to attain? If they will soon also be registering CSWs then perhaps that does not matter to them. Why is no one talking about quality? AtW is designed to allow Deaf and disabled people equality in work, to find and retain jobs. The DWP would happily force people to use CSWs as quality for them is not an issue. It comes down only to cost regardless of value for money even when an unqualified Support worker charges not much less than an interpreter and cannot provide the same service. A register of CSWs rather than enabling registration for this group will inevitably be used against Deaf people by the DWP. Some Deaf people want CSWs. My personal opinion is that public money should not be wasted on unregulated and unskilled personnel. This also should not become the norm for those who do not want them and choose registered professional interpreters. The use of CSWs in education is another matter and regardless of how many self-published books support this, it still does a disservice to the BSL-using Deaf student.

5) Would a register of CSWs be used for schools only? No. For the reasons stated above. Would it benefit schools? Maybe. Would it benefit the Deaf student who is a BSL user. No. They would need a Registered Interpreter (see above). ACSW and NATED have now merged and formed ADEPT which puts CSWs in a stronger position.

Unless those supporting a CSW register stop pushing for CSWs to be used in areas outside of education such as AtW, for CSW courses to have interpreting units, for ‘career CSWs’ who do not develop skills and a qualifications body which goes against the NOS then I doubt interpreters will support moves by Signature or CSW organisations for registers or interpreting units where they do not belong.

Are Statutory Regulation and CPD cure-alls for the ills in interpreting?

photoRoger Beeson NRCPD Registered BSL/English Interpreter (since 1988)

Roger Beeson is a self-employed interpreter based in London. He was a founding member of ASLI and has held various offices, including Chair. He is a regular attendee at its London & South-East Region meetings. He was made a Fellow of ASLI (FASLI) in 2008. He is co-founder and still one of the co-owners of the long-lived independent online interpreting discussion forum “e-newsli”. He is chair of trustees of 3 Deaf organisations, drawing on the experiences of a lifetime spent living and working with Deaf people. He is scaling down his interpreting work, aiming to work a maximum of 3 days a week.

So NRCPD surveyed views on Statutory Regulation and CPD, and will no doubt come up with the expected results. What about the unasked questions?

  • What are Deaf people’s experiences of using NRCPD yellow badge holders?
  • Does the NRCPD yellow badge assure competence and quality?
  • What do interpreters see that’s not right in interpreting?
  • How many more would complain if it was as easy as pressing a button?
  • Is the NVQ system fit for purpose?
  • How do NRCPD’s CPD requirements address interpreting shortcomings?
  • Do we need a more rigorous test of interpreting, post qualification?
  • Is NRCPD really policing interpreting?
  • Does NRCPD have the personnel to understand what is happening on the ground in the interpreting world, or to find imaginative and sustainable solutions?

What would address shortcomings?

  • Statutory regulation? I don’t think so.
  • CPD in its current form? I don’t think so.

In recent months there have been two high profile court cases in London, involving Deaf defendants on serious charges, where registered interpreters have been told to stand down by a judge, following complaints by Deaf defendants and other interpreters. This is serious stuff. But nobody complained to NRCPD (as far as I know).

We could go on and on with anecdotes about sub-par performance, but we know why only a tiny number complain. Interpreting is a transient event, usually in a private space and rarely recorded.  This makes it difficult to gather evidence for a formal complaint.  However, it is clear when talking to Deaf consumers and interpreters, that there are worrying registered interpreters out there. Why can’t NRCPD proactively monitor interpreters when concerns are raised which are difficult to turn into formal complaints? Why isn’t there an interpreters’ MoT to identify weaknesses?

Before NRCPD points the finger at “cowboys” outside the fold, what is it doing to sort out what is under its control?

I’ve been a long-time supporter of the principle of registration. Even if the rhetoric rarely matched the reality, I paid my annual fee. I’d imagined that once the majority of people being paid to interpret were registered, that standards would be cranked-up. But far from that, NRCPD has become a pointless encumbrance, driving people away from registration. NRCPD is now part of the problem, not the solution.

What’s the connection between doing a CPD activity, writing about it, and high interpreting performance? Is there really any realistic prospect of Statutory Regulation in the next decade?

NRCPD needs to urgently reform itself if the whole registration system is not to go into melt-down (and I’m conscious that this contribution could precipitate that). Where is the credibility and leadership to address the real concerns of Deaf people and interpreters?

Communication Support Crisis in Scotland

Submitted Anonymously

Much has been said about the national shortage of British Sign Language/English Interpreters compared to countries such as Finland. Over the years, there have been various initiatives to increase their numbers and improve professional regulation. In Scotland, there are around 80 BSL/English interpreters registered with either NRCPD or SASLI, covering approximately 13,000 BSL users.

Action on Hearing Loss (AoHL) estimates that there around 850,000 people with a hearing loss in Scotland. The majority of these communicate using English. They rely upon communication support provided by speech to text reporters (STTRs), electronic or manual notetakers, and lipspeakers.

Collectively, this group is known as Access to Communication in English (ACE) professionals. NRCPD is the only body which holds a register for all of the ACE professions.

So there are lots of registered ACE professionals, aren’t there? In fact, there are only three registered ACE professionals for the whole of Scotland. That is equivalent to one registered electronic notetaker or lipspeaker for every 283,000 D/deaf people.

