Chief Constable Simon Cole
Leicestershire Police
National Police Chief's Council (NPCC) lead for
Languages
By email: Simon.Cole@leicestershire.pnn.police.uk
CC: Chief Constable Sara Thornton of Thames Valley
Police, NPCC Chair,
CC: Mr Ian Fraser, Head of Procurement
responsible for interpreting and translation services,
Dear Mr Cole,
Please find below and attached the
submissions in relation to the Crown
Commercial Service (CCS) Language Services Framework Agreement
(FWA) made on behalf of the following
representative bodies which are members of Professional Interpreters
for Justice (PI4J):
· Association of Police and Court Interpreters (APCI)
· Chartered Institute of Linguists (CIOL)
· Cymdeithas Cyfieithwyr Cymru (CCC)
· Institute of Translation and Interpreting (ITI)
· National Register of Public Service Interpreters
(NRPSI)
· National Union of Professional Interpreters and
Translators, part of Unite the Union (NUPIT)
· National Union of British Sign Language
Interpreters, part of Unite the Union (NUBSLI)
· Society of Official Metropolitan Interpreters UK
Ltd (SOMI)
We understand that the CCS has
informed the National Police Chiefs’ Council (NPCC) that interpreters and their
representative bodies are ‘on-board’ and support their Language Services FWA.
This is not the case.
On 25 March 2015 PI4J sent an email
to the CCS outlining our position with regard to the CCS Language Services FWA.
Our correspondence made it very clear
that we cannot support any arrangements or
FWA which does not fully take into consideration all our submissions in respect
of minimum professional qualifications for Public Service Interpreters (PSI)
and BSL/English Interpreters, Deaf interpreters and Sign Language
translators, mandatory NRPSI/NRCPD/SASLI registration, and independent
regulation and quality and performance auditing.
This FWA has not incorporated all our
suggestions and concerns into the specifications and we do not believe it will
fulfil the language demand and standards requirements for the Police Forces and
other agencies serving the Criminal Justice System.
Just as important are sustainable and
fair rates of pay for interpreters, which do not
discriminate between spoken language and BSL interpreters.
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.
Interpreters have demonstrated this for
the last four years by their ongoing refusal to work for the agency to which
the Ministry of Justice outsourced their court interpreting service through a
commercial contract which has been widely discredited, resulting in massive
disruption and a market exit of skilled and experienced interpreters.
They have also refused to work for
other low-paying agencies which show little regard for quality and standards.
The message is simple: unless interpreters are
offered sustainable rates, they will boycott this contract too.
Interpreters are used by the police
services for essential communication with the public, 95% of which is of an
evidential nature for victims, witnesses and suspects and so is required to be
of the highest standard. Failure to achieve the required standard will result
in increased risks of, at the very least, unacceptable delays in justice and at
worst, miscarriages of justice.
Either way it will be accompanied by
increased costs (e.g. keeping people in custody or having to release suspects
due to a lack of interpreters) and reductions in public confidence and satisfaction.
The only way to ensure quality of
result for the victim and fairness for the perpetrator in any case is having
good-quality interpreters, resulting in improved integrity of investigations
and trials, better treatment of victims, witnesses and detainees, compliance
with legal obligations, and good race relations.
We maintain that
there could be more savings in the long term by investing in the establishment
of a central government agency, which is “not for profit” and therefore does
not seek to gain a pecuniary advantage from interpreters’ work. This may
achieve a streamlining of the system and thereby utilise interpreter services
in a more organised and efficient way—dealing with the process of identifying
and booking individual interpreters, as well as with the payment process.
With this in mind, we urge you to
review the Police National Guidance on the use of this and other similar
framework agreements and/or contracts, and consider the alternative solutions
which PI4J presents in the attached letter to Kent Police regarding
their recent decision to outsource interpreting services to thebigword.
We understand that procurement arrangements
are left to the discretion of chief officers when determining an operational
matter such as the individuals or organisations they use to provide services
for their forces.
We therefore request that you please
forward this email to all NPCC Members and other interested parties, in order
to inform them of our submissions.
Yours sincerely,
Professional Interpreters for Justice
(PI4J)
