What is NUBSLI?
The National Union of British Sign Language Interpreters (NUBSLI) was established in May 2014 in response to the government’s changes to Access to Work. The campaign group, Stop Changes To Access to Work, had previously been established to challenge the divisive tactics being used by government against the deaf community and interpreters. However it soon became apparent that alongside the deaf community, the interpreting profession would also be targeted under the banner of the government’s 2012 welfare reforms.
NUBSLI was set up to ensure BSL/English interpreters/translators have a strong political voice, and so that the interpreters/translators could be protected from imposed detrimental changes to terms and conditions, and fees. In protecting the BSL/English interpreting profession, the Union also serves to protect and uphold the British Deaf community’s access to services.
“Standing up for interpreters; standing with the Deaf community”
Who is this guide for?
The aim of this guide is to provide some basic information to trainee and newly qualified interpreters, about working freelance and the support available to you. The guide may be useful to other interpreters at any stage of their career who are about to start freelance work.
Advice and guidance is always available for members of NUBSLI, whose aim is to ensure interpreters feel protected, safe and supported.Members also benefit from Unite’s legal services and a range of other membership benefits. You can find out more on their website.
Section 1: Setting up
There are currently three avenues of registration for BSL/English Interpreters: NRCPD, RBSLI and SASLI.
NRCPD registration currently costs £234 per annum for RSLI status, and £142 for TSLI status. Registered Sign Language Interpreters (RSLIs) must evidence 24 hours of Continuous Professional Development (CPD) per year to maintain their registration status with NRCPD. A large number of agencies and contracts only engage NRCPD registered interpreters. (For more information about CPD, see Section 4). Further details can be found on their website.
RBSLI registration currently costs £150 annually. RBSLI’s CPD system is compulsory for registrants. Evidence of ‘fully achieved’ CPD (18 hours) is shown on registrants’ profiles.
Further information on RBSLI can be found on their website.
Both regulatory bodies require evidence of your BSL/English Interpreting qualifications as well as DBS Checks, (see point e).
SASLI maintains a register of Sign Language Interpreters and Communication Professionals in Scotland. Registration is available in various categories and levels depending on a number of factors, available on their website and is for trainee and full members.
SASLI members are expected to accrue a set number of CPD points per membership year and be registered with the Protecting Vulnerable Groups Scheme (PVG Scheme), which is managed and delivered by Disclosure Scotland.
The Scottish Association of Sign Language Interpreters (SASLI) is going through a transition to become the Scottish Register of Language Professionals with the Deaf Community (SRLPDC)
b) Professional Membership
There are two professional membership organisations; Association of Sign Language Interpreters (ASLI) and Visual Language Professionals (VLP).
ASLI aims “to encourage good practice in sign language interpreting and to support our fellow professionals”. ASLI provides various training opportunities nationally at reduced rates for members, holds regional meetings, and has links to various resources including best practice recommendations. Current membership fees per annum are, £180 as an Associate member, and £204 as a Full member, both include annual PII cover. It is also possible to join as a Student member for £48 a year. Find out more
VLP’s aim is “to support each other on a local and national basis, to promote and maintain high standards of sign language interpreting and encourage good practice throughout the profession”. VLP accepts full and student members who are registered and regulated by NRCPD, RBSLI or SASLI. Annual membership is from £47 ( PII cover optional extra). Find out more
Both membership organisations hold conferences which interpreters can attend at a cost (discounts for members), the conference will usually provide you with around 12 hours of structured CPD – see section 4
Both have email forums which can be accessed for information and support.
The National Union of British Sign Language Interpreters (NUBSLI), is part of Unite the Union. It is the fastest growing union of a single profession and the first national union of sign language interpreters in the world.
NUBSLI’s aim is to protect the rights of BSL/English interpreters/translators working in the UK.
