Introduction, Scope and Confidentiality
The Regulatory Centre for Irish Sign Language Interpreters Ireland CLG has been established for the purpose of maintaining the register of Irish Sign Language Interpreters and quality assurance scheme (“the Register”), currently being developed by the Sign Language Interpreting Service. This company will operate under the business name of RISLI.
As part of the registration and quality assurance scheme, registered interpreters agree to abide by a Code of Conduct, among other criteria for maintenance of registration.
This paper sets out the processes for handling complaints against respondents.
The Complaints sub-committee (‘sub-committee’) is responsible for investigating complaints about registered interpreters. If the sub-committee is satisfied that a complaint is proven in part or in full, the sub-committee decides on the appropriate action to be taken.
The Complaints Processes only deals with the interpreter’s registration status. Issues relating to employment are a matter for employers.
Confidentiality & Conflict of Interest
The consideration of complaints is private and confidential and will be treated as such by the sub-committee and Secretariat.
Written English versions of all relevant correspondence, reports, or other documentation produced in the course of any complaints process investigation or other dealings with a complaint will be sent in the first instance to the complainant for their records. A Deaf ISL-using complainant can request the sub-committee to translate and send any such documentation in a securely stored and transmitted ISL version.
It shall be compulsory for all sub-committee members to declare any conflicts of interest in relation to any complaint or maintenance of registration issue coming before the sub-committee. The chairperson of the sub-committee will consider any such conflict, and make a decision as to the member’s involvement in the process.
No member of the sub-committee can have been involved in any prior investigation into the complaint, whether through RISLI, an external agency or organisation, or any interpreting body.
Scope of Process
Any person (“the complainant”) can make a complaint about a registered interpreter (“respondent”), to include if they feel the interpreter has breached, or failed to follow, the Code of Conduct. Complainants can include service users, other registered interpreters, organisations or the Registration Panel itself.
A complaint cannot be progressed against an interpreter who is not on the Register at the time the complaint is made. In general, complaints about events which pre-date the opening of the Register will not be considered, save in limited circumstances.
Complaints should include the identity of the complainant and details of the complaint.
Complaints should be raised as soon as possible after the incident has occurred. It is recommended that complaints are made within three months of the incident(s) occurring, however all complaints will be considered.
Making a Complaint
A complainant should make a complaint. To submit a complaint, the complainant can use one of the following options:
- Complaint Form: Fill out the Form (see Appendix 1). The completed Form can be emailed to firstname.lastname@example.org or by post/in person to: Complaints sub-committee, Register of Sign Language Interpreters, c/o Sign Language Interpreting Service (SLIS), Deaf Village Ireland, Ratoath Road, Cabra, Dublin 7.
- Irish Sign Language (ISL): You can submit a complaint in Irish Sign Language (ISL) by sending a video message to the Register. ISL complaints should follow the structure of the Complaint Form. ISL Submissions can be emailed to email@example.com with the subject line “For attention of Complaints sub-committee”, or sent to the Secretariat’s mobile number, 086 138 0180.
- ISL Meeting to Complete Form: Alternatively, RISLI can organise a meeting with the complainant via videoconferencing, or in person, with an ISL interpreter or ISL-fluent staff member, to fill out the Complaint Form. To arrange such a meeting, the complainant contact RISLI (Text: 086 138 0180, Email firstname.lastname@example.org or video call) or attend the office at the address above.
The following information in the Complaint Form (or equivalent video in ISL) should be included:
- Complainant’s name and contact details.
- The name of the registered interpreter the complaint is about.
- What happened – a description of the incident, action, or behaviour that occurred
- When and where it happened
It is also recommended that the following information is provided:
- Details of anybody else present who witnessed the incident or behaviour
- The interpreting agency or employer (if known) which arranged for the interpreter to be there
- The complainant’s desired outcome from the complaints process
Initial Complaint Check by Secretariat
Upon receiving the Complaints Form, the secretariat will check the following criteria:
- The Complaints Form is completed and includes the required information. If necessary information is missing from the form, the secretariat will go back to the complainant requesting the required information.
