T9000 interrupts its scheduled broadcasts on the topic of nonsense to bring you this breaking news. A glacial process of reform at Signature/NRCPD, which began a year and a half ago, would finally appear to be bearing some fruit. (I mention merely in passing that Signature has taken in an estimated £300,000 in registrant fees during that time.) Two new things are happening, either or both of which might be cause for concern if you still believe that NRCPD have any relevance to your work.
The first issue is that the governance of NRCPD, the board of trustees, is finally being refreshed: this was announced to registrants by e-mail last week. BD Consulting UK, a private firm, has been appointed to manage the recruitment process of four permanent “registrant trustees”, in the model of several other registers which have four professional members, four lay members and a Chair. This is good news, and what we all wanted. Isn’t it?
The second is that following a good deal of pressure (not to mention about 30 years of academic literature about interpreter “role” and deontological ethics) a revised Code of Conduct has been published in draft form, together with a draft revision of the complaints process. “Consultation” on the drafts has been requested, in the form of two more Surveys Monkey which ask the questions NRCPD wants answered. But this “consultation” fails to meet one of the most fundamental requirements of a consultation: hardly anyone knows it is happening. It has not been announced to registrants by e-mail; it has not been published on any form of social media that I can locate; it was not highlighted in an NRCPD newsletter because NRCPD does not produce a newsletter; it was simply dumped on their website without fanfare, a website which incidentally has no means of keeping in touch with its audience such as an e-mail subscription list or an RSS feed to name just two popular internet technologies which have existed for over 15 years.
Let’s take a closer look at both of these developments.
BD Consulting UK: who are they and how were they selected?
I’d never heard of this firm and thought that I knew most of the major players in Deaf Industry recruitment, so I did a little research.
BD Consulting UK’s website is not exactly forthcoming: DNS records show that the domain is registered to a Mr Byron Davies, presumably the BD in BD Consulting UK. Searching for both Mr Davies’s name and the company name confirms in several locations (for example) that he is the owner and managing director and set the firm up in 2010, but I couldn’t find any information at all about BD Consulting UK’s previous work activity, clients or personnel. It’s almost as though they’re not a fully functioning agency, but I’m sure that’s just the distorting effect of the internet’s lens. They are sometimes described as a “strategic management consultancy working at the interface and adding value to public/private partnerships”, which made me blink a few times but has not yet helped me form a coherent picture of exactly what it is they do.
Mr Davies has had an illustrious and eerily familiar career. He was the Chief Executive of South Glamorgan County Council and Cardiff Council for a total of two decades, and the President of SOLACE, the Society of Local Authority Chief Executives. His CV, while impressive, doesn’t list any experience of interpreting as practitioner or recipient or commissioner of interpreting services, or any experience of working in the Deaf community. Perhaps BD Consulting UK’s employees have that expertise in spades instead. (Edited to add: this Byron Davies is not the same Byron Davies as the Welsh Assembly Member of that name).
The current Chair of NRCPD, meanwhile, is Huw Vaughan Thomas, currently serving his second and final term. Strangely enough, Mr Thomas is also a former Chief Executive of two Welsh local authorities, serving in that role for Gwynedd and then Denbighshire County Councils. He was also for a time the Assistant National Secretary for SOLACE. He’s currently the Auditor General for Wales. Clearly, Mr Thomas and Mr Davies had an existing professional relationship in the context of local government.
All of which begs the questions: why and under what criteria was BD Consulting UK commissioned to undertake this recruitment process? Was it for their expertise in appointing third sector trustees, their knowledge of sign language interpreting? We can’t demonstrate that because BD Consulting UK has absolutely no historical footprint whatsoever. Were any other firms considered? What kind of comparative or competitive process took place? Does the Board – a non-executive body – have the power to commission work in this way? NRCPD has no executive officers, because it doesn’t really exist as a stand-alone entity – so what role did Signature’s execs play in the commissioning? Why do Signature/NRCPD not have capacity to administrate this recruitment themselves?
For myself, this reminds me very strongly of the original “options appraisal stakeholder consultation” last year, which was passed without any apparent discussion or selection process to Cassiopeia, a consultancy with clear links to Sandra Verkuyten OBE, another NRCPD board member. The board meeting minutes disclosing this interest were not published until several months after the consultation had ended. You could argue that both examples of private consultancies being commissioned in this way are simply experienced professional governors using (“leveraging” in their sociolect) their networks to benefit the profession, in their best judgement. Alternatively, you could argue that it was blatant nepotism: governors lining the pockets of their associates with our annual registration fees. Since we don’t really know what takes place behind closed doors or off the record, it would be reckless to make a definitive statement either way.
I’ve written to Signature/NRCPD and asked for more information about the selection of BD Consulting UK. If they respond with anything substantial, I’ll update this post.
The draft Code of Conduct
As part of the assessment process to get on the Master of Arts interpreting programme at the University of Leeds, I wrote an essay comparing the IRP and NRCPD Codes of Conduct for UK sign language interpreters from 2004-2010, and also compared them to the NRPSI, ITI and AIIC spoken language interpreting Codes. A more up-to-date version of the table I used for the analysis (also now including the NAD-RID Code) can be found in the Resources section above; this work (and the work of many other far more talented people) informed my MA research into how interpreters working in education understand their “role”.
So while I don’t claim total expertise on ethics in interpreting practice, I have spent not inconsiderable time thinking about this stuff. At the moment, though, I already have plenty of work to do, not to mention considerable NRCPD survey fatigue. So after one quick scan, my initial opinion of the new draft Code of Conduct is … meh. If you have more energy than me and want to spend any of your time cramming square blocks through the round holes of NRCPD’s predetermined set of survey questions, here’s a messy spray of food for thought.
