This policy covers the minimum standards to use when producing information. There will be a toolkit to give guidance to council staff on how to produce information in alternative formats or languages. This is being developed. For help before the toolkit is available please contact the relevant sections listed at the end of this policy. The policy includes:
1.1 Introduction and background
This section of the policy deals with how to provide information for disabled people. They can choose the format when it's reasonable, for example by computer, audio tape, sign language, Braille, disc or large print and so on.
Disabled people asking for information should not be disadvantaged in terms of time, convenience, effort or comfort. Sometimes it may not be necessary to produce information in another format if it can be provided face to face by a member of staff, and the disabled person is happy with this.
The Disability Discrimination Act (DDA) 1995 creates rights for any person defined by the Act as a disabled person. They should not be at a disadvantage when provided with goods, facilities and services. It should not be "impossible or unreasonably difficult" for disabled people to use services and this includes getting information.
The DDA requires people providing a service to look ahead to where there may be barriers to getting information or services and to remove these barriers. The Act says that people providing a service should make 'reasonable adjustments' to services. This can be by providing extra aids and services to make sure that disabled people are not disadvantaged. So we must make sure, when it is reasonable, that disabled people get information in different formats such as Braille, audio tape, computer disc, large print, in sign language and so on.
The law uses the phrase 'reasonable adjustment' to give some flexibility and allow for different solutions in different situations. The Disability Rights Commission (DRC) Code of Practice advises that 'reasonable' may vary according to the:
Type of service provided.
Nature of the organisation providing a service; its size and resources.
Effect of the disability on the disabled person.
1.2 What is "reasonable"?
Things to think about when considering what is 'reasonable' in the DRC Code of Practice include:
How practical is it for the people giving the service to take the steps?
Financial and other costs of making the adjustment.
- The amount of disruption taking the steps causes.
- Money already spent on making adjustments.
- The availability of help with the cost or other help.
Whether taking particular steps would help the person get the information.
1.3 Guaranteed minimum standard for all councillors and staff
All councillors and staff must follow this policy. They will need to:
Know how to provide information in different ways for disabled people.
Provide this free to the disabled person.
Produce leaflets, letters and information offering at least an address, a telephone number, a fax number and an email address. Also include textphone numbers and mobile text numbers where available.
Know how to book interpreters or lip speakers for people who are deaf, hard of hearing or deaf and blind.
Know how to use and encourage others to use Typetalk for people who are deaf, hard of hearing or deaf and blind. This service may also help some people who are unable to speak or have impaired speech.
Offer help to fill in forms and other paperwork.
1.4 How long do we have to reply?
We give a member of the public information in a different format under the DDA, wherever possible, within ten working days. If this isn't possible we'll say why, and a give date when the information will be available.
Essential information will be available immediately in different formats (for example, when following the complaints procedure).
The service will be provided at no extra cost to the disabled person.
Public documents will be written in plain language to avoid problems such as translating local sayings.
People will be kept up to date about when they can expect to get the information they've asked for.
1.5 Guaranteed standards for written information
Below is a checklist of minimum standards for all written information that you produce including email, letters and leaflets. All staff must follow the guidelines below. This will help you to comply with the Disability Discrimination Act 1995.
Point size 14 should be used wherever possible. Point size 12 is the absolute minimum.
All text should be left justified.
- Use a plain type face. For further information please refer to the Corporate Identity Protocol.
- All information and documents (whether internal or external) should be produced in plain English, this is not an alternative format but a style of writing that is standard practice
- Do not put writing over pictures or watermarks.
- Writing should always be in maximum contrast to the background, for example, black on yellow or white.
- Do not use block capitals, italics or underlining. Use bold instead.
- Offer information in different formats on all letters and leaflets including Braille, sign language, videotape, British Sign Language (BSL), large print, computer disk, email, and easy read.
1.6 Publicising accessible information
We will make sure that members of the public know about how important we know it is that everyone can get and understand our information.
1.7 Disability Equality Duty
We have a duty to promote equality for disabled people. It is a duty by law under the DDA 2005 to encourage disabled people to be involved in public life. This might include:
All notices advertising public meetings of council committees, public consultations and so on should include a standard notice. The notice confirms that people can ask for and be given all forms of help with the spoken language (known as Language Support Professionals (LSP).
- Any DVDs either used by us for staff training or given to the public should have English subtitles as standard, and should ideally also offer British Sign Language.
2.1 Introduction and background
Where language is a barrier to communication, translating information into a language other than English is one possible solution. Where this is an option we also have to consider other issues. These are:
Is translating the information the best way to provide it?
