NRCPD have this week announced that they have become a “separate and independent” company and registered charity which is also a “subsidiary of Signature”. We are told that this paradox is a step along a “transition” towards “full independence”; nonetheless, the adjective “independent” appears five times. The entity was born on 1 January 2017; NRCPD’s director attended a local workshop on 2 February and updated them on this new status, a full week before registrants themselves or the outside world were informed, nearly six weeks after the fact. The Strategic Plan was also revealed, in all its vague and unsubstantiated glory. Elsewhere, in an advert for an Honorary Treasurer, we can confirm that the new NRCPD is a “wholly owned subsidiary” of Signature (the trading name for CACDP, the actual legal entity: as we’re discussing legal entities, I’ll only use CACDP hereon). So what does “separate and independent” mean, exactly?
Post-truth. Alternative facts. Brexit is Brexit, and statutory regulation is statutory regulation.
You have to wonder whether those interpreters and agency owners enthusing about the Uber/Airbnb/Etsy model of commerce – “disrupting the market” with a “digital revolution” – have actually ever experienced life as an Uber driver themselves.
“Character-forming” is a euphemism
It was at about this time last year – early summer 2015 – that the full extent of my failure was finally confirmed. For five months, a suspicion had been growing that the Signature unit I had been persuaded to run, BSI423 “Introduction to Interpreting”, was not only prescriptive and very narrow in scope when it should have been a light and sweeping tour, but was quite literally unassessable as well. Like a painting by numbers kit with all the numbers missing and an unexpected last minute bill for fifty gallons of battleship grey.
Five months went by during which I played voice-mail table tennis, wrote many increasingly strident e-mails and did a lot of rocking back and forth in the corner of the shower crooning “Gov’mint come’n took mah baby” in order to establish that absolutely no-one involved in delivering this brand new course – myself, the centre, the awarding body – had much more than the faintest inkling of how it was actually supposed to be completed. Collectively, we all failed a small group of colleagues who were honestly trying to develop as new interpreters. (Fortunately all of them have great potential and I expect amazing things from them, regardless.)
The final deal-breaker was a suggestion, made to me by a member of staff at the awarding body, that if an assessment wasn’t working out then I might have to “make it up” a bit by asking leading questions. That’s really when I started walking away. I’m still walking.
Why is this kind of thing happening in the first place? First, we should explore what “standards” actually are. At this point you might want to supply your own Bagpuss-like wibbly-wobbly dissolve with a surreal harp scale, indicating that we are phasing into the recall of events from earlier in time or some kind of reverie.
I was quite lucky. I was introduced to the “Deaf world” and British Sign Language (BSL) by a talented teacher with a lived deaf experience and a knack for bringing a bone dry syllabus to life. The cost to me for that first life-changing intervention was five of your Earth pounds. But the giddy days of 2004, when Further Education subsidies were scattered like petals, are now just nostalgia. We could ask:
- With the public sector repeatedly “salami-sliced” since 2010, are people now signing up for beginner BSL classes as much as they did in the past? (Spoiler: no – new learners have been halved since then.)
- What is the BSL training market worth to Signature? (Spoiler: recently, a fairly consistent £1.35 million per year or so, despite the continuous loss of learners.)
- How much does it cost Signature to “regulate” BSL/English interpreters? (Spoiler: pick a number, any number.)
I sent my mechanical goblins hunting. They brought back electric bacon.
I was unable to attend Signature’s statutory regulation meeting in January due to being unexpectedly hospitalised (I’m fine now). While waiting for my belly-button to resume normal service, I did a little bit of reading and uncovered a range of interesting and depressing responses to the statutory regulation struggle in the annals of several other professions. Many of these are the kind of practitioner-focused issues that have so far (to my knowledge) been absent from dialogue. This is a long post so let’s start with the main shakedown and then move on to the sources.
Key issues raised
- Statutory regulation encourages “medical model” approaches to practice which even healthcare professionals may find oppressive, let alone those in occupations which are patently not healthcare.
- Excessive regulation – increased inspection regimes, measurements and managerialism – can lead to increased “reactivity”, a term which describes practitioners feeling a pressure to select “easy wins”, reject more difficult work, abandon more difficult clients and “cover their backs” instead of acting from best professional judgement.
- Campaigns to promote statutory regulation above self-regulation have historically resulted in schisms and increased disunity within various professions. Almost all the campaigns resulted in failure and wasted resources, even for professions between thirty and two hundred times the size of BSL/English interpreting.
