Translation Policy

1. Purpose/Abstract

The University acknowledges the importance of being able to exercise effectively its responsibility for academic standards when the delivery and/or assessment of academic awards are conducted in a language other than English. This policy makes explicit the University’s requirement for translation of relevant documents and assessed student work.

2. Scope

The scope of this policy covers any academic (collaborative) partnership that is operating primarily in a language other than English, so that the University will be able to maintain academic standards and oversight of all relevant aspects of the partnership for operational and quality assurance purposes.

Where the partnership delivers in a language other than English and where appointed staff and external examiners are not bilingual it will be necessary to: 

i. Translate institutional documentation (including all materials relating to assessment and assessed student work) into English, 

ii. Translate institutional documentation (including all materials relating to assessment) to the partner’s primary language of delivery / instruction

iii. Translate business relevant documentation where appropriate

This policy applies to delivery and assessment in a language other than English specifically for:

i. Academic partners (academic and professional services)

ii. External Examiners

iii. University colleges and professional service departments

iv. Agreements and contracts between an academic partner and the University

v. University Academic Regulations, relevant policies, and procedures

vi. University of Derby certificates and/or transcripts (Where the latin/roman alphabet is not used and/or where there is an in-country requirement for translation of the documents)

vii. Marketing and publicity materials

viii. Programme and module documentation such as programme and module specifications, handbooks, assignment briefs, examination papers and assessment feedback

ix. Committee minutes and agendas

x. Samples of assessed student work

xi. Student communications

xii. Student records

3. Definitions

i. College Quality Assurance and Enhancement Committees (CQAEC)

ii. Collaborative and Partnerships Sub-Committee (CPSC)

iii. Academic Development and Quality Committee (ADQC)

iv. The term ‘delivery’ in this policy includes delivery and assessment

4. Policy Statement

An academic partnership that is delivering and assessing in a language other than English will require translation of documentation from the language of delivery into English and vice-versa, where the appointment of staff and external examiners who are not bi-lingual so that the University can assure all relevant aspects of the partnership are compliant with the Office for Students Regulatory Framework. This includes (and is not specifically limited to) translation of institutional documentation (such as Academic Regulations, policies, and procedures), learning, teaching and assessment materials, assessed student work, committee agendas and minutes, certificates and transcripts and marketing materials. Translation of these requires careful quality management and the use of high-quality independent translation services approved by the University.

Assessment of student work must be in the language of delivery (for avoidance of doubt all student work must be assessed and moderated in the original language of delivery e.g. reports, essays, coursework, examination papers, presentations). 

Appointment of External Examiners/Moderators, and academic staff responsible for moderation should normally be bilingual with a good working knowledge of the language of delivery and appropriate subject expertise. This is to ensure the fairest and most economical approach to assessment/moderation in a language other than English. Where it is not possible to appoint bilingual staff then translation of the materials is a clear requirement.

Where translation is necessary the translation must be undertaken by:

i. An independent and qualified translator who can provide accurate and official translations with subject knowledge, nominated by a local British Council office and approved in advance by the University.

Translated materials must be quality assured through control translations.

4.1 Control Translations

Control translations should be used to quality assure translations. Control translations should be conducted on an annual basis by an independent and suitably qualified translator who has not taken part in any translations that are to be verified by this process. The translator should be independent from the academic partner and approved by the University

Control translations are a sample of translated documents that are checked for accuracy in translation from the original language of delivery / instruction to the English language. Such control translations are carried out to verify translations and assure the University of the standard and quality of the translation(s) undertaken [accuracy, register, meaning of the translations] by comparing them with the original in the first language. The activity does not produce a further translation but instead a report on each piece of work for consideration by the University. Documents to be verified by the control translations would normally include student coursework and/or examination papers from specific modules, regulatory documents and operational documents. A representative sample of documents such as policy documents, marketing materials, programme delivery/teaching documents and assessed student work should be selected by the University on an annual basis for control translations.

Where the control translation report or other feedback indicates that the translation is not of the necessary standard and quality for External Examiners and staff in the University to fulfil their responsibilities (such as internal and external moderation) then the University is responsible for investigating the particular translator/agency and making further checks on their work. In assessing the impact of the insufficient standard and quality of the translation the University may take immediate action to require that another agency be employed.

4.2 External Examiners

External Examiners should normally be bilingual with a good working knowledge of the language of delivery and appropriate subject expertise. They should externally moderate in the original language of delivery and assessment. Where it is not possible to appoint a bilingual external examiner, translation of the materials is a clear requirement.

As well as moderating student work, the External Examiner is responsible for moderating assignment briefs and examination papers in the original language of delivery. Where the External Examiner is not bilingual, translation of these materials is a clear requirement.

Appointment of bilingual External Examiners with appropriate language, subject expertise and experience of UK Higher Education should be a key factor in any decision to approve a new academic partnership/delivery of a new programme by the academic partner, where the language of delivery is not English.  

4.3 Internal and External Moderation

The Moderation policy of the University requires that all work on all modules and at all   locations are sampled (in line with the University’s Internal Moderation Policy) and internally moderated by University of Derby staff adhering to the University’s Academic Regulations. Where University of Derby staff and External Examiners are not bilingual with appropriate language and subject expertise the moderation sample must be translated.

