LANGUAGE ACCESS PLAN PROCEDURES Free Library of

LANGUAGE ACCESS PLAN PROCEDURES

Free Library of Philadelphia

January 2022

Table of Contents

1. Purpose and Authority 3

2. General Policy 4

3. Language Access Coordinator 5

4. Direct Contact with LEP Individuals 6

5. Language Access Services and Protocols 6 - 10

A. Interpretation

1.) Services Provided

2.) Protocols

3.) Procedures

B. Free Library Locations

C. Translation

1.) Services Provided

2.) Protocols

3.) Procedures

D. Staff Training

E. Multilingual Staff

6. Notice of the Right to Language Access 10

7. Language Access Complaint Procedure 11

8. Data Collection 12

Free Library of Philadelphia

LANGUAGE ACCESS PLAN

PURPOSE AND AUTHORITY

A. In Cooperation with the Mayor’s Office, the Free Library of Philadelphia is

committed to compliance with Title VI of the Civil Rights Act of 1964, 2 C.S. § 561 et

seq. (Act 172 of 2006), and the Philadelphia Home Rule Charter § 8-600 and § A-200,

in ensuring meaningful access to City services and programs for individuals with

limited English Proficiency (LEP).

B. The purpose of this document is to establish an effective plan and protocol for

The Free Library of Philadelphia personnel to follow when providing services to,

or interacting with, individuals who have limited English proficiency (LEP).

Following this plan and protocol is essential to the success of our mission to

advance literacy, guide learning, inspire curiosity, and promote diversity and

inclusion.

GENERAL POLICY

A. The Free Library of Philadelphia recognizes that the population eligible

for services includes individuals who are Limited English Proficient (LEP).

It is the policy of The Free Library to ensure meaningful access to LEP

individuals. The Free Library of Philadelphia adopts the following policy

to ensure that LEP individuals can gain equal access to The Free Library‘s

services and communicate effectively. This Plan applies to all Free Library

departments and neighborhood libraries.

B. It is the City’s policy to grant access to services or programs to every

person, even when the person has a limited ability to speak, understand,

read, or write English. The Free Library intends to take reasonable steps to

provide LEP persons with meaningful access to services and programs. The

Free Library seeks to reduce barriers by increasing its capacity to deliver

services and benefits to people in their primary language.

C. The Free Library bears the responsibility for providing appropriate services.

Staff at the initial point of contact have the duty to identify language

needs. The use of informal interpreters such as family, friends of the

person seeking service, or other customers should be discouraged. Minor

children are prohibited from acting as interpreters. No staff may suggest or

require that an LEP customer provide an interpreter in order to receive

services

D. The preferred method of serving LEP persons is by:

(1) Using competent bilingual staff able to provide services directly to

the customer in his/her/their primary language without the need for

an interpreter. (2) Available, trained, competent bilingual staff may be

used for in-person or telephone interpreting to support other staff.

(3) Staff should seek assistance from professional telephonic

interpreters.

LANGUAGE ACCESS COORDINATOR

Lindsay Southworth

Senior Program Manager - Adult Education and Language Learning

Free Library of Philadelphia

Parkway Central Library

1901 Vine Street, 1M

southworthl@freelibrary.org

215-686-8664

DIRECT CONTACT WITH LEP INDIVIDUALS

The Free Library of Philadelphia has several points of contact with the public:

LEP individuals visit neighborhood libraries, attend library programs, call the library and

interact with library staff at community events throughout the city. In these instances, if

there is no bilingual staff available to interpret, staff will use telephonic interpretation

A) INTERPRETATION

Interpretation is the immediate oral rendering of the source language into the

target language.

Services Provided

● To ensure that the inability to communicate in English does not deprive the

public of rights and privileges, our department will provide an interpreter,

at no cost to the resident, for LEP individuals. Services offered include:

available, trained, competent bilingual staff and in-person telephonic

interpretation.

Protocols

● An individual approaches an employee and appears to be asking for help but has

difficulty communicating what he or she needs, and/or when a request for an

interpreter is made either orally, in writing, or by pointing to a language poster,

the employee shall determine whether a bilingual staff member is available who

speaks the language being requested. When bilingual staff is not available, the

employee shall contact a telephone interpreter service(GLOBO) to provide

interpreter services, the process to do so is outlined below:

○ Dial 267-318-XXXX

○ When prompted, enter the Location code for your library (the last 4 digits of your

library’s phone number) and follow the prompts.

● If GLOBO is not able to provide interpretation services for the language requested, call

United Language Group at 800-535-XXXX and follow the instructions given.

B) FREE LIBRARY LOCATIONS

Andorra Library

Independence Library

Queen Memorial Library

Blanche A. Nixon/

Cobbs Creek Library

Joseph E. Coleman

Northwest Regional Library

Ramonita G. de Rodriguez

Library

Bushrod Library

Katharine Drexel Library

Richmond Library

Bustleton Library

Kensington Library

The Rosenbach

Cecil B. Moore Library

Kingsessing Library

Roxborough Library

Charles L. Durham Library

Lawncrest Library

South Philadelphia Library

Charles Santore Library

Library of Accessible Media for

Pennsylvanians (LAMP)

Tacony Library

Chestnut Hill Library

Lillian Marrero Library

Thomas F. Donatucci, Sr.