- A political will is required to take up the cause of state regulation, which brings with it political scrutiny, which entails unpredictable effects such as sudden reversals of support or unexpected spotlights on bad training/practice. Statutory regulation can stop being statutory at any time should political will or public support be withdrawn: the fight to keep your status may be even more effort than that expended to attain it. The current political will is opposed to statutory regulation even for highly specialist and expert clinical professions taught over and above postgraduate level, let alone social/linguist ones with a mixed bag of vocational qualifications that verify skills instead of teaching them.
- Meta-regulators such as the Professional Standards Authority (PSA) and its predecessor the Council for Healthcare Regulatory Excellence (CHRE) have long asserted that regulation must be based on empirical assessment of “actual harm” and not “possible risk”, i.e. regulation must be proportionate to the problem it is trying to solve. A regulator that creates sledgehammer/nut issues is incompetent.
- Given that absolutely none of above is even acknowledged, let alone addressed, by Signature’s meandering rationale for pursuing statutory regulation, it becomes necessary to ask whether the current governance of their “NRCPD service” is fit for purpose and their personnel are qualified to decide our profession’s future. Who watches the watchers?
- Finally, the concept of principled non-compliance may offer some solutions, or at least traction, to those with doubts and fears about the path ahead, while those who favour statutory regulation have a paradox to resolve.
It has been about a year since my decision to voluntarily leave the NRCPD register and I’ve done no freelance work during that time. All of the BSL/English interpreting work I’ve done since then has been through a public sector employer (this actually provides “consumers” with a higher level of scrutiny, support and accountability than any voluntary regulator can muster). Now that I’ve completed another degree and have more time to work again, it recently crossed my mind that I could re-register. And then today, NRCPD did three things:
- Announced a formal statement of regulatory intent, in which they set out their long-term but short-on-details plan to criminalise unregistered community interpreters
- Published a new Code of Conduct and complaints process
- Revamped their website slightly (I’d feel bad if I didn’t point out that they’ve stealthily removed all previously published correspondence between registrants and the Board) (Further note, 20/11/2015: the missing correspondence has now reappeared elsewhere on the site, prompting us all to remember the importance of Hanlon’s Razor.)
What do I make of all this? More below the break.
A couple of months back, I had a rummage in the 2011 Census statistics, CRIDE 2014 surveys and regional NRCPD registration breakdowns. There was also a more speculative look at the state of communication support in Deaf Education. This proved to be a very popular post with a lot of sharing: hearty thanks to all.
I’m now very grateful to staff at NDCS, who have shared more detailed breakdowns of the CRIDE 2014 national survey with me, allowing for better reckoning of the education scene. I was also able to try and speculatively triangulate the Census reckoning of sign language users in the UK against CRIDE’s estimate of children and young people who sign. See the previous density of interpreters post for the full discussion on what the problems with the Census data are and why some people are very firm about how wrong it must be.
As a baby interpreting tutor and toddling workshop designer, I’ve spent a bit of time recently comparing interpreting curricula. We’re at a relatively privileged moment in history because there is, at last, some competition to Signature‘s monopoly on the vocational BSL education market, in the form of new arrivals iBSL.
I’m quite capable of writing seriously and in a proper academic style. But this is a blog. If I can’t have fun and speak my mind, why bother? Despite that, I think there may be some serious points and interesting finds here. I don’t think anyone has done this before: if I’m wrong, please let me know.
This mini-project used three data sets, all available to the public. One (a portion of the 2011 National Census) has questionable data. The next (CRIDE’s 2014 survey) comes with a warning attached that it should only be used for analysis and debate rather than drawing any hard conclusions. The last (NRCPD’s May 2015 registration breakdown) only represents those interpreters who choose to register with NRCPD. Therefore the following should also be taken as an exploration – stuff that is or is not likely – rather than solid fact. I’m the first to point out other people’s terrible use of stats and I hope I’ve been equally critical and honest about my own dalliances.
If you’re already bored you can skip ahead to the pretty maps.
NRCPD recently began releasing a breakdown of qualified registered interpreters by region for the first time. When I saw this, I realised there is the potential to have a pop at some very old questions: how many BSL users per interpreter are there? and where is the most work for interpreters? and where do Deaf people compete most for interpreter availability? The answers would obviously be of interest to those invested in Deaf Industry strategy and marketing, but there are political concerns as well. For example, I regret that it has been suggested to me more than once that there are “too many interpreters” (only by interpreters, obviously).
But counting registered interpreters is the trivial part. The question of how many Deaf people there are and where they are has always been problematic, because we don’t all necessarily agree on what they are. Humans always come unstuck on methods and definitions, because words don’t mean anything in themselves. For areas, grey is the new black. Determinations of identity are always going to be muddy, because people are fabulously muddy.
But if you don’t ever try, you don’t progress. Despite these issues, there is always some kind of data. Data trumps ideology every time. You just have to pull your finger out. [Read more…]