Signature must release their NRCPD cash cow: part 1

  Although interpreters pay to be regulated, any register does not belong to them, nor do they get a say in how the regulator they use is run. However, they do have a right to see where their money goes and that it indeed goes towards the actual public protection of people who use that regulator. I do not just mean Deaf people but the many people who place their trust in a register to provide them with information on who is qualified or in training, has insurance, is police checked and safe to book for their service/organisation to provide access to Deaf people as per statutory duties.
The holder of the NRCPD registers is Signature which is the trading name of CACDP. Another subsidiary of which is Signature Commercial Limited. A company which declared losses of £96k in the year ending 2013 and £160k for 2014. The accounts show website costs, two employees but barely any more information than that as they have “taken advantage of financial reporting standard 8 whereby subsidiary undertakings do not have to disclose inter-group transactions if 90% or more of their shares are controlled by the group”. Who knows what costs are being squirrelled away in the commercial arm.
This is one example of a lack of transparency. The next accounting practice will be more shocking to those that pay money to the register. Especially for those like myself who have called for independence of NRCPD from Signature and received the answer that it costs too much money to run the register and it could not survive without funding from Signature to keep it afloat.
In the accounting year ending July 2011, the register made a profit of £36k as follows:
Income  130,434    Expenditure  94,478     PROFIT  35,956
In July 2012:
Income  161,394    Expenditure  279,339   LOSS   -117945
In July 2013:
Income  180,810 Expenditure    285,450   LOSS   -104640
In July 2014:
Income  212,409   Expenditure  335,162   LOSS  -122,753
Why the spiralling costs of running a register? There are no separate accounts for NRCPD as CACDP/Signature does not have to provide them. The annual reports for NRCPD reveal nothing but a promise to improve transparency in their finances. A promise yet to be fulfilled.
The only clue is in the way that expenditure is apportioned to each activity in the CACDP/Signature accounts and what this percentage of overheads amounts to as a total of all expenditure. In July 2011 registration was deigned to have cost 6% of all of CACDP/Signature’s expenditure. A fairly reasonable cost which resulted in an overall profit of £36k that was made by CACDP/Signature.
Why the loss of £118k in 2012 despite an income of £161k? A whopping 18% of CACDP/Signature’s expenditure was attributed to the activity “registration” which amounted to £279k. This stayed at 18% for 2013 and has now increased to 21% for 2014.
So CACDP/Signature, with many different activites, apportions 21% of ALL of its costs to registration i.e. NRCPD supposedly costs CACDP/Signature £335k. Put in perspective a much smaller 16% is apportioned to development of examinations, training and materials.
Does it really cost £335,000 to run a register? Only if you apportion 21% of your overheads against registration. 21% of every single staff member at Signature is paid for by the register, despite the fact that not all staff members work for NRCPD.
It is time that the finances of CACDP/Signature were more transparent for registrants and Deaf people alike. It is time for the NRCPD registers to be truly independent at a time when we need them to be, more so now than ever in this political climate. Interpreters, other registrants and Deaf people need to call for independence so we finally make this happen. NRCPD’s so-called independent governance no longer cuts it, it is tied by these accounting procedures. An income of £212k is more than enough for a successful register to survive and furthermore, with not just the financial ties cut from CACDP/Signature, with employees working solely in its interests the register is much more likely to grow and succeed.

NRCPD Statutory Regulation Survey

The NRCPD have sent out a survey to communication professionals to assess their thoughts on statutory regulation. The deadline is Friday 11th July.
My answers are below. If anyone has any comments please post in response:
1. Do you support the NRCPD aim of statutory regulation? Yes
I support the aim of statutory regulation. I am not convinced the NRCPD are the right body to hold this as it is still not independent from Signature/CACDP and I haven’t been happy with the way UKCoD have dealt with the AtW enquiry and how interpreters have not been involved as much as they should have been.
2. Do you think requiring registrants to agree to a code of conduct is a good thing? No
The Code of Conduct is too prescriptive and does not allow for the breadth of ethical decision making that a BSL interpreter has to practice every day. The Code of Ethics was much better and reflective of other professions. A teological approach to ethics rather than deontological would be much more suited in the case of interpreters. This is a much more up to date way of thinking in the interpreting profession (see Dean and Pollard’s Demand Control schema).
3. Do you think requiring registrants to continue their professional development is a good thing? Yes
I agree with CPD but do not agree with the way that NRCPD have mandated that some hours should be structured but also limited to only courses about interpreting. This has created a market for CPD courses but not increased the value of CPD to practitioners of more than five years post qualification. For example I would like to attend courses on voice production, mime and another language. I believe these would all enhance my work as a practitioner but none of these courses would fit the NRCPD’s criteria. I have completed most of the courses that are on offer in the market and am struggling to find anything that would enhance my professional development.
The rather arbitrary numbers allocated to structured and unstructured do not make sense and were not created in consultation with interpreters.
The more experience one has the more unstructured CPD is completed rather than structured: peer supervision groups, clinical supervision, evaluating ones work, attending or facilitating interpreter meetings, volunteering for interpreter organisations, reading research and articles.
I also do a number of hours of voluntary interpreting which I often record and evaluate.
I would recommend that NRCPD readjust the hours of structured and unstructured or rather put the total amount of hours an interpreter should complete without being prescriptive.
I would recommend that NRCPD allows courses indirectly related to interpreting to be counted as CPD.
I would recommend that NRCPD consult interpreters when reviewing CPD.
4. Are you willing to meet with members of the NRCPD Board to discuss statutory regulation, continuing professional development and the code of conduct’ if the opportunity arises? Yes
Further comments:
The NRCPD should consider asking TSLIs to take an ASLI trained mentor and provide funding to ASLI to provide this. Currently any RSLI can support a TSLI and they would not necessarily have the skills to offer that support.
Before any statutory regulation takes place Signature should be completed independent from NRCPD.
The alternative would be that another body holds the power to regulate.
When representations about interpreters are made to government the NRCPD should be representing the interests of interpreters as well as Deaf people rather than the view of Signature or UKCoD. This represents a direct conflict of interests and independence is paramount