Library

David Cohen Ogontz Library

Logan Library

Torresdale Library

Eastwick Library

Lovett Memorial Library

Wadsworth Library

Falls of Schuylkill Library

Lucien E. Blackwell West

Philadelphia Regional Library

Walnut Street West

Fishtown Community Library

McPherson Square Library

Welsh Road Library

Fox Chase Library

Nicetown-Tioga Library

West Oak Lane Library

Frankford Library

Northeast Regional Library

Whitman Library

Fumo Family Library

Oak Lane Library

Widener Library

Greater Olney Library

Overbrook Park Library

Wynnefield Library

Haddington Library

Parkway Central Library

Wyoming Library

Haverford Library

Paschalville Library

Holmesburg Library

Philadelphia City Institute

C) TRANSLATION

Services Provided

● To ensure that the inability to communicate in English does not deprive the public

of rights and privileges, our department will continue to provide translations, at no

cost, for LEP individuals.

Protocols for Document Translation

The following vital written documents have been translated: Arabic, Simplified Chinese,

French, Spanish, Russian, and Vietnamese.

● Library Card Application

● Reconsideration of Library Materials

● Standards of Acceptable Behavior

● Holiday Closing Signs

● Unattended Children Signs

● We Speak Your Language poster

● Photo Release Forms

● Program flyers (sample here)

Procedure for Submitting a document for translation: Email your request to

southworthl@freelibrary.org. If you are submitting a design request and would also like

translation, please note that translations can add three to four weeks to the graphic design

process and are subject to the availability of funds for this service.

D) STAFF TRAINING

The Free Library’s Language Access Plan & Protocol will be provided to all staff at the Free

Library, posted on the intranet, and provided as a hard copy to all Free Library staff members at

hiring so that all staff will be knowledgeable of Language Access Plan policies and procedures.

In order to continue meaningful access to library information and services for LEP individuals, all

public service staff will receive annual Language Access Plan training, or training upon

employment, and then annually through the Free Library’s Cluster Meetings.

Language Access Plan training will include information on the following topics:

- Legal obligation to provide language assistance;

- Language Access Plan and protocols;

- Identifying and responding appropriately to LEP individuals;

- Obtaining interpreters (over the phone);

- Using and working with interpreters (over the phone);

- Translating procedures;

- Using or not using multilingual staff as in-house interpreters and access to these staff

members;

- Reporting data about Language Access.

New staff training will be provided on the Free Library’s Language Access Plan to provide

guidance on how to effectively communicate with LEP library users.

E) BI/MULTILINGUAL STAFF

FREE LIBRARY STAFF - WORLD LANGUAGE SKILLS

The list of identified staff that can deliver services directly in a language other than English or

serve as interpreters for other employees can be found on Employee Intranet under Human

Resources-- Staff Roster.

World Language

Number of Staff

World Language

Number of Staff

ASL (American Sign Language)

Italian

Arabic

Japanese

Bengali

Mandarin

Bosnian

Portuguese

Cantonese

Romanian

Croatian

Russian

French

Spanish

German

Serbian

Greek

Tamil

Hokkien

Ukrainian

Hungarian

Yiddish

NOTICE OF THE RIGHT TO LANGUAGE ACCESS

Posters notifying LEP individuals of their right to language access are displayed in areas of public

contact at all 54 library locations across Philadelphia in the seven languages most prevalent in

the City.

LANGUAGE ACCESS COMPLAINT PROCEDURE

You may file a formal Language Access grievance with the Office of Immigrant Affairs if you

believe you have been wrongly denied the benefits of this Language Access Plan. You must file

your complaint within 6 months of the alleged denial. To file a formal complaint, you must fill

out a Language Access Grievance Form and submit the form in person, by mail, or email to:

Office of Immigrant Affairs

Maria Giraldo-Gallo

Language Access Program Manager

1401 JFK Blvd., Suite 1430

Philadelphia, PA 19102

Email: Maria.Giraldo-Gallo@phila.gov

The form is available on OIA’s website.

Additionally, any person, regardless of immigration status, may submit a formal legal complaint

through the Philadelphia Commission on Human Relations. To do so, please complete a Public

Accommodations Discrimination Intake Form and submit it in person or by email to:

Philadelphia Commission on Human Relations

The Curtis Center

601 Walnut Street, Suite 300

Philadelphia, PA 19106

To access the form and for more information, please visit www.phila.gov/humanrelations

DATA COLLECTION AND ANNUAL REPORT

The following information will be required to be monitored and collected by departments and

will be collected via annual reports by the Office of Immigrant Affairs:

a. Number of hours staff spend providing services in languages other than English.

b. Number of minutes of over-the-phone interpretation.

c. Number of Documents Translated

d. Language Services Expenditures

e. Number of bilingual staff

f. Number of staff trained in Language Access/Cultural Competency

When staff members provide interpretation, we will need to collect the following data: name

(staff), library, language, and approximate hours per month spent providing services in this

language. You may utilize the table below for tracking purposes.

LIBRARY

NAME (staff)

LANGUAGE

HOURS (per month)

When the library provides programs in languages other than English, we will need to collect the

following data: library, name of program, language provided, program description

LIBRARY

NAME OF PROGRAM

LANGUAGE

PROGRAM DESCRIPTION

The Free Library will conduct an annual evaluation of its Language Access Plan to determine its

overall effectiveness, review the progress of department goals and identify new goals or

strategies for serving LEP residents. The evaluation will include the following:

a. Assessment of the use of telephonic interpretation, in-person interpretation, and

translation services.

b. Assessment of data collected about the LEP’s primary language.

c. Assessment of the number and types of language requests during the past year.

d. Assessment of whether staff members understand the Language Access Plan and

procedures, how to carry them out, and whether language assistance resources and

arrangements for those resources are up-to-date and accessible.

e. Assessment of complaint information; and

f. Assessment of soliciting feedback from LEP individuals and community groups.