- Changes have been made. Who made them and what are their credentials? What theories, research, and evidence informed those changes? Which professional experts and academics were consulted?
- Didn’t I hear something about this becoming a Code of Practice, à la “community of practice”? What happened to that?
- At first glance, the new Code looks most like a return to the old IRP code. Like many other Codes in many other times and places, it now begins again with a general statement of “ethical principles” or desirable qualities and actions that a professional should have and do, something which was removed from the 2010-2014 NRCPD Code. There is nothing wrong with any of them and only a sociopath would argue there was: it’s all stuff like “do no harm”, “strive to do good”, “be honest”, “act justly and fairly” etc. In fact, they are all things that we would expect any reasonable member of society to uphold: it is the kind of stuff that parents tell their infants. Which begs the question: why do they need laying out in a Code of Conduct as though we are infants? Because having a Code is nothing to do with the actual work of interpreting and everything to do with social status. This is the performance of professionalism.
- Following from this, what are interpreters expected to do if following some other part of the code – eg. section 3.3, “You should strive to ensure that complete and effective communication takes place” – leads to harm being done or dishonesties being perpetrated or unjust acts being committed? How are we expected to resolve this no-win “code clash”? Report ourselves to NRCPD? Fall over, frothing at the mouth?
- Interestingly, for the first time, the Codes are broken up into those which “must” be obeyed at all times, and those which “should” be obeyed wherever possible. Presumably, the latter will not always be possible or they would be a “must”. The notes in the “consultation” survey refer to profession-specific sections of the old Code which have been removed because of a desire that the new Code refers only to “higher level” considerations relevant to all communication professions (lipspeakers, note-takers, translators etc.) and that those occupation-specific guidances should be left to the professions to develop (which does make me wonder why we have one giant Code as a catch-all for people who do quite different jobs). Furthermore, if we’ve established that we’re removing “guidance”, and a very general standard is desirable but it “might not be possible to meet [it] in every situation”, then why is it in a Code of Conduct at all? Shouldn’t this be stuff covered in training and professional/academic literature? Compare and contrast the general tone of this Code with the British Psychological Society’s Code of Ethics and Conduct (2009), which starts by pointing out that “No code can replace the need for psychologists to use their professional and ethical judgement … Thinking is not optional”. So, as “professionals”, are we trusted to make a judgement, or not? Are we trained to be “safe to practice”, or not? Is something a universal truth, or not? Does the work of interpreters take place in a wildly and daily varying set of circumstances each of which requires a unique and well-judged approach that takes a large number of factors into consideration, or not? Since they clearly can’t ever be enforced, can I simply ignore all the “shoulds”, or not? If you can fit all of critical interpreter decision-making into four sheets of A4, why do we need interpreter training or research at all? If we’re not equipped to handle these judgement calls by the time we leave training, a stone tablet isn’t going to help. That’s what (peer) supervision, practitioner forums, CPD, literature etc. are all for.
- Following from this, I could read section 1.2 as meaning that adequate preparation for an assignment is a “should”, is not compulsory. That’s a green light to the kind of shoddy agency practice that has been driving us all bonkers.
- I’m glad to see that the old code about “impartiality” is gone and replaced by much less ambiguous language about discrimination (1.3), which is probably what the old wording was really intended to mean. See essays by Dennis Cokely and Robert Lee if you’re not sure why this never made any sense – I’ve rambled incoherently about it myself here.
- Still on the theme of reading intentions, section 3.4 is even more massively problematic than before – “You must not add or take anything away from the intended meaning of the communication”. This mathematical wording has been altered slightly from the previous Code which used the incredibly vague term “spirit of meaning”, but in this case the added specificity just makes it even worse. This part of the Code is also now a must, not a should, so misreading intentions could potentially be a disciplinary matter if this part of the draft Code is enacted. Any interpreter worth the name has been trained in pragmatics, intended co-construction of meaning, illocutionary acts, etc. As linguists, we know that almost every single utterance will vary from the literal, semantic meaning of its component parts. Guessing intentions is a messy human activity which unavoidably goes awry on a daily basis. Furthermore, interpreters deal constantly with strategies for “unpacking” terms which lack equivalency or which rely on specific world knowledge – “adding” and “taking away”, in other words. Obeying this demand is going to be absolutely impossible and I’m stunned that this didn’t hit the cutting room floor. God knows how note-takers will cope with a ban on “taking away”.
- Also new and expanded are sections 6 and 7, which appear to attempt to regulate my behaviour and ethics outside of work, and patronisingly reminds us breaking the law is bad, m’kay. Again, this is nothing to do with interpreting effectively and with integrity – this is about boosting the status of the profession. Section 6.5, on conflicts of interest, is particularly eyebrow-raising given our discussion above.
- The Code ends with the same “Glossary” as older codes, which I’m sure will be continued to be used by professionals as excuse-conferring rigid definitions for anything they want to get out of, such as translating from BSL into written English or making cups of tea. And this is another one of the essential problems: people will always claim that because something isn’t in the Code, they don’t have to do it, or shouldn’t do it. People interpret (see what I did there) fixed codes as defining fixed roles, but we all know that a stopped clock is only right twice a day.
Your mileage may vary. There’s probably a lot more to pick apart, but as our American colleagues might say, I am done with this. Good luck, and be well.
(edited 15/11/2014 for broken links and brevity)