- The interpreter is currently registered.
If the complaint satisfies the criteria, the secretariat will refer the complaint to the Registration Panel for a sub-committee to be formed for investigation. The complainant and the respondent the subject of the complaint will be informed:
- that a complaint has been received
- that the complaint is being proceeded with as per the Complaints Process
- that the complaints has been referred to a Complaints sub-committee
In addition, the respondent will be sent the original Complaints Form and any supporting documentation.
If the complaint does not satisfy all of the criteria in the section above, the Registration Panel, the complainant and the respondent will be informed:
- that a complaint has been received
- the identity of the complainant and respondent
- that the complaint cannot be accepted, mentioning the criteria above that was not fulfilled
Complaints sub-committee Investigation
The sub-committee will give initial consideration to a complaint. The sub-committee may decide to refuse to investigate a complaint if:
- assuming the events complained of are true, they would not amount to a breach of the Code of Conduct
- the complaint is made in bad faith
If the sub-committee decides not to investigate the complaint, the sub-committee will proceed to the final Complaints Report.
If the sub-committee decides to investigate the complaint, the complainant and the respondent will be notified.
The respondent will be given an opportunity to provide a response by way of a Response Submission. A copy of the Respondent Submission is also sent to the complainant.
The complainant is then given an opportunity to respond to the Respondent Submission, in a Complainant Response Submission. This must be sent by the complainant within 30 days of receiving the initial Respondent Submission. A copy of the Complainant Response is also sent to the respondent who will have an opportunity to respond. Further exchanges of correspondence may take place depending on the views of the sub-committee.
The sub-committee may request further information from the complainant, respondent, or any other organisation(s) or individual(s) to assist in the investigation.
The sub-committee can request the complainant, the respondent, or any other individual involved in the complaint whose evidence is required, to attend before the sub-committee at an Evidence Hearing.
Evidence Hearings will be held in private. Evidence Hearings may be video and audio recorded, and an Evidence Hearing Transcription may be produced.
Where the sub-committee, in the course of investigating a complaint, deem it necessary, the sub-committee may appoint external consultants to assist it in considering the complaint. Such external consultants may be asked to prepare a report for the sub-committee. The sub-committee may provide a copy of the report to the respondent and complainant.
Mediation is a non-formal route towards resolving an issue between the respondent and the complainant, through the use of a trained mediator. It is a voluntary process which both the complainant and respondent must agree to follow. Mediation may be recommended by the sub-committee as suitable for certain complaints.
If, in the view of the sub-committee, the circumstances are deemed to be suitable, the sub-committee may pause investigation of the complaint and suggest mediation to the complainant and respondent and invite them to participate. If either the complainant or the respondent does not agree to mediation, or either party make no reply within 30 days, the sub-committee will continue the investigation.
If both the complainant and the respondent agrees to mediation, the sub-committee will appoint a trained mediator. RISLI will fund the cost of the trained mediator and any interpretation needed for the meetings.
Prior to meeting, the complainant, respondent and mediator sign an Agreement to Mediate, which verifies:
- understanding of the mediation process by all parties
- agreement of all parties to co-operate with the mediator
- agreement of all parties to take part in the mediation process with the aim of reaching an agreement
- the understanding of all parties that either the complainant or respondent can withdraw from the mediation process at any time
- the understanding of all parties that the mediator can close the mediation process at any time, if they believe the issues will not be resolved through mediation
- the understanding of all parties that everything said or done in the meeting is confidential, unless otherwise agreed by all attendees
- the understanding of all parties that no admission made or documents used during the mediation process will be forwarded to either the sub-committee or the Registration Panel, and that such documents will be destroyed by the mediator after the mediation meeting, with the exception of :
- any contract between the Register and the mediator
- the signed Agreement to Mediate, to be retained by all parties to mediation only
- any final Mediation Agreement, to be retained by all parties to mediation only
- a Mediation Success or Mediation Failure notification, sent by the mediator to the Complaints sub-committee
The mediator may request to meet the complainant and / or the respondent separately before any mediation meeting.
