2017.01.26 PI4J email to Warwickshire and West Mercia Police re outsourcing of Language Services

West Mercia and Warwickshire Police Alliance

Chief Constable Martin Jelley
Warwickshire Police
By email: martin.jelley@warwickshire.pnn.police.uk

Chief Constable Anthony Bangham
West Mercia Police
By email: anthony.bangham@westmercia.pnn.police.uk
26 January 2017

Dear Chief Constable Jelley and Chief Constable Bangham

Re: West Mercia and Warwickshire Police Alliance language services

Professional Interpreters for Justice (PI4J) is an umbrella group representing over 2,500 interpreters from both the National Register of Public Service Interpreters (NRPSI) and the National Union of British Sign Language Interpreters (NUBSLI). Our aim is to work with government to ensure the quality of interpreting available to the Justice System and in the Public Sector.
Reliable communication provided by qualified professional interpreters and translators is an essential resource which ensures that justice and human rights are upheld for non-English speakers and deaf people. This is put at risk if standards are dropped and quality is sacrificed.
PI4J has been at the forefront of the professional interpreters’ campaign against the unacceptable lowering of standards and quality in public service.

PI4J has become aware that the Warwickshire and West Mercia Police Forces are in the process of reviewing the procurement of translation and interpreting services.

Currently both Forces source local interpreters and translators directly from the National Register of Public Service Interpreters (NRPSI) and the National Registers of Communication Professionals working with Deaf and Deafblind People (NRCPD) which maintain registers of professional, qualified and accountable legal interpreters. Payment rates are set in accordance with ACPO guidance issued in 2009. We believe this system has served you well for many years and there have not been any supply or quality issues.

However, Warwickshire Police’s response to a recent Freedom of Information Request for details of any procurement exercise aimed to shape the future strategy in relation to language services, indicated that it is currently participating in a collaborative further competition conducted through the Crown Commercial Service (CCS) Language Services Framework RM1092, aimed to be completed during January 2017 and implemented in April 2017.

PI4J has grave concerns in relation to the outsourcing of language services to commercial agencies.

Although we understand the need for police forces to increase efficiency and reduce costs, we have a direct interest in the most important aspect – that of maintaining the quality and fitness for purpose of public service interpreting provision with a view to protect the public.

This is put at risk if standards are dropped and quality is sacrificed for profit by agencies, as is demonstrated in the UK courts where the Ministry of Justice’s outsourcing of interpreting services through a widely discredited commercial contract since 2012 has and continues to cause untold problems due to failures to provide interpreters or through the supply of unqualified, inexperienced and incompetent interpreters, resulting in disruptions and delays to criminal trials.
It has also led to a massive market exit of skilled and experienced interpreters in that sector. These interpreters are still currently providing services for Police Forces such as yours.

PI4J strongly believes that outsourcing of language services to the private sector is not the solution for the current issues faced by the UK police forces. We believe that a system of competitive tendering where the lowest bidder wins will lead to unfavourable terms and conditions for legal interpreters, who can and will transfer their expertise to other areas of work as they are self-employed independent professionals.

Not-for-profit alternatives must be considered. Setting up a booking and payment centre to provide services efficiently and effectively whilst preserving the National Agreement on Arrangements for the use of Interpreters (NA) and the independent regulatory bodies would lead to significant savings and would not have a detrimental effect on the delivery of justice.

One example of how this can be achieved is the Metropolitan Police Service, which has achieved significant savings by streamlining their system. Their interpreters are subject to strict guidelines and the NRPSI Code of Conduct, but are also paid rates which are commensurate with their skills and the degree of responsibility of their work.

Cambridgeshire Constabulary has also been able to produce year-on-year savings on interpreting costs by means of careful cost management and efficiency savings. The force enjoys an excellent relationship with its interpreters and is not plagued by availability problems.

Equally, the Welsh forces have been able to achieve savings of between 30 and 50% by working with the not-for-profit Wales Interpretation and Translation Service (WITS).

One of PI4J’s aims is to work with the government to ensure quality and standards of interpreting available to the Criminal Justice System and to provide guidelines to public service providers in respect of their language service provision.

