Critique of the Framework Agreement's Equality Impact Assessment (EIA)
As part of the 2011 Framework Agreement on the Use of Interpreters and Translators in the Public Sector, an EIA was carried out. This was flawed in the sense that it misinterpreted an already unsatisfactory survey in order to bolster its argument that the FWA would have a reduced impact on BME’s (Black Ethnic Minorities). This earlier survey, on which the EIA was based, was CILT’s 'Labour Market Intelligence for the Qualifications Strategy in Translation and Interpreting (2008)'.
According to the EIA, this CILT report suggested that, in the UK, ‘nearly half the [interpreting & translating] work-force are native English speakers. Approximately 40% are native speakers of another language and the remainder are bilingual (brought up speaking two languages)’. In fact the EIA is referring here to the following extract from the CILT report: ‘1.3.3 Nearly half the [interpreting & translating] workforce (48%) are native English speakers. Slightly fewer (40%) are native speakers of another language and one in ten are bilingual.1.3.4
Earlier research by Schellekens (2004) found that 44% of the language professionals originated from the UK; 30% from EU; 11% from Eastern Europe; and 12% from the rest of the world:... 48% individuals worked as translators; 9% as interpreters; and 42% as both interpreters and translators.’
The CILT report and the Schellekens report it quotes, both reach the conclusion that nearly half the interpreter/translator workforce are native English speakers (48% & 44% respectively). And this is a statistic that the EIA repeats in its analysis of the impact of the Framework Agreement (p.13). Thus the EIA conveys the impression of a workforce that is, to a great extent, indigenous in origin, with the corollary that serious issues relating to BME do not therefore arise. Yet neither the CILT report nor the Schellekens report take account of the inclusion of British Sign Language in their surveys, specifically in regard to BSL's potential to skew the reports' demographic conclusions (see Schellekens p.9: 'A number of specialist BSL training providers, interpreters and agencies participated in this research project...; pp.12/13: ‘…organisations reported problems recruiting staff in specific languages. Half of these needed British Sign Language interpreters; see also CILT pp. 15, 19, & particularly p. 53 where it states: ‘there is a need for greater supply in relation to wide range of languages but particularly Eastern European languages, Middle Eastern languages, Chinese and British Sign Language (BSL))’.
The undifferentiated inclusion of BSL - as just one more foreign language among many - will have inevitably distorted the conclusions these reports have drawn regarding the indigenous flavour of the industry's practitioners. Furthermore, if the CILT and Schellekens surveys had contacted organisations that had a relatively large number of BSL interpreters on their books, this will have tended to inflate the figures for native linguists, thereby supporting the impression that native linguists - who constitute the vast majority of BSL interpreters - are also a dominant force in the interpreting of foreign languages.
On a related tack, the CILT report shows that the same percentage (48%) of the work-force that are ‘native speakers of English’ are also ‘non-interpreting translators’. It is likely, therefore, that there is a close correlation between the native element of the work force (48%) and the non-interpreting translator element (also 48%). In other words, most native workers are not involved in the public service interpreting sector at all, but are trained in specialist translation disciplines. A corollary of this is that the vast majority of public service interpreters will be foreign nationals, not born in the UK. As such they represent a significant BME entity & should deserve a full EIA given the impact of this procurement consultation on their livelihood.
If the 'Better Trials Unit' had had any desire to fully investigate the BME impact of their proposed regulations, they could have easily conducted a survey of all those professional public service interpreters registered on the two main websites (www.nrpsi.co.uk & www.apciinterpreters.org) to find out their ethnic origin. They would have discovered that the vast majority were not natives of these islands. The report quoted by CILT, namely Schellekens (2004), makes the following comment on the interpreters it consulted (p.7): ‘3.5 Choice of domain: Freelance interpreters and translators and companies reported that commercial clients provided by far the most employment; and that business formed the largest domain.’
In fact, in 2004 there were very few agencies or ‘businesses’ that had any role in booking interpreters for work in the public sector. To my own knowledge none of the police forces or courts I was working for at that time were outsourcing work. One can only conclude that the freelance interpreters consulted by this report, had nothing to do with the public sector. This survey is therefore flawed as an indicator of the character of the public service interpreting domain at that time. The same Schellekens report issues a caveat on its statistical reliability (p.2): ‘Although we have no information on the exact size of the interpreting and translation industry, we can say that the number of respondents [to our survey] is low in relative terms and that as a consequence no statistical relevance can be derived from the information in this and the underpinning reports’.
Thus, the report itself seeks to dissuade the reader from putting any weight on its statistical findings. Meanwhile the CILT report itself is flawed in its statistical reliability. It admits that the liberal use of freelance interpreters within the market makes information-gathering problematical (see p.5: Collecting numerical information from within the sector itself is also difficult, partly as a consequence of the large numbers of freelancers working in the sector’). For the Ministry of Justice to base its EIA on such a report constitutes a lack of due diligence since the CILT report clearly did not contact many (of the numerous) freelancers as individuals, and yet freelancers were the predominant providers of public service interpreting. Furthermore, the CILT report states on p.8 that: ‘Most professional interpreters and translators will be working for specialist agencies who will in turn offer their services to a hugely diverse range of clients’. In fact, while public service interpreters were by now (2008) joining agencies, these interpreters were still getting the majority of their court & police work directly from the service requester, not through agencies. Meanwhile, the mention of a ‘hugely diverse range of clients’ does not ring true of the client base of public service interpreters who work principally for the UK Border Agency, Tribunals, Police, Courts, Probation Service and Prisons. One feels that the sentence quoted from the report is much more likely to be true of specialist translators and their agencies, than of public service interpreters.
The CILT report as a whole, is skewed by its failure, when drawing broad conclusions, to differentiate between public service interpreters, interpreters working for businesses & translators. It is therefore highly prejudicial of the EIA to use it to bolster arguments that are specific to public service interpreters. Furthermore, the undifferentiated inclusion of BSL (and, by extension, the Britishness of its practitioners) into the statistics, may have given the make-up of the overall workforce a more indigenous character than it deserves.