Q1 - Please let us know anything you think we need to understand regarding how effectively regulation works within the sectors in which you have particular interest or expertise.
This response relates to professional linguists working as interpreters and translators in different sectors, including conference, business and public service interpreters.
Regulation of these sectors is varied and tends to be through voluntary registration or assessments carried out by individual employers or agencies. It is reliant on a range of professional qualifications and assessments carried out and awarded by a variety of different bodies.
Where frameworks or regulation are in place, quality is more assured. However, the landscape of supply and demand is complex and includes a large proportion of freelance professionals. There is no guarantee that all parts of public services or commercial employers are aware of the need to verify qualifications and use qualified interpreters. For this reason, it is important to understand the nature of supply and how best to support its regulation effectively through a single national professional qualifications framework of reference that is easily recognised and understood by all stakeholders and all sectors.
Interpreters and Translators are highly skilled professionals. Most will have graduate and postgraduate academic language qualifications (based on our latest research over 80%) and many will have postgraduate professional (i.e. vocational) qualifications in teaching or translation (over 50%) including a proportion who will have the highest level of postgraduate professional qualification the CIOL Qualifications Level 7 Diploma in Translation.
Currently different public service sectors require different levels of qualification and experience against what is both a heterogeneous and complex ‘supply side’ with individual linguists, Language Service Providers (LSPs) and publicly produced contract holders matching complex demand (very different contexts and many languages at many levels) with equally complex supply (many freelance translators and interpreters and many LSPs).
A clear national framework would help both the supply and demand side and enable a clearer career path for linguists - which along with fairer pay - would improve the pipeline of linguistic talent which is currently insufficient to meet the needs of public services and business.
Recognising the complexity of the landscape the Chartered Institute of Linguists (CIOL) as the profession’s independent Chartered body has offered to help develop a better qualifications and recognition framework for professional linguists, with the input of business and public services, as a formal proposal and representation to HM Treasury in the Comprehensive Spending Review submitted on 24/9/20.
Q2 - Please let us know anything you think we need to understand regarding how accessible the regulatory system is within the sectors in which you have particular interest or expertise.
There is a role for professional bodies to play - not least our own, CIOL - to clarify and provide structure to enable linguists, Language Service Providers (LSPs), public services and businesses to better understand each other's needs.
The regulatory framework at present relies largely on the Regulated Qualifications Framework (RQF) for general and vocational qualifications regulated by the Office of Qualifications and Examinations Regulation (Ofqual). Professional linguists also enter the profession with undergraduate, masters and postgraduate qualifications.
Others with strategically important languages may have limited access to professionally recognised languages, but are highly skilled and experienced with limited access to the accreditation of prior experiential learning (APEL).
To understand how these relate to operational standards in practice, which can be regulated effectively, an accessible overarching framework of reference and assessment process would be invaluable. What is needed is a framework of professional levels and standards, as you find in other professions, something that is present within some government departments whose sectors use linguists and language professionals (already the case in part with the police, MOJ and CCS).
Such a framework could also support and be promoted as an enabler and a standard for business in the context of renewed focus on international trade and competitiveness, as the economy tries to rebuild, overcoming the challenges of COVID 19 and the inevitable disruption of leaving the European Union and engaging in wider global markets, where English may not be the dominant language.
We need to give UK businesses support and commercial advantage, by encouraging them to use professional linguists for interpreting and translation from a recognised framework. This will not only help them in communicating effectively, but also in localising and tailoring their propositions to demanding international audiences and markets.
Q3 - Please let us know anything you think we need to understand regarding the extent to which the regulatory system is proportionate and/or offers good value for money (for all stakeholders) within the sectors in which you have particular interest or expertise.
Given the relatively small size (in value) of the professional languages sector, a lighter touch, but nonetheless rigorous and reliable, professional/vocational framework for practical and professional qualification could enable public services and businesses to get the services they need more readily and at more consistent value for money; and also could attract more potential linguists into the sector.
The aim would be to create a clearer, simpler framework and standards that are self-sustaining after the initial investment, against clear professional needs and an assessment framework. Training providers, colleges, universities and other organisations would be able to deliver professional training more effectively within such a framework with some support and oversight from CIOL and other partners, together with the relevant public and private sector stakeholders.
Q4. Please let us know anything you think we need to understand regarding how effectively the regulatory system serves public interests within the sectors in which you have particular interest or expertise.
Public Sector Interpreters who choose to self-regulate through professional registration, or membership of professional organisations which are subject to codes of conduct and practice, help to ensure that the interests of the general public are safeguarded and that professional standards are upheld. However, there are interpreters working through a wide range of agencies across different sectors where regulatory practice varies and is less likely to draw on a consistent set of standards.
The risk with the lack of a professional framework for linguists, which can be applied across all fields of interpreting and translation, is that the profession is less well structured which affects its status and perceived value and leaves stakeholders less confident that their interests will be well served. A negative outcome from this situation is that the profession is inadequately resourced and fails to attract sufficient linguists of appropriately high standards to meet the demand from private and public sectors, including crucial support in public service translation and interpreting for the Criminal Justice System, Police, National Health Service and other important public services.
The challenges and opportunities for the UK post-Brexit mean the demand for qualified interpreters and translators will be greater than ever: to support UK trade and investment, businesses and our diplomatic and international relations. But at present it is unlikely to be met.
A better framework for Professional qualifications - which CIOL has offered to help develop - would deliver considerable public value, and support trade and investment and the UK’s standing in the world, and would underpin professional standards in interpreting and translation across all sectors, improving public services in all aspects of civil society