A further eight are eligible, but not registered with NRCPD. The figures are similar for Northern Ireland and Wales, with only a moderate improvement for England. Deaf English users are unable to access registered communication professionals when and how they need to.

Signature withdrew its entire portfolio of ACE qualifications in 2011. Since then, there has been no training pathway towards NRCPD registration for notetakers or lipspeakers anywhere in the UK.   To compound the problem, NRCPD no longer recognises the old Level 2 lipspeaking or electronic/manual notetaking awards for the purposes of registration. There is a new Signature lipspeaking course due to be launched soon.

For electronic notetaking however, the only formal qualification available is an Open College Network Award. This is run by training centres in London (City Lit) and Manchester. This award has still not been accredited by NRCPD and does not lead to registration status.

Why is registration important?   NRCPD registration ensures that you have met the national occupational standards (NOS). Registrants agree to adhere to a code of conduct and abide by a formal complaints procedure. This protects service users and ensures that confidentiality will be maintained. Registrants must also hold professional indemnity insurance, have undergone criminal records checks and commit to at least 30 hours of continuous professional development each year.

In Scotland, there are no registered verbatim speech to text reporters. Therefore, electronic notetakers provide a non-verbatim communication service. They work in the same domains as BSL/English interpreters. This includes all levels of court, tribunals, police interviews and medical settings.

The Scottish legal system largely recognises the importance of using qualified, registered BSL interpreters. However, this is not the case with electronic notetakers. The emergence of “Remote Respeakers” is set to complicate matters further still.

Remote respeakers use voice recognition technology to produce live captions at meetings and events. Currently there is no recognised respeaker training programme that leads to NRCPD registration.

For BSL interpreters, there is a risk of co-working with unqualified, unregistered electronic notetakers or respeakers. Each of these produce a permanent record of the interpreter’s English interpretation. Most of these people are not registered so if there is any dubiety over what appears in the transcript, then it’s the SLI who is more likely to be sanctioned since only the interpreter will be registered.  Many interpreters do not seem to realise that the Electronic Notetakers are unregistered, or in some cases, unqualified. Increasingly, they are expected to provide a transcript of the discussion not just to clients but event organisers. The transcript might then be shared with a wider audience or even published online.

If a complaint is made to a registration panel about the accuracy of an interpreter’s words in a transcript, only the registered communication professional can be disciplined. How would this affect the interpreter’s insurance cover? This has yet to be tested.

What can be done to address this situation? Deaf people should be able to access communication in their own language. Whenever, and however they need it. If booking an electronic notetaker or lipspeaker, ask if they are qualified. Ask if the communication professional is registered with NRCPD. Ask if they hold any qualifications. And if not, why not.

NRCPD Statutory Regulation Survey

The NRCPD have sent out a survey to communication professionals to assess their thoughts on statutory regulation. The deadline is Friday 11th July.

My answers are below. If anyone has any comments please post in response:

1. Do you support the NRCPD aim of statutory regulation? Yes

I support the aim of statutory regulation. I am not convinced the NRCPD are the right body to hold this as it is still not independent from Signature/CACDP and I haven’t been happy with the way UKCoD have dealt with the AtW enquiry and how interpreters have not been involved as much as they should have been.

2. Do you think requiring registrants to agree to a code of conduct is a good thing? No

The Code of Conduct is too prescriptive and does not allow for the breadth of ethical decision making that a BSL interpreter has to practice every day. The Code of Ethics was much better and reflective of other professions. A teological approach to ethics rather than deontological would be much more suited in the case of interpreters. This is a much more up to date way of thinking in the interpreting profession (see Dean and Pollard’s Demand Control schema).

3. Do you think requiring registrants to continue their professional development is a good thing? Yes

I agree with CPD but do not agree with the way that NRCPD have mandated that some hours should be structured but also limited to only courses about interpreting. This has created a market for CPD courses but not increased the value of CPD to practitioners of more than five years post qualification. For example I would like to attend courses on voice production, mime and another language. I believe these would all enhance my work as a practitioner but none of these courses would fit the NRCPD’s criteria. I have completed most of the courses that are on offer in the market and am struggling to find anything that would enhance my professional development.

The rather arbitrary numbers allocated to structured and unstructured do not make sense and were not created in consultation with interpreters.

The more experience one has the more unstructured CPD is completed rather than structured: peer supervision groups, clinical supervision, evaluating ones work, attending or facilitating interpreter meetings, volunteering for interpreter organisations, reading research and articles.

I also do a number of hours of voluntary interpreting which I often record and evaluate.

I would recommend that NRCPD readjust the hours of structured and unstructured or rather put the total amount of hours an interpreter should complete without being prescriptive.

I would recommend that NRCPD allows courses indirectly related to interpreting to be counted as CPD.

I would recommend that NRCPD consult interpreters when reviewing CPD.

4. Are you willing to meet with members of the NRCPD Board to discuss statutory regulation, continuing professional development and the code of conduct’ if the opportunity arises? Yes

Further comments:

The NRCPD should consider asking TSLIs to take an ASLI trained mentor and provide funding to ASLI to provide this. Currently any RSLI can support a TSLI and they would not necessarily have the skills to offer that support.

Before any statutory regulation takes place Signature should be completed independent from NRCPD.

The alternative would be that another body holds the power to regulate.

When representations about interpreters are made to government the NRCPD should be representing the interests of interpreters as well as Deaf people rather than the view of Signature or UKCoD. This represents a direct conflict of interests and independence is paramount