Does translating the information help make people feel more equal, to feel included and draw together the community, or does it stop us achieving these goals?
Is translating the information the right way to use our limited money and staff time?
We already deal with translation in a way that takes account of many of the issues described in this document. But we want to set this out clearly in a written policy, to make sure that we all take translation decisions in the same way, being fair and clear in the way we work.
In the past, we have translated documents into a set number of languages. But we know that in a city where over 100 languages are now spoken this is not the best way to decide who gets information translated. Although there are lots of languages spoken in the city, this doesn't justify translating into every language. We need evidence that translating information improves understanding, draws people together and is the best use of our time and money.
Some non-English speakers may not read their own language and some languages do not have a written form. For these, translation is no use and information would need to be provided differently; for example, by speaking or by demonstrating. Research has shown that some people, whose first language is not English, prefer spoken English to written translations. Audio tapes in English can reach a wide audience and our Translation Service can arrange for documents to be written out for audio tape.
This policy sets out where we stand on these issues and our approach to providing translation services. It is a brief statement of principles and also a practical tool to help staff to decide whether a translation is the best thing to do. A checklist at the end of the document simplifies and standardises how to reach a decision.
2.2 National context
In December 2007, the Department for Communities and Local Government (DCLG) gave a lead on using translation to help cohesion and integration.
The DCLG guidance responds to "Our Shared Future", a Commission for Integration and Cohesion report published in July 2007. This report looked at how communities live together in England and Wales and suggested ways to improve things.
One result from an opinion poll showed that many people see a common language as a key part of communities pulling together. The Commission took the view that automatically translating documents into other languages could weaken the importance of English of helping citizens to talk to one another, to connect with one another, to find work and to take part in a shared life.
The Commission also saw that local authorities are best to decide what's right in their own area. Guidance on translation can be found here.
Our policy takes account of both our own and local issues, and of how we fit into what's happening in the country. We will continue to agree with translation where it's clearly needed, but will change the previous approach of translating into a 'set list' of languages.
A new policy will need to fit in with the aims of our plans for making sure everyone is included and treated equally and that different groups of people are able to live together.
2.3 Our current provision
Our Translation Service arranges translation of written documents for both our services and for external customers. You can find out more about this service in the toolkit.
We also have a contract for telephone interpreting to help us speak to customers without English as a first language. We are also part of a consortium of local authorities and NHS trusts that buys-in face-to-face interpreting from the Newcastle Interpreting Service (NIS). There is more information on these services in the interpretation section of this document and in the toolkit.
2.4 Translation principles
There is no law saying all materials should be translated. The Race Relations Act says that everyone should have access to services - translation may or may make sure of this. The Human Rights Act only insists on translation if someone is arrested or charged with a crime.
The guiding principles for this policy are as follows:
We do not encourage translating into a 'set list' of languages for the reasons we said above.
We should only translate when it's proved that it's needed.
We should think about methods other than translation, such as using plain English, interpreting or providing a summary.
We need to think about giving people the chance to learn English, particularly English for Speakers of Other Languages (ESOL) (see below).
It may be right to translate if:
It's really needed, for example, to make sure that non-English speaking residents are able to get important services.
There is a basic human right, for example, to help people to vote.
- Translation helps people live together. For example, to help local groups or go-betweens who work with people new to the country or non-English speakers.
There's no other way to speak or write to someone.
Translation directly helps people to fit in. For example, to make sure that people understand rules and customs, such as getting rid of rubbish or where you can park.
We need to keep the law, for example, if we can't speak or write to someone we'd be breaking the Race Relations (Amendment) Act 2000.
Translation may not be the right thing to do if the following is true:
Where the information may not be needed. For example, council plans and reports not likely to be read by most people.
Where the information could be provided differently. For example, translating complicated leaflets where what is really needed is sending someone to a service.
Where translation is based on a set list of languages, without thinking about who the information is for.
Where the staff and cost involved in translation could be shared with other organisations.
2.5. Encouraging people to speak English
For our suggestions above to work, we must give people a real chance to learn English.
Often, providing information in plain English, an easy to read style, would make sure that more people understand it. This is not just for those speaking English as a second or other language, but also for people who don't read very well.
Newcastle also has an ESOL service with English classes all over the city. This helps people who speak other languages with reading, writing, speaking and listening, plus helping them train for work and find out about courses. ESOL staff speak 17 languages between them. This helps people to join a class and to introduce them to the course. It also helps ESOL get in touch with hard to reach people through community groups.
