Title

Machine Translation

Ensuring Meaningful Access

for Limited English Proficient

Individuals

Michael Mulé, DOJ

Robin Runge, CRC

U.S. Department of Labor

Civil Rights Center

June 24, 2014

Overview

Civil Rights Obligations

Key Terms

Translation Examples

Transitioning Towards a Multilingual Site

Best Practices

Title VI of the Civil Rights Act of 1964

“No person in the United States shall, on

the ground of race, color, or national

origin, be excluded from participation in,

be denied the benefits of, or be subjected

to discrimination under any program or

activity receiving Federal financial

assistance.”

Section 188 of the

Workforce Investment Act of 1998

“No individual shall be excluded from

participation in, denied the benefits of,

subjected to discrimination under, or denied

employment in the administration of or in

connection with, any such program or activity

because of race, color, religion, sex (except as

otherwise permitted under title IX of the

Education Amendments of 1972 (20 U.S.C.

1681 et seq.)), national origin, age, disability,

or political affiliation or belief.”

Lau v. Nichols, 414 U.S. 563 (1974)

National origin discrimination includes

failing to provide LEP individuals

“meaningful access” to federally-

funded programs.

http://go.usa.gov/4KVd

Workforce Investment Act of 1998

Implementing Regulations 29 CFR 37.35

§37.35 What are a recipient's responsibilities to provide services

and information in languages other than English?

a. A significant number or proportion of the population eligible to be

served, or likely to be directly affected, by a WIA Title I-financially

assisted program or activity may need services or information in a

language other than English in order to be effectively informed about,

or able to participate in, the program or activity.

b. In circumstances other than those described in paragraph (a) of this

section, a recipient should nonetheless make reasonable efforts to

meet the particularized language needs of limited-English-speaking

individuals who seek services or information from the recipient.

What That Means in Plain English Terms

a) When there are enough non-English speaking

individuals in the community, those individuals should

be able to learn about, apply for, and participate in,

your program/services - entirely in their own language

– using all the avenues you made available (such as in

person, phone, and online).

b) Even for less common languages, you must provide

services to individuals in other languages. This

includes the use of “Babel Notices” and providing

language services to known non-English speaking

customers/clients.

Summary of LEP Obligations

• The obligation to provide language services rests with the

recipient and cannot be forced on the individual customer/client;

• Communicate the availability of language services (free of

charge);

• Do not depend on family or friends of the customer/client to

provide the language services;

• Vital documents are more than just paper documents and can

include webpages, online applications, texts, tweets, and other

social media;

• Babel Notices cannot replace the obligation to provide

individualized translations (but are a good practice to

communicate the availability of LEP services).

Translator- written

Interpreter- spoken

Interpreter vs. Translator

http://go.usa.gov/fL9

Machine Translation vs. Translator

Machine Translation Translator

▪Must maintain

structure of original

meaning, keeping

ideas and facts

accurate.

▪Must transmit cultural

references, including

slang, and other

expressions that do

not translate literally.

▪Software or online

applications that

automatically

translates written

material from one

language to another

without the

involvement of a

human translator or

reviewer.

Machine Translations

How Machine Translation Works

(Google)

When Google Translate generates a translation, it looks for

patterns in hundreds of millions of documents to help decide on

the best translation for you. By detecting patterns in documents

that have already been translated by human translators, Google

Translate can make intelligent guesses as to what an appropriate

translation should be. This process of seeking patterns in large

amounts of text is called "statistical machine translation". Since

the translations are generated by machines, not all translation will

be perfect. The more human-translated documents that Google

Translate can analyze in a specific language, the better the

translation quality will be. This is why translation accuracy will

sometimes vary across languages.

See http://translate.google.com/about/intl/en_ALL/

for more

information including a video explanation

How Machine Translations May Be Accessed (Bing)

Bing Toolbar - Automatically translate any webpage instantly, using the

translation features in the new Bing toolbar.

Bing Translator - Instant translations via Bing Translator portal and

within Bing search. Bing Translator translates text and web pages

between any of the supported languages, automatically detecting the

language when needed.

Translator App for Windows Phone - Translate printed language by

simply pointing the camera, even when offline, from street signs and

posters to transit schedules and restaurant menus.

Translator App for Windows 8 - The app places powerful translation

technology at your fingertips by instantly translating content in more than

40 languages, at home, work or on-the-go.

Microsoft Translator in Office - You can translate your Microsoft Office

documents with Microsoft Translator —words, phrases, or even your

entire document, through the Research task pane.

See http://www.microsoft.com/en-us/translator/for-users.aspx

Accurate Translations?

Roundtrip Translation

SOURCE: Google Translate

Original text Machine translation

A respirator shall be

provided to each

employee when such

equipment is

necessary to protect

the health of such

employee.

These devices can

be used in the

respiratory tract if

each employee to

protect the health of

workers is

necessary.

When Not to Use Machine Translation

• To translate vital documents (including webpages)

when you do not have a trained, human translator

for that language available to review and correct

the translation and when you do not have a staff

person available to review the translation as well

• It is seldom, if ