Post-truth. Alternative facts. Brexit is Brexit, and statutory regulation is statutory regulation.
A couple of weeks ago I sent Signature-NRPCD a grumpy but civil complaint about their continued poor communications and inactivity since the regime change last summer. Back then, I was relatively chipper: we had a change of CEO at Signature, a new director for the NRCPD service with experience from the Chartered Institute of Linguists, a sudden (if mysterious) abdication of the three most “medical” board members, and a clear promise to set up a new independent register, all things many of us wanted. I may have had a Babycham.
I didn’t even get an acknowledgement of my e-mail, because clearly that’s how you build relationships with “stakeholders”. But – and this can only be a coincidence – in the last week, a new document quietly appeared on the menu: the Strategic Plan 2017-2020.
Now, as a working interpreter, I juggle semantics every day. I eat six impossible translations for breakfast. I bend equivalences to my will like Thor. But even I can’t twist this into anything resembling a “plan”. At the very best, it is yet another wishlist, a letter to Santa Claus sans milk and cookies: I want a pony and to be Queen Elsa and have improved communication with stakeholders. It’s the kind of frenzied multi-coloured vision-quest flip-chart thought-shower scribble that dishevelled middle managers emerge with from out of their sweat lodge after being locked in for six hours with only steam and burning leaves for sustenance. It’s like that kind of to-do list you make as an ironic form of procrastination where the first sixteen entries are things like “make this list” and “make another list” and the last one is “finish PhD”.
The Plan contains:
- References to data: zero
- References to internal research: zero
- References to external research: zero
- References to consultation: zero
- Discussion of the barriers to regulation encountered by other professions or their wider professional discourse on the matter: zero
- Acknowledgements of any possible drawbacks to intensified, state-dictated regulation: zero
- Descriptions of the actual form the independent register will take: zero
- Specific milestones: zero
- Vague timescales: one, the “long term”
- Ways of measuring success: zero
- Ways of recognising and learning from failure: zero
- Concrete suggestions about how mere practitioners and the Deaf community can get involved: zero
And they have the nerve to tell us about “standards”. Let me tell you about some other standards. In principle if not rigour, they apply both to leading academics and adolescents embarking on their first formal qualifications. When you make a statement about cause and effect – for example, “We are pursuing statutory regulation because it will ensure that every practising communication and language professional meets minimum standards of training and practice, thereby increasing public protection” (my italics) – you give a source. You back it up with evidence, quantitative or qualitative, because otherwise it’s just a bald assertion, an “alternative fact” to which any passing stranger could simply say “No it won’t” and be equally justified. If action X leads inevitably to outcome Y as is being claimed, and this has apparently already happened elsewhere, then there will of course be evidence that it works. We call this an “evidence base“. I’ve looked for it – either I’m bad at searching literature or it’s not there. If the latter, you inevitably start to wonder why it’s not there. Homework: what are the units of “public protection”?
You also do your darned best to drag yourself as far up Bloom’s taxonomy as you possibly can. You are expected to progress from “what” to “how” to “why” to “but”. Some schoolchildren master this concept: for professionals, you could even call it an ethical imperative. Far be it from me to lecture on ethics, but by which ethical standards should we be judging Signature? Turn-about is fair play, yes?
Of course, there’s a point of view which holds that S.M.A.R.T. targets – a bog-standard staple of project managers and teachers alike – are not always appropriate. It is, apparently, not always fair or productive to hold people down to specifics, to deny all the utility of abstraction, to limit “big picture” thinking. I suppose this is what we are expected to take “Strategic” to mean. It doesn’t seem quite fair though, does it, that people who have positioned themselves at the helm get to have all the dreamy wafting while all the serfs in the field labour under grids of tick-boxes and criteria and quotas. Can I have “dreaming” as a CPD target? Is that “structured” or “unstructured”? The Plan ends with the assurance that the fine operational details – or the “work”, if you prefer – will be hammered out in yearly Operational Plans, with dates and a column for initials and everything, and that those will be reported to the Board. Which means, on past form, that we will get to see them 6-18 months after the fact.
There’s lots more to talk about in the Plan – top of my list would be “explore the potential need for new registers, and routes to registration, responding to the needs of the market in the public interest”, which is probably talking about CSWs, so stock up on popcorn now – but the will to live has left the building. We’ll see what comes drifting down the stream – maybe I’m just an old drama queen and it’ll all be lovely.
But I’ll be honest – I’m actively looking for another occupation, and my reasons are nothing to do with pay rates or agencies or Frameworks but with the state of the field and its main players, the interpreting oligarchy. If you want a vision of the future, take a look at what’s happening across the street for counsellors and psychotherapists – the top-down threat of co-opting clinical supervisors as literal informants, the introduction of “mystery shopping”, the endless quick-fire rounds of governance by Survey Monkey – and ask yourselves if you would still want to work in that kind of world. Me, I’d rather pull pints, wipe tables and work on a novel until the neo-Nazis take me round the back and shoot me.
One last thought for you. In last year’s essay on the downsides of state regulation and the many, many problems practitioners and governments find within it, I hinted (perhaps too vaguely) about Principled Non-Compliance. This can be boiled down to simply observing the very first principle of your professional ethics: minimise harm. Just as a thought exercise – I’ll give you a CPD “point” if you write it down – ask yourself what Signature would have to do, what line they would have to cross, how many small but accumulating compromises you would make, before you finally abandoned them because that would be the most ethical, least-harm action you could take?