In April 2016 Professional Interpreters for Justice (PI4J) made strong representations to both Warwickshire and West Mercia Police Forces by email indicating our position in relation to outsourcing of language services and the use of framework agreements, including the CCS. Please see attached copy of our letter to you, which was also forwarded to the National Police Chiefs’ Council (NPCC).

Following on from this, PI4J representatives, including the NRPSI, met with the NPCC Strategic Group for Language Services on 11 November 2016 at the Home Office. This meeting was attended by Ian Fraser (National Procurement Lead), Sally Conquest (Home Office Lead), Barry Nicholson (Metropolitan Police Lead for Language Services) and DCI Sarah Shrubshall (Staff Officer to CC Cole, NPCC Lead for Language Services).

There was a positive exchange of views and a further meeting is to be arranged in March/April of this year. It is hoped it will become a regular event, to the benefit of both parties. We understand that the NPCC National Working Group on Languages was informed about the focus of our discussions at this meeting, and we trust this information was forwarded to you.

We wish to reiterate the main points made by PI4J during this meeting in relation to the essential aspects which should be enforced by all Police Forces when considering their provision of language services.

These were set out in our follow-up email to the NPCC Strategic Group for Language Services (copy attached).

These include:
- Police Forces’ observance of the National Agreement (NA) on Arrangements for the use of Interpreters in the CJS (revised 2007). The NA provides guidance on arranging suitably qualified interpreters when the requirements of Articles 5 and 6 of the European Convention on Human Rights (ECHR) apply.
- A requirement for all interpreters providing services to police forces to be registered with the profession’s regulatory bodies (NRPSI and NRCPD), in the same way the Metropolitan Police Service does.
- Both NRPSI and NRCPD exist to protect the public by regulating communication and language professionals.
- All Registrants are subject to the regulatory bodies’ Code of Professional Conduct and allegations of professional misconduct are investigated by the Disciplinary Committee, at no cost to service providers.
- Vetting to the appropriate level must be facilitated for all interpreters registered with the regulatory bodies NRPSI and NRCPD.
- Just as important is that sustainable rates of pay must be maintained for interpreters and translators in order to retain the number of interpreters currently working and attract new interpreters to the profession.

The use of the National Agreement and mandatory NRPSI/NRCPD registration will support the regulation and professionalisation of interpreting in the criminal justice sector.

The aim is for regulation by law and protection of title. This is to ensure high standards and a qualification based selection, and offers protection to both the interpreter and Police Forces since registered interpreters are suitably qualified and vetted.

We ask that you maintain all the necessary safeguards to ensure the quality and standards of such a vital service provided to members of the public, whether they are victims, witnesses or suspects, and include many vulnerable people.

Without appropriate safeguards to protect and uphold basic human rights, the interests of justice cannot be served for those who cannot understand the proceedings.

PI4J would be very happy to meet with you to assist in the review. We believe that we can provide you with valuable support in maintaining the appropriate level of quality police service and public protection.

We look forward to hearing from you further.

Yours sincerely,

Professional Interpreters for Justice (PI4J)

PI4J: What are we asking for?
1. The use of qualified interpreters
2. Full consultation with the interpreting profession
3. Sustainable terms and conditions to be offered to interpreters
4. Independent auditing of quality and performance
5. Independent regulators: Regulation and the maintenance of registers should not be in the hands of private providers
6. Minimum levels of interpreter qualification
7. Statutory protection of title
Professional Interpreters for Justice (PI4J) Member Organisations:
Association of Police and Court Interpreters (APCI) – chairman@apciinterpreters.org.uk
Cymdeithas Cyfieithwyr Cymru; (CCC) – geraint@cyfieithwyrcymru.org.uk
Institute of Translation and Interpreting (ITI) – chiefexec@iti.org.uk
National Register of Public Service Interpreters (NRPSI) – chairman@nrpsi.org.uk
National Union of Professional Interpreters and Translators, part of Unite the Union (NUPIT) – nupit@unitetheunion.org
National Union of British Sign Language Interpreters part of Unite the Union (NUBSLI) – branchsecretary@nubsli.com
Society of Official Metropolitan Interpreters UK Ltd (SOMI) – board@somiukltd.com
The Chartered Institute of Linguists (CIOL) – keith.moffitt@ciol.org.uk

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