4.4 Management and Review of Translation Requirements

As part of continual monitoring Programme Leaders, Academic Partnership Leads and the Academic Partnerships Office must monitor and review control translations and other relevant feedback.

Where the control translation report or other feedback indicates that the translations are not of the necessary standard for External Examiners and staff in the University to fulfil their responsibilities (such as internal moderation) then the Academic Partnership Lead and/or Academic Partnerships Office are responsible for investigating the particular translator and carrying out further checks on their work and/or require that a different translator is employed.

4.5 Postgraduate Research language of communication

Normally, for Postgraduate Research provision materials submitted for examination shall be written in English and the viva-voce examination shall also be conducted in English. Exceptionally, because of the inclusion in the thesis of reference to original materials in other than the English language, the nature of the study or of the works submitted may necessitate a variation of this norm in which case the student should seek approval of the variation from the the College Research Committee.

4.6 Agreements and contracts

Agreements and contracts between the academic partner and the University should include provisions relating to:

i. the language of delivery and of assessment

ii. responsibilities and management of translations

iii. documentation /materials that must be translated e.g., certificates and transcripts

iv. financial implications for translation, taking into account the volume of work to be translated and the cost of control translations and quality assurance quality assurance of the translations

v. appointment of bilingual academic staff with appropriate language, subject expertise and experience of UK Higher Education

vi. The operational manual (and/or its replacement) must include information about language of delivery, appointment of staff, translation processes in-line with this policy and translation of documentation

4.7 Awards, Certificates and Transcripts

Transcripts must record the name of the Academic Partner organisation and the language of delivery. Where the language of assessment is not the same as the language of delivery this must be made clear on the transcripts.

4.8 Assessment Boards

Assessment Boards irrespective of the language of delivery must be conducted in English and be managed by the University of Derby, in-line with the University’s Academic Regulations. 

4.9 Documentation / Materials

A list of documentation and materials that should normally be translated into English and the language of delivery (where an academic partner delivers in a language other than English):

i. Publicity/marketing materials

ii. Claims for Recognition of Prior Learning

iii. Programme handbooks and other key information provided to students that relate to the University of Derby Award

iv. The University Academic Regulations and core policies

v. Programme specifications, module specifications, operational manual, and other documentation for staff and students

vii. Minutes of relevant committees, assessment boards and any other key meetings

v. Materials required for monitoring purposes e.g., analyses of student feedback, external examiner reports / responses, continual monitoring Self-evaluation Documents

vi. All materials relating to assessment and moderation, e.g., all draft examination questions (and model/example answers etc.) and moderation samples

vii. Certificates and transcripts

viii. All materials relating to assessment and moderation, e.g., all draft examination questions (and model/example answers etc.) and moderation samples

ix. Certificates and transcripts (where the latin/roman alphabet is not used and/or where there is an in-country requirement for translation of the documents).

Where necessary all digitally stored translations and sensitive data should be encrypted.

5. Policy Implementation

This policy provides amendments that update structural terminology used within the document to simplify and streamline the translation policy approved in 2015 by Academic Board.

Oversight and governance of the implementation of this policy is through the deliberative structure of the University. Firstly, by Programme Committees reporting to and College Quality Assurance and Enhancement Committee (CQAEC), who in turn provide annual assurances of compliance to the Collaborative and Partnerships Sub-Committee (CPSC), a sub-committee of the Academic Development and Quality Committee through Continual Monitoring. Where there are instances of non-compliance this must be reported to the relevant College Quality Assurance and Enhancement Committee (CQAEC) so that risks to the institution are mitigated.

The requirements set out in this policy form part of agreements and contracts with academic partners and are included in all operational manuals (and / or their replacement).

This revised policy comes into effect February 2023, with communication and revised implementation guidance published by February 2023

6. Sanctions

Where instances of non-compliance with this policy are identified by the Academic Partnerships Office, Programme Leader and/or Academic Partnership Lead this must be reported to the relevant College Quality Assurance and Enhancement Committee (CQAEC) so that risks to the institution are mitigated. The CQAEC must report this and any action taken to mitigate risk to CPSC. Partners operating outside of this policy must agree an action plan and timescale to move to a position of compliance with the Policy as quickly as is practicable. This should be approved by the CPSC and monitored by the relevant CQAEC.

7. Related Documentation

Internal Moderation

External Examiners

Continual Monitoring

8. References 

Data Protection Act 2018. 

9. Equality Analysis

Equality analysis has been conducted, for further information please contact the policy owner. 

Appendix 1

Translation Document Table - Documents and allied processes derived from University Academic Regulations which will be provided to students, staff and external examiners to enable effective delivery and assessment in a language other than English.

Control Translation Flow Chart transcript

1. Documents identified for translation by Project Manager

2. Schedule for translation published to all relevant parties

3. Translators identified and approved using criteria published in this policy

4.

a. Original document generated in English to be translated into partner language of instruction

OR

b. Original document generates in partner's language of instruction to be translated into English

If b:

5. Sample agreed for control translation and sample provided in English and partner language of instruction to the control

6. Control Translation report generated and considered programme committee/College Quality Enhancement Committee

7.

a. No issues identified

OR

b. Issues identified

If a, skip to 9.

If b, continue to 8.

8. Corrective action taken in-line with the policy

Continue to 9 OR return to 4b.

9. Annual Translation Control Report and Annual Monitoring provide data for the review of the translation table in section 8, and which documents should continue to be translated.