There are many benefits to joining NUBSLI and you will be a part of Unite the Union with further benefits:
Access to NUBSLI benefits:
- Being part of a democratic collective voice and having your say on issues that affect you
- Representation at the highest levels of government giving interpreters a political voice
- Representation to relevant groups (UKCoD, NRCPD, RBSLI, BDA, NRPSI/NUPIT/PI4J)
- Support with late payment issues
- Support with other legal and business issues
- Experienced union reps to support you and provide guidance
- Emergency support offered outside usual working hours
- Support offered for employed or freelance interpreters
- Freelance fee guidance which is updated annually by members
- Access to the monthly meeting via webinar
- Discussion on the issues affecting us now
- Regular communications keeping you up to date
- Making the profession more united and robust
- Free booking of rooms for CPD at Unite regional office for members
- Buddy system for Trainee interpreters
- Access to CPD via attendance at monthly or annual meetings or via webinar training
- Being part of a campaigning organisation working towards making our work/Access for Deaf people better
- Access to local members via Regional Organisers
- Be part of the 40% of interpreters who are already members
Access to Unite member benefits:
- Access to a 24 hour free legal helpline
- Free will service
- Access to affiliated services’ discounts e.g. foreign currency, insurances
- Discount rates for the Unite hotel in Eastbourne
- Discounted rates for financial advice in your own home
- Access to member breaks at Esher Place, Surrey
- Access to a credit union
- Access to the People’s Operator for great mobile phone deals
- Discounts for other services – e.g. tax return service
- Vouchers for referring new members to Unite
- Being part of the largest Union in the UK and campaigning with other Unions on similar issues
- Critical illness insurance advice
- Pension advice
- Free eye test
d) HMRC – Unique Tax Reference/Sole Trader/Ltd Company
As a freelance interpreter you must register with HMRC as self-employed. You need to decide on the structure of your business; for interpreters this is usually either a sole trader or a limited company.
When you contact HMRC they will register you for self assessment and provide you with a Unique Tax Reference (UTR) number. This number identifies you with the Tax Office as self-employed and you will be required to submit a self assessment tax return at the end of every financial year. The paperwork will differ depending on whether you are operating as a sole trader or a limited company.
Being a limited company (usually ‘limited by shares’), is a slightly more complex process in that you need a company name, to be registered with companies house and additional documents such as a Memorandum of Association. However, the setting up process is quite straightforward; it takes 24 hours and costs as little as £15. If you register via the online system, you can also use standard articles of association. Find out more on their website.
Whilst the paperwork can be more complex, it has the benefit of keeping your business finances separate from your personal finances, and as a Director of the company you are not liable for any of the company’s debts. Also, limited companies pay Corporation Tax which can be less than the tax paid as a sole trader.
Some self employed people complete their tax return themselves and some use an accountant. Whichever you choose you will need to keep records of your income and expenditure along with receipts. Information about what you are permitted to record as business expenditure can be sought from HMRC or an accountant.
e) Professional Indemnity Insurance (PII) and DBS
Professional Indemnity Insurance (PII) is a registration requirement for all interpreters. This insurance covers any fees/compensation costs should someone make a complaint against you or engage in a legal dispute over the services you have provided. You can obtain your own PII via insurance companies such as MHA or Hiscox. Cost will depend on level of cover. If you are a member of VLP or ASLI you will have PII provided as part of your membership.
A relevant background check is also a requirement for registration and should be obtained from the Disclosure Barring Service (DBS) or Protecting Vulnerable Groups Membership Scheme (PVG). You are advised to check with your registration organisation and any agencies you might accept assignments from what level of disclosure they require, as these may vary. Anyone working with children or vulnerable adults is required to undergo this background check.
There are agencies that will be able to process a DBS check on your behalf for a charge. There are also various companies that can administer this for you. If you’re a NUBSLI member and require assistance, please email email@example.com.
Once you have a DBS certificate in place, you can set up an automatic annual renewal which you must apply for within 19 days of receiving your certificate. This costs £13. Go to the gov.uk renewal website to find out more:
f) Registering with agencies
There are many agencies who you can register with to obtain work. There is no charter or quality mark for agencies, some are more reputable than others. It is useful to ask local interpreters about the best agencies to work with in your area.
Section 2: Fees/T&Cs/Finance
a) NUBSLI Fee Guidance
NUBSLI carried out a membership survey across the country to establish a guide on fees to assist freelance interpreters. You can read the fee guidance on our website.
The aim of this work was to establish a benchmark of fair, appropriate and sustainable fees for interpreters. The need for this guidance was heightened by government and some agencies attempting to drive down the profession’s fees and terms and conditions. In establishing fee guidance NUBSLI has made it possible for interpreters to be working in solidarity with one another to ensure we are all paid a fair wage and remunerated appropriately.
The fees for interpreters can vary slightly region to region, nevertheless, a ‘call-out’ fee of 3 hours, along with working to full/half day charged sessions developed as industry standard to ensure that the profession can be maintained. It is becoming more commonplace for agencies to offer rates of pay on 2 hour minimums, and hourly thereafter. This practice is threatening the sustainability of the profession.
