Translation and interpretation policy

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    Policy Owner: Public Affairs
    Approval: Board of Directors
    First Approved: May 2005
    Effective Date: N/A

    Introduction

    TCHC recognizes that the City of Toronto is made up of many peoples and cultures. TCHC is committed to providing an inclusive housing environment in which all individuals are equally valued and fairly treated.

    TCHC recognizes that many tenants communicate in a language other than English. In August 2003 TCHC identified that in addition to English, there were 71 written languages used to communicate in our communities. The Social Housing Reform Act requires TCHC to provide translation and interpretation services for the French language where requested. In addition TCHC has provided translation/interpretation at the building, community and cross organizational level for at least 18 languages in addition to English.

    This policy has been developed through an examination of the past practices of the organization, the experience gained through the implementation of the draft TCHC Translation and Interpretation Policy as well as interviews with staff who have knowledge and experience in providing communication that required translation and/or interpretation services.​

    Purpose

    The purpose of this policy is to enable tenant participation; maximize tenant understanding of matters affecting tenancy and their daily lives as tenants; provide clear direction to Toronto Community Housing staff regarding translation and interpretation; provide direction to Community Councils in addressing translation and interpretation needs related to Community Council sponsored activities; and ultimately to facilitate implementation of the Community Management Plan.

    The policy helps to meet the goal of providing an inclusive housing and working environment, which is a commitment made in Toronto Community Housing’s policy on Human Rights, Harassment and Fair Access.

    This policy focuses on both translation of materials and interpretation services to tenants.​

    Application of Policy

    This policy applies to:

    • Rent Geared to Income and Market Rent Tenants;
    • Direct and Contract Managed Communities;
    • TCHC Contracts for service in which tenant engagement is required.

    Definitions

    For the purposes of this policy, the following definitions have been taken from applicable legislation:

    • Translation is changing one written language into another written language.
    • Interpretation is changing the spoken word into another spoken language and is an interactive process.​

    Principles

    Tenants require access to information that affects:

    • the status of their tenancy in Toronto Community Housing,
    • their daily lives as tenants,
    • their ability to participate in decision-making processes that ultimately can affect their tenancy.

    Policy statement

    TCHC will use translation and interpretation services to promote tenant understanding and engagement to enable full participation for tenants in TCHC issues and activities.

    Language Preference

    • TCHC will develop a methodology to collect and analyze the language of preference for TCHC tenants;
    • Translation will be provided based on the identified needs of the target audience of the communication, which may include:
      • The top languages of a building
      • The Top 3 languages of the Community Housing Unit
      • Identified languages of a specific group, e.g. tenant representatives
    • The top 3 languages across all communities if the communication is directed to all tenants;
    • CHU Managers will review the language preferences in the communities on a regular basis, at a minimum during the annual business planning process;
    • When written communication is received in a language other than English, TCHC will have this communication translated. Return communication, if required, may make use of translation and/or interpretation services;
    • TCHC will ensure that a translation and/or interpretation strategy is incorporated into each communication plan and community engagement activity undertaken;​
    • TCHC will provide advance notice of meetings to ensure tenants requiring or requesting translation and/or interpretation services are able to do so in advance;
    • Community Housing Unit Mangers will ensure that strategies for translation and interpretation are developed within the CHU Council to meet the identified language preferences of Tenant Representatives;
    • TCHC will provide interpreters at tenant meetings and other events where tenants and/or staff have identified the need for interpreters;
    • Toronto Community Housing recognizes its obligation to provide housing services in the French language.

    Translation of written communication

    TCHC will normally translate the following types of written communication:

    • Invitations to participate in consultation sessions, tenant election activities, and building meetings;
    • Newsletters, information notices and other communication where the primary audience is tenants;
    • Tenant Polices and Procedures;
    • Tenant handbooks or similar information materials;
    • Building signage (e.g.,: laundry room instructions, fire exit procedures).

    Toronto Community Housing will translate materials that affect tenants as described above. This includes, but is not limited to, materials such as:

    • Contracts, Leases, Legal Notices, etc.
    • Business plans and strategic documents.
    • Communication directed at Employees

    TCHC and Tenant Responsibilities

    Tenants will provide as much notice as possible, in advance of a meeting, to advise TCHC that they are requesting translation and/or interpretation services OR that they no longer require the requested translation and/or interpretation services.
    TCHC will make use of international symbols and drawings to improve the communication with all language groups
    Documents on corporation-wide issues will be translated into the French language whenever intended for the public where it includes French-speaking tenants.​
    Toronto Community Housing staff will provide interpreter services for meetings or telephone conversations with individual tenants where tenancy issues are being discussed. Staff will also arrange for interpreter services where tenants are using the corporation’s complaints procedure.

    Standards

    • TCHC will develop and communicate to stakeholders a set of standards to be applied to translation and interpretation services;
    • TCHC will develop a pool of approved translators and interpreters and make it available to all staff;
    • TCHC will develop a set of standardized invoices and evaluation processes to ensure consistently in the delivery or translation and/or interpretation services.

    Policy Review

    This policy will be reviewed 18 months after implementation. The policy review will include feedback from tenants and staff.​

    Applicable Legislation and Reference Documents

    The following legislation and reference documents apply:

    • Tenant Protection Act, 1997;
    • Social Housing Reform Act, 2000;
    • TCHC Community Management Plan (CMP);
    • TCHC Human Rights, Harassment and Fair Access Policy.