But we would need to make sure that ESOL would be able to deal with anything that happened as a result of our new policy, such as more people wanting to learn English.
2.6 Making sure people are included and that communities join together.
We clearly need to help all 'at risk' communities and encourage good relations between our existing and newer communities. We have set ou t how we will do this in our Social Inclusion, Equalities and Community Cohesion strategies.
Some key issues are as follows:
Should translated material contain a passage in English to say why it has been translated?
Explaining clearly to others why a document has been translated will help to make sure that people don't get annoyed about 'special treatment'. We need to be open and clear about why a translation is needed to stop other groups having hard feelings about it. We have to weigh up avoiding hard feelings with the need to inform someone with translated information.
Is translation helping groups join together, or is it stopping it?
In many cases, it may be a stepping-stone - for example, by helping people to get important services and therefore take part more fully. In other situations, it may be a barrier - for example by encouraging some groups to see learning English as less important.
2.7 Should I translate this?
The checklist below will help you to decide when, what and for whom to translate:
Is it essential to translate this document?
Who is the document for? For example, is it young mothers, pensioners, workers and so on and do they include people who don't speak English?
Can you give good reason for translating the document?
Do you have proof that people will miss out without this translation?
Do you have the right information about who can't speak English locally, and is it being updated as we find out about local changes?
What would be the cost of not translating these materials - would it cost us or other organisations more in the long run?
What is the affect of not translating a document, for example, would it stop people being able to take part in their community?
Are there other ways of getting information across, such as by working with other organisations?
Does all the document need to be translated?
- Are you sure that people will read well enough to understand this document?
- Should it first be made simpler through plain English, summarised or could you use pictures?
- Are you doing what the Disability Discrimination Act 1995 says to make sure people can understand information?
- Could it be translated when asked for rather than before it's asked for?
- Have you considered the cost of translating the document against the benefit of the information contained in it?
- Will the translated information be used in full, or is it likely that it will sit on the shelf?
Working in partnership with other agencies.
Could community groups, partners, or some other method, do a better job of giving the information out?
Have other local or national agencies already translated the information and could you use it?
Is there any way of doing this that is recognised nationally as the best way?
Issues around drawing together the national best practice?
Community cohesion and integration issues.
Is translation part of wider plans to draw together the community? Does the material fit well with your overall plan to keep residents, both settled and new, informed?
Have you considered whether other communities might feel left out by not having information translated for them? This isn't a reason not to translate something but you may need to explain why one group has information translated and another doesn't.
Have you got a welcome pack for people new to Newcastle? Is it held on a computer, or in another way that is easy to update? Does it include details about learning English and interpreting services?
Is it absolutely necessary to translate the information considering all the things mentioned above?
Which information is it right to translate?
Should we translate information when it is asked for?
By providing a translation are you encouraging people to learn English too?
Have you considered the effect on people who use the translated information and also how people who speak English might see it?
Many staff regularly deal with customers whose first language is not English. We have some guidelines for this policy.
Never ignore someone if you don't understand him or her.
Speak more slowly than usual, using short sentences.
Ask 'open' questions such as 'when', 'why', 'what', 'where', 'who', instead of questions where the answer is 'yes' or 'no'. Answers to these types of questions will let you know if you have been understood.
Use clear gestures to show what you mean.
Get help from an interpreter if needed.
In most cases, it should be clear that it isn't right to use friends or family members to interpret. There are a number of reasons for this, including:
To make sure you don't break data protection laws by keeping your discussion with the person private.
It may be important for the conversation to be private, for example when talking about their health.
To make sure that information is being spoken accurately by interpreters who we know can speak both languages well.
3.1 Telephone interpreting
We have a contract with a company for telephone interpreting. Staff are advised to use the phone interpreting service to get initial information from customers and/or to arrange an appointment to have a face to face interpreter present. Information on how to use this service is included in the toolkit.
3.2 Face to face interpreting
We have a service level agreement with Newcastle Interpreting Service (NIS) for face to face interpreting. Staff can contact NIS direct to book an interpreter. NIS has a handbook for staff who use interpreters and can train staff in working with interpreters. Information on how to use this service is included in the toolkit.
4. For more advice
For Easy Read contact:
Bill Norman, Valuing People Co-ordinator - Phone: 0191 211 6435, Email: email@example.com
For all other information contact:
Angela Hamilton, Principal Policy and Research Officer - Phone: 0191 211 5019), Email: firstname.lastname@example.org