mediation meeting is organised with the mediator, the complainant, the respondent, and if required, a registered ISL / English interpreter (the identity of whom to be agreed on by both complainant and respondent) to interpret the meeting. At the beginning of the mediation meeting, the mediator will outline the process to be followed in mediation. The complainant and respondent each then give an opening statement.
With the support of the mediator, the issues in the complaint are then discussed in detail. Where possible, the complainant and respondent will then agree on next steps. This may include for example, the respondent offering an apology, commitment to amend future practice, or other actions agreed at the meeting. Follow-up meetings may need to be arranged to continue the mediation process.
Finally, if an overall agreement is reached, mediation has been successful. The mediator will take a record of what was agreed, and both the complainant and respondent sign the Mediation Agreement. This agreement is to be kept confidential, unless the complainant and respondent jointly agree to make it public. The Mediation Agreement is not submitted to the sub-committee or Registration Panel.
The mediator will report to the sub-committee the result of the mediation, successful or not. If mediation is successful, the mediator will simply report that:
- the mediation was successful
- that a Mediation Agreement is now in place
- that the complaint should now be considered closed
No further information about the mediation process will be given. The complaint will then be regarded as closed by the sub-committee, who will proceed to completion of the final Complaints Report.
If mediation is unsuccessful, the mediator will simply report to the sub-committee that:
- non-agreement of one or both parties to participate in a mediation process
- withdrawal of one or both parties from the mediation process
- no agreement being reached in mediation meeting
- closing of the mediation process by the mediator, as they believe the case will not be resolved through mediation
No further information about the mediation process will be given. The complaint will revert to the sub-committee for investigation.
Reporting, Decisions, and Recommendations
The length of the complaints process will depend on the nature of the complaint. The complainant and respondent will be kept updated.
Once the investigation is complete, the sub-committee will prepare a Complaints Report. This report will refer to all documentation considered by the sub-committee and any evidence heard. In addition, the report will include the decision reached on whether the facts are proven, any decision on any action to be taken, and any other information deemed necessary.
Actions decided upon by the sub-committee can include:
- Formal written warning to the respondent
- Conditions to be attached to the respondent’s registration as a result of the complaint being upheld in whole or in part. See Registration Process for more information. The Conditions that can be attached can include:
- Condition – CPD: The respondent is required to complete a tailored CPD programme, over and above the standard CPD requirements of registration. Completion of the CPD programme should ideally be within 12 months from the date of the Complaints Report will be attached as a Condition to the respondent’s registration.
The respondent is responsible for sourcing suitable CPD.
If, after previously incurring two such CPD Conditions, a further complaint is received about a respondent, which again indicates significant training or skills development needs, the sub-committee can recommend the respondent undergo a Baseline Skills Check.
- Condition – Mentoring: The respondent is required to sign and fulfil a Mentoring Agreement with a trained Mentor (See CPD and Mentoring Policy) for a specified period.
- Condition – Skills Check: The respondent is required to undergo and pass, ideally within twelve months of the date of the Complaints Report, a Baseline Skills Check (SC-B) to establish whether they currently possess and can demonstrate sufficient basic competencies to practice.
Such other conditions as the sub-committee considers appropriate
- Suspension: Suspending the respondent from the Register and/or a Specialist Panel for a specified period.
- Removal: Removing the respondent from the Register.
The sub-committee will provide a copy of the Complaints Report to the complainant and the respondent.
The Registration Panel will be notified of the outcome of the complaint.
A respondent or complainant can appeal the decision of the sub-committee. See the Appeals Processes.