Following the survey results, a call out fee has been included in the guidance. The fee reflects that some interpreters are able to do more assignments per day and therefore charge less to accommodate this.
We would recommend that interpreters think about local market forces when quoting for bookings, so as not to have a detrimental impact on other interpreters in the area. The work of NUBSLI on fees guidance requires the collective support of freelance interpreters sticking to their terms and conditions and fighting for fair and appropriate pay.
Please note: NUBSLI have taken advice from Unite the Union’s legal department about this piece of work and can confirm that this does not breach any competition laws.
For more information on NUBSLI Freelance Fee Guidance please see the FAQs on our website.
b) Terms & Conditions
Most interpreters will have a set of terms and conditions which detail cancellation terms, and specific conditions under which they are prepared to work. For example they may stipulate the following type of information: when a co-worker is needed, any required preparation materials, the need to be notified in advance if an assignment is to be streamed or recorded for public use, etc. Some choose to include their fee rates as well. The industry standard cancellation terms are as follows:
- Over 14 days – no charge
- 14-8 days – 50% charge
- 7 – 0 days – 100% charge
c) Record keeping
Accurate and timely record keeping are essential. It is recommended that you keep an up to date spreadsheet or log of all your bookings with the following information:
- Invoice number
- Date of booking
- Name of agency/ booker
- Booking reference number
- Agreed fee
- Agreed travel/expenses
- Date invoice sent
- Date payment received
You may wish to log further details such as the name of any co-workers and preparation requested or received.
Also, keep notes on any incidents or issues, e.g. travel problems, if the client does not arrive (how long did you wait, who said you were able to leave), any differences between the information provided about the job you accepted and the actual booking, and so on. These are essential in order to protect yourself in the case of any disputes.
Be aware of the need to protect any sensitive data appropriately so as to not be in breach of the Data Protection Act. Seek advice if you are not certain.
Timely invoicing is important to ensure you are paid within a given period. It is important you keep a record of when you sent your invoice to the organisation so that you can chase late payment and keep evidence. Sending invoices electronically is useful in identifying when invoices were sent.
Some interpreters choose to use invoicing software which provides a secure way to create and access your invoices remotely. Whilst some of these incur a charge there are benefits to using this method, for example you are able to set up automatic late payment notifications to your clients, and can send invoices simply from a smart phone. Any cost of business software can be offset against tax liability.
Some examples are:
e) Chasing payment/late payment charges
Government Late Payment Legislation stipulates that invoices should be paid within 30 days.
An interest calculator showing what you are legally entitled to charge is also available via this website which is currently set at 8% plus the Bank of England base rate, plus a compensation charge. It is good practice for your invoices to include a statement about the fact that you will levy late payment charges in accordance with legislation if necessary.
It is advisable to send a reminder on, or soon after, the due date. The point at which the decision to reissue an invoice with late payment charges added is an individual one. This may depend on what, if any, interaction you have received following a reminder email.
NUBSLI are able to access legal advice and representation via Unite’s legal department if members require support around late payments. Members requiring support can contact us at firstname.lastname@example.org.
f) Pension/Critical Illness cover
As a freelancer you will need to arrange your own pension, should you wish to have one. You can find out more about pensions on Unite’s website. Critical illness cover is also recommended.
SECTION 3: WORKING PRACTICES
a) Professional competence
NRCPD have a Code of Conduct to which regulated Trainee Interpreters and RSLIs must adhere. The Code states; “2.1. You should only undertake assignments for which you have the appropriate qualifications, competence and experience.”
You can see the full Code of Conduct on the NRCPD website.
Trainee interpreters should not undertake assignments in the following domains:
- Legal – Police/Court/Solicitors
- Mental Health
- Child Protection
- Social Services
- Disciplinary meetings
- Any assignment which involves the signing of legally binding documentation
If you are asked to undertake this work by an agency, you should refer them to the NRCPD Code of Conduct and contact NUBSLI for support.
Some assignments will require two interpreters (or perhaps a team of interpreters) to co-work. This could be due to the duration or complexity and should be discussed before a booking is confirmed.
You should request the name of your co-worker in advance from the person/agency who has booked you. This is important so that you can ensure they are suitably qualified and registered with NRCPD, SASLI or RBSLI.
If the proposed co-worker is unqualified/inexperienced, you should consider the potential impact this may have on the interpreted interaction, as well as the clients. Reference to the code of conduct of your respective regulator will assist you in reaching a decision on whether to accept or decline the assignment.
