Compliance Policy

 

The purpose of this Compliance Policy is to establish a framework for remote interpreters to follow in their work with ProZ.com. This policy outlines the minimum standards that all remote interpreters must adhere to, including ethical conduct, confidentiality, data protection, and compliance with relevant laws and regulations.

ProZ.com expects all remote interpreters to understand and comply with this policy. Failure to comply with this policy may result in disciplinary action, up to and including termination of the interpreting contract. Adherence to this policy is essential to maintain our reputation and provide the highest quality interpreting services to end clients, partners, and non-profits.

 

This document is to be used internally as a guideline by the Compliance Officer to carry out their daily tasks.

 

 

Keep strictly confidential all information obtained during interpreting assignments, while observing relevant requirements regarding disclosure. Confidential information will not be published, communicated, or disclosed to any person or organization outside of the assignment. Confidential information includes but is not limited to: 

 

• Name, age, gender, etc. of the participants
• Day of the week, time of day, time of year the session occurred 
• Location 
• Other people involved
• Details discussed
• Any personally identifiable information

 

Note: Confidentiality may need to be broken if a threat of self-harm or harm to others is made in the presence of the interpreter but without the client present.

 

 

Provide the most accurate interpretation possible without altering, adding, or omitting anything stated during the assignment. Accuracy includes:

 

• Interpret everything said by all participants.
• Respect the intention behind the message.
• Interpret rude, uncomfortable, obscene, or other difficult or embarrassing language.
• Reflect the tone, attitude, and emotions of the speaker.
• Maintain the register (level of language, from formal to informal).
• Capture cultural aspects of the message. 

 

For sign language interpreters: 

• Choose the linguistic register and mode of communication that the Deaf person understands best. 
• Interpret what is uttered and convey other relevant auditory and visual information.

Maintain impartiality by not sharing personal opinions, beliefs, or imposing personal biases during the interpreting session, even if the interpreter disagrees with the message on personal or moral grounds. Impartiality includes:

 

• Avoiding body language, gestures, tones of voice or facial expressions that could reveal personal feelings or value judgments.
• Avoiding conflicts of interest. If the interpreter has any perceived or real conflicts of interest, they will disclose this information before committing to an assignment. 
• Not sharing opinions or giving advice (even if asked to do so).
• Not attempting to influence any participant.
• Withdrawing from the session if impartiality becomes impossible. 

 

Act professionally and ethically; demonstrate objectivity and show conduct consistent with the basic principles of relevant codes of ethics. Professionalism includes:

 

• Refraining from participating in assignments that are outside the interpreter’s professional skills, language fluency, or level of training.
• Not accepting assignments for which the interpreter does not have the required certification or qualification.
• Providing excellent customer service by employing a professional demeanor and being courteous and respectful to all.
• Not stating that any participant “understood” (or “misunderstood”) your interpretation. (Providers and clients are responsible for checking for understanding.).
• Dressing professionally.
• Taking calls in a secured environment where personal and/or personal health information (PHI) will not be at risk.
• Remaining in a session for its entirety, ensuring to confirm with all participants that the session is complete. 
• Staying informed of and adhering to BPIN policies and guidelines that relate to professional duties. 
• Staying up to date with the latest professional standards and protocols.

 

Maintain the boundaries of the interpreter’s role by ensuring professional distance for the duration of the interpreting session. Role boundaries are dictated by the interpreting specialization and setting; it is the interpreter’s responsibility to act within the appropriate boundaries for each session. Role boundaries include: 

 

• Limiting social relationships or interactions with participants to professional courtesy and respect.
• Not offering guidance, making recommendations, or providing additional resources.
• Clarifying your interpreter role as needed. 
• Supporting the communicative autonomy and decision-making of all participants, notwithstanding pressure or influence to do otherwise. 

 

 

Actively pursue continuing education to improve professional knowledge and skills. Professional development includes: 

 

• Staying updated on all platform upgrades or changes by watching the training videos and other instructional materials sent by ProZ.com.
• If certified, meeting all requirements to maintain certification. If certification lapses, Boostlingo must be informed, and the interpreter’s profile will be updated.
• Pursuing professional development training opportunities.

 

 

Treat everyone with respect. Respect includes: 

 

• Upholding the dignity of participants.
• Promoting communicative autonomy of all participants.
• Using culturally appropriate forms of address. 

 

 

Conduct professional relationships with collegiality, cordiality, and mutual support. Professional relationships include: 

 

• Supporting and mentoring newer colleagues.
• Avoiding criticizing, slandering or otherwise insulting colleagues.
• Resolving disputes with colleagues collaboratively and amicably.
• Conducting yourself with courtesy, fairness, respect, and professionalism with colleagues
• Upholding the interpreting profession and its dignity
• Engaging in the utilization of autoclicker software or any supplementary tools that might confer an unjust advantage to interpreters is strictly disallowed. ProZ.com upholds a commitment to fairness and integrity in the interpreter community, and as such, the use of such mechanisms is deemed unacceptable and runs counter to ProZ.com's mission. The aim of this is to ensure a level playing field for all interpreters, fostering an environment where proficiency and skill are the primary factors that contribute to successful outcomes.

 

These are critical precautions that, when not taken, expose a serious risk to patient privacy and security. The interpreter should disconnect from the pool if they are not able to guarantee that these privacy measures will be taken.

 

The ProZ.com Privacy Safeguards are the following:

 

1. Make sure all calls are taken in a private room, doors and windows closed.
2. Make sure you are completely alone in you work room and that no one else can enter during a call.
3. Make sure the room is properly insulated and that no noise can come in or out during a call.
4. Wear headphones.

