Language Access Guidance for the COVID-19 Response

Information
The City of Portland’s language access responsibilities fall under its obligation to ensure nondiscrimination on the basis of national origin per Title VI of the Civil Rights Act of 1964 and Executive Order 13166.
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The City of Portland is responsible for taking reasonable steps to provide equitable and meaningful access to it programs, services, activities, and communications to members of the public who have limited English proficiency and experience institutional language barriers.

Limited English proficiency (LEP) individuals are community members who often are multilingual and may be English language learners. An LEP individual may be able to communicate in English to a certain degree or in certain circumstances depending on the topic/vocabulary, but have the civil right, in accordance with Title VI, Civil Rights Act 1964 and E.O. 13166, to request access to information, services, and programs in their preferred language, from the City, free of cost.

City bureaus can take a proactive approach to meaningful engagement with limited English proficiency (LEP) communities by planning for language access needs. Bureau-initiated, pre-planned activities include translating information about a City program, service, or/and activity and disseminating materials appropriately; engaging LEP communities in the planning phase of new programs, services, activities, or projects.

Community engagement with culturally and linguistically specific community-based organizations and community leaders is vital when communicating about City programs, services, activities, and communications to multicultural communities whose primary language is not English.

Additionally, bureaus, and in this case, the Emergency Coordination Center and Joint Information Center, can take a proactive approach to access and engage in planned efforts for providing access. 

Tracking is a measurable way to document and report on language access compliance activity. Providing meaningful access includes fulfilling public-initiated language access requests and can also be a result of proactive measures taken by City bureaus. Both types of language access measures should be tracked.

Language Access Guidance for the Joint Information Center

Assessing vital documents for translation into commonly encountered languages:

To determine what documents are vital documents, the impact and importance of the documents in communicating pertinent information to the community should be considered.

The following are the overarching criteria considerations a bureau should use when determining the bureau’s vital documents:

Does the document have:

  • Safety implications
  • Health implications
  • Legal implications
  • Financial impacts
  • Notices of rights and disciplinary action

City bureaus will use the baseline vital document assessment criteria and determine its own additional criteria based on the programs, services, activities, and information it provides the community in English. During an emergency, assessment of vital documents is best achieved by working with linguistically specific community leaders and organizations who best understand the needs of the community. Additionally, an internal assessment using the above criteria in conjunction with community needs is best practice.

Providing meaningful access to limited English proficiency (LEP) community members takes into consideration that not all of the bureau’s documents can be translated, and yet careful consideration must be given to the vital document assessment in order to ensure that LEP community members have equitable access to the bureau’s/City’s information in the same manner that the English-speaking community experiences.

When creating new content, it is advised to use plain language. Prior to sending out a document for translation, ensure that you have used the clearest language possible in English on your original document(s). By doing so, you ensure the translated document communicates your message clearly.
Create content that:  avoids jargon, doesn’t cause text fatigue (too much text on the page), uses accessible info graphics when appropriate to convey a message. https://www.plainlanguage.gov/guidelines/

When listing languages on a webpage always list the language name in English and in the specific language. This is done so both English speakers (like city staff) and multilingual community members can identify the language on the page. Additionally, any link with a title that is a translated document should be titled in both languages (English and the translated language).

Current situation

The Emergency Coordination Center is currently taking proactive steps to ensure multicultural and multilingual communities will have access to communications regarding the current COVID-19 situation. Measures are being taken to embed equity into all aspects of the operations in collaboration with the Office of Equity and Human Rights.

Recommended websites with information in multiple languages (links that can be added to any city webpage as resources):

Multnomah County’s COVID-19 webpage contains updated health information in many languages and more languages are being added every day. Click on the languages listed and it will take you to the page with a list of languages, each with up to date health information regarding COVID-19.

https://usahello.org/  Information for immigrants and refugees. Many languages available.  

The CDC (Centers for Disease Control) and WHO (World Health Organization) also have information available in various languages.

As in regular city operations, any city program, service, or activity that is public facing should ensure that the staff are trained on how to use and connect to a telephone interpreter in order to fulfill requests from the public for language assistance. It is the public’s civil right to be provided with an interpreter free of cost.

All public-facing city documents must include a version of the meaningful access statement. Please review the guidance on the Office of Equity and Human Rights’ Civil Rights page for the guidance and translated versions of the statement. Within the translated versions please consider using the “add on” as a way to state in nine languages that translation and interpretation are available.

Sample:

Traducción e Interpretación  |  Biên Dịch và Thông Dịch  |  अनुवादन तथा व्याख्या

口笔译服务  |  Устный и письменный перевод  |  Turjumaad iyo Fasiraad

Письмовий і усний переклад  |  Traducere și interpretariat  |   Chiaku me Awewen Kapas

Translation and Interpretation:  XXX-XXX-XXXX

This language access guidance was created for the Emergency Coordination Center and Joint Information Center’s response to the COVID-19 emergency. This guidance contains information on language access procedures, resources, tools, and best practices for use citywide.

Additional resources for City staff:

https://www.justice.gov/crt/fcs/EmergenciesGuidance
https://www.justice.gov/crt/file/885391/download
https://www.lep.gov/