It is also good practice to make contact with your co-worker prior to the booking to share any relevant existing knowledge that either one of you may have, to talk over preferred ways of working together and to prepare for the assignment.
You are entitled to request preparation information and materials for assignments you are booked for and also to receive this with sufficient time to make use of the information.
If you have requested preparation and do not receive it you are entitled to withdraw from the booking under NRCPD’s Code of Conduct, section 3.
In addition, it is good practice to use your initiative to prepare as fully as possible, e.g using the internet to do research ahead of the assignment or speaking to colleagues.
d) Unethical practice/complaints
If you are concerned about the behaviour or practice of another interpreter, agency or client you can contact NUBSLI, your registration body (NRCPD, SASLI or RBSLI) or the booking agent. NRCPD, SASLI and RBSLI have a complaints procedure which can be accessed via their websites.
NUBSLI is interested in unethical practice by any agencies and welcomes case studies. If you have any information about agencies not adhering to industry standard fees or terms and conditions or practices such as charging interpreters fines please send email@example.com. This information will be used to support the work of NUBSLI and in supporting our members.
Section 4: CPD
a) What is required?
Continuous Professional Development (CPD) is the training, learning and development that is undertaken post qualification. As practice professionals, it is crucial for interpreters to maintain an up to date level of knowledge, to continue to develop our skills and challenge our thinking.
CPD can include conference events, training courses, webinars, further reading/research, mentoring or supervision and meetings with colleagues or mentors/supervisors
NRCPD currently require RSLI interpreters to log 24 hours worth of CPD per registration year. This means that you need to start collecting CPD hours from the day you upgrade your registration from TSLI to RSLI, ready to submit when you renew your registration the following year. You should decide on your own objectives for the year and record this as part of your evidence. The CPD you undertake during a year should link back to your personal set objectives.
The hours are split into ‘Structured’ and ‘Unstructured’ (see point c).Further information and details can be found in the NRCPD CPD handbook.
RBSLI do not have CPD as a mandatory requirement for registration. However they do support the practice and have a system for their registrants to log their CPD. RBSLI recommend interpreters log 18 hours of CPD per registration year. Further information can be seen on their website.
b) How to log and record
You can log the hours achieved on the NRCPD, or RBSLI websites under your account profile.
In addition to the log of time, you must keep your own more detailed records and evidence, (such as emails, certificates of attendance, powerpoint slides) of your CPD. If you are selected for audit from the NRCPD you need to be ready to present this evidence. This needs to include your CPD aims and objectives for the year, a reflective log of the activity undertaken, including what you learnt and gained in relation to your yearly objectives and your practice as a whole.
Therefore it is advisable to keep this record up to date and in order throughout the year, as and when you do any CPD.
Some interpreters use smartphone apps to record their CPD points. There are several of these available. Examples of these are:
- CPD Log
They can be found from the compatible app-stores for your device (Android/iTunes). Ask colleagues for recommendations.
c) Structured/Unstructured CPD
NRCPD require you to undertake a mix of CPD and hence the hours are divided into structured and unstructured.
In basic terms ‘structured’ CPD is the more formal activities with set objectives laid out e.g. training, organised events, facilitated supervision, courses and conferences (including the conferences of the membership organisations).
‘Unstructured’ CPD is the training or further learning you undertake on your own, this could be further reading, peer supervision groups or meetings with colleague(s) such as NUBSLI meetings, or self-reflection of your practice.Recording yourself interpreting and carrying out a discourse analysis or writing up a self-reflection account is another example of unstructured CPD.
It is good practice and strongly recommended for all interpreters to make arrangements to engage their own supervisor or mentor.
Many interpreters set up their own peer supervision groups which can take a structured format and be facilitated (either by a more experienced interpreter or an external professional, such as a psychologist), or more informally just as a forum for colleagues to discuss their issues/dilemmas with each other.
One to one supervision/mentoring is extremely beneficial in allowing a practitioner the space to take a more holistic perspective on their work, allowing for more informed thinking to develop enhanced self-reflection skills.
The benefits of these practices are widely recognized. During the early stages of your career either mentoring or supervision is highly recommended.
SECTION 5: MISCELLANEOUS
a) Where can I get further info/help?
b) Joining NUBSLI
Joining NUBSLI is as easy as 1, 2, 3…
- Join using Unite’s website (or join using the Unite the Union app).
- Wait for an email confirming your membership number.
- Send your membership number firstname.lastname@example.org or use our online form.
Important: Once you’ve joined Unite, you must tell us your membership number. This is to make sure that you are added to NUBSLI.