 

These are the most important requirements to take a call. Interpreters should observe these requirements at all times.

 

Please note that non-compliance with any of these four requirements will result in immediate removal from the interpreter pool. 

 

 

ProZ.com also requires that interpreters comply with certain quality standards. Interpreters are expected to strive for excellence. These requirements help ensure customer satisfaction with each call.

 

The ProZ.com Quality Requirements are the following:

 

1. Provide a faithful and functional interpretation.
2. Be dressed professionally.
3. Have a neutral background, ie. a solid color wall, curtain, or backdrop (for VRI only).
4. Have good lighting (for VRI only).
5. Be courteous at all times.

 

 Non-compliance with any of these ProZ.com Pool requirements will result in the temporary deactivation of your interpreter pool profile. The Quality Assurance Specialist will contact you to schedule a test call. The purpose of this call will be to assess your environment and help clarify what went wrong during the call. If all the requirements are met, the pool interpreter profile will be activated again. Permanent deactivation may be considered after repeated violations of the ProZ.com Quality Requirements.

Introduction:

 

HIPAA, the Health Insurance Portability and Accountability Act, is relevant to remote interpreters because they are often involved in healthcare communication and may have access to protected health information (PHI). Protected health information is any information that can be used to identify an individual and is related to their health status or healthcare services. This includes information such as medical history, diagnosis, treatment plans, and medication lists.

 

Remote interpreters, including video remote interpreters, may work with healthcare providers and patients to facilitate communication and ensure that patients with limited English proficiency or those who are deaf or hard of hearing can receive the care they need. In doing so, they may come into contact with PHI, which is protected under HIPAA regulations.

 

HIPAA requires that covered entities, including healthcare providers, health plans, and healthcare clearinghouses, maintain the privacy and security of PHI. This includes requirements for access control, data transmission security, breach notification, and business associate agreements. As remote interpreters may have access to PHI during their work, they must also comply with HIPAA regulations to protect patient privacy and maintain the security of patient information.

 

Headset Use:

 

VRI interpreters must use a headset during all calls to ensure the privacy and confidentiality of patient information. Headsets should be used to prevent background noise and ensure that only the VRI interpreter can hear the call. Headsets should also be cleaned and disinfected after each use to prevent the spread of infection.

 

Password and Login Credential Protection:

 

VRI interpreters must protect their passwords and login credentials at all times. Passwords must be strong and not shared with anyone. VRI interpreters must log out of their accounts when not in use and avoid using public Wi-Fi or unsecured networks when accessing their accounts.

 

Private Workspace:

 

VRI interpreters must work in a private workspace to ensure that no one else can hear calls or access patient information. The workspace should be free from distractions and secure. The workspace should also be kept clean and organized to maintain a professional environment.

 

Ensuring Confidentiality:

 

VRI interpreters must ensure the confidentiality of patient information during all calls. Interpreters must not share patient information with anyone except for authorized healthcare providers. Interpreters must also follow all HIPAA guidelines regarding the handling and sharing of patient information.

 

 

In addition to the requirements outlined in the previous HIPAA compliance policy for Video Remote Interpreters, the following five additional requirements are important to ensure privacy and security according to HIPAA:

 

Interpreters who have access to remote interpreting calls must meet certain qualifications and training requirements to ensure that they can provide accurate and professional interpreting services while also maintaining the privacy and security of patient information. The qualifications and training requirements for remote interpreters are outlined as follows:

 

1. HIPAA-Compliance Training: Interpreters must complete HIPAA-compliance training to understand the requirements for protecting patient privacy and the consequences of non-compliance.
2. Basic ProZ.com Remote Interpreting Training: Interpreters must complete basic remote interpreting training to develop the skills needed to provide accurate and professional interpreting services via remote platforms.
3. Signed Code of Conduct: Interpreters must sign a code of conduct that outlines the ethical and professional standards expected of them while providing interpreting services.
4. Signed Agreements: Interpreters must sign agreements that outline their responsibilities for protecting patient privacy and maintaining the security of patient information while providing interpreting services.
5. ID Card with Name and Picture: Interpreters must have an ID card with their name and picture on it to confirm their identity and ensure that only authorized interpreters have access to remote interpreting calls.
6. Language Proficiency Certificates: Interpreters must possess language proficiency certificates to demonstrate their ability to provide accurate interpreting services in the languages they interpret.

 

For interpreters with a medical specialization, the following additional qualifications and training requirements apply:

 

1. Annual Proof of HIPAA-Compliance Training: Interpreters with a medical specialization must provide annual proof of HIPAA-compliance training to ensure that they are up to date with the latest HIPAA regulations and requirements.
2. Proof of Medical Terminology Training: In addition to the 40-hour basic medical interpreter training, interpreters with a medical specialization must provide proof of medical terminology training to ensure that they have the knowledge and understanding of medical terminology needed to provide accurate interpreting services in medical settings.
3. 3+ Years of Experience in Medical Interpreting: Interpreters with a medical specialization must have a minimum of 3 years of experience in medical interpreting to demonstrate their proficiency in providing interpreting services in medical settings.

 

By meeting these qualifications and training requirements, interpreters can ensure that they are prepared to provide accurate and professional interpreting services while also maintaining the privacy and security of patient information in compliance with HIPAA regulations.

Canada: HIN, National Standard Guide for Community Interpreting Services

Australia: AUSIT Code of Ethics and Code of Conduct

United Kingdom: ITI Code of Professional Conduct 
Boostlingo Code of Conduct: https://cfcdn.proz.com/file_resources/trainings/5edb8d77e413c1243082ce8ffa254120_BPIN for BPIN Partners.pdf