Justice CommitteeWritten evidence from the Association of Translation Companies


The Association of Translation Companies found it difficult to engage with the Ministry of Justice.

In its attempt to support the process bureaucratic obstacles appeared to be placed in the ATC’s way.

Once our views were sought they appear to have been ignored.

We recommend that professional representative bodies are consulted before embarking on future complex procurements, as this can help inform the framework and help avoid the bear traps.

While recognising the need to make savings in public expenditure, this should not be at the expense of the quality agenda, which needs to be placed far higher up the agenda.

1. The Association of Translation Companies (ATC) is the world’s longest established professional organisation representing the interests of commercial companies offering language services.

2. A number of its members tendered for the contract to supply interpreting and translation services to all agencies of the Ministry of Justice. A number informed the Association that they had decided to withdraw from the process, as they viewed the specifications to have been flawed.

3. Two of our members, Applied Language Solutions (ALS) and thebigword were shortlisted after the remaining bidders had been eliminated from the process.

4. The ATC’s Public Sector Committee was proactive in seeking to support the MoJ’s procurement department by offering what advice it could to help officials develop a credible process that took into account the many issues which it considered needed to be considered.

5. The process of setting up a meeting with the appropriate officials proved extremely difficult and commenced once Buying Solutions issued an OJEU notice in August 2009.

6. While seeking to offer advice, our approaches did not appear to have been welcomed in the first instance. An official at Buying Solutions told us that it would be “inappropriate” to meet with a supplier organisation, despite the ATC being one of the world’s longest established professional bodies representing interests of translation companies.

7. Further delays were created when the Ministry of Justice decided, following consultations with stakeholders within the criminal justice system, that the scope of the proposed Buying Solutions framework would not be sufficient to meet the specific needs of the criminal justice system.

8. We persisted in our approaches but the process of setting up a simple face-to-face meeting with officials overseeing the procurement to offer helpful advice took nearly seven months. We found this frustrating.

9. We were similarly unimpressed by a message received from an independent outside consultant employed on a short term contract to advise the Ministry of Justice who, on completing his assignment, asked us to circulate his details to our members to support their public sector bids.

10. The ATC recognised that part of the Government’s agenda was to streamline the procedures and, at the same time, reduce expenditure on interpreting and translation services across all justice settings. However, our advice focused purely on the quality agenda.

11. The ATC also recognised that the National Register for Public Sector Interpreters, (NRPSI) and other approved lists, while providing a useful database of interpreters, does not represent the total available pool of suitably qualified interpreters that could be used across all justice settings. Indeed many ATC members, including those tendering for the MoJ contracts have had to establish their own databases of interpreters using their own quality control regimes, often in collaboration with universities. This had been made necessary, as a result of around a third of all those on NRPSI database opting to withhold their details from translation companies. This practice preceded the awarding of the contract to ALS and was something about which MoJ officials were unaware

12. As a result of the protracted process of setting up a meeting, the procurement process had by then proceeded past the PQQ stage and the short listing of bidders, many of which we were informed were our members.

13. Having finally secured a meeting and establishing reasonably regular email contact, the ATC was invited to contribute to the debate in the Competitive Dialogue phase of the procurement.

14. Having consulted widely we commented specifically on two issues. The first was that the MoJ appeared to have adopted a different tiering system to that used to award contracts for similar services in other government departments via the OGC.

15. We felt that by adopting a three tier approach, while the rest of Government was using a four tier system for sourcing interpreters, showed an inconsistent approach that could compromise the quality of the service delivered. The Association also warned that this inconsistency could lead to problems further down the line and might be a source of criticism of the MoJ’s approach that could, potentially, undermine confidence in it.

16. The second observation made by the ATC was that the Ministry of Justice did not appear to acknowledge the importance of the Institute of Translation and Interpreting (ITI) and the important role it plays in the continued professional development of interpreters. We felt that this was a significant omission that needed to be addressed.

17. We were later consulted by the MoJ about the significance of the various professional qualifications being cited by short listed bidders.

18. This set alarm bells ringing, as we would have expected that rigorous research ahead of the short listing would have suggested that all the qualifications were important guides as to the competence of interpreters to be used.

19. For the record the qualifications about which our views were sought were:

Diploma in Public Service Interpreting.

Metropolitan Police Test.

Community Interpreting Level 3 Diploma.

Community Interpreting Level 1–2.

A degree partly studied in English with at least one interpreting and one translation component.

Formalised basic interpreter training including one of the following the Worker’ Education Association (WEA) programmes, bi-lingual skills certificates, community level interpreting degrees under the NVQ certification system.

Partial Diploma in Public Sector Interpreting (DPSI) (not module 3b).

Degree in linguistics, English philology, modern languages.

Cambridge proficiency in English Certificate.

First or post graduate degree in interpreting.

First or post graduate degree in the relevant language.

20. Having taken so long to be admitted to the table to offer support to the Ministry of Justice, the Association of Translation Companies was disappointed that our advice on the tiering system and the significance of the Institute of Translation and Interpreting role in delivering interpreter CPD appeared to have been ignored.

21. If we are to draw lessons from this particular process the ATC believes they would be:

(a)Consult the professional representative bodies before embarking on such a procurement process in the future—it can help provide a comprehensive map of a complex marketplace which can help avoid unnecessary bear traps.

(b)Seek to remove many of the bureaucratic obstacles placed in the way of professional groups such as the Association of Translation Companies to enable an early productive dialogue to take place.

(c)Place a far greater emphasis on the quality criteria.

(d)Recognise that the period for an interpreter to train and gain expertise can be as long as a doctor, solicitor or accountant and deserves the same professional recognition.

(e)Recognise that streamlining systems to deliver cost savings to the public purse, should never be achieved at the expense of delivering the highest quality interpreting services.

August 2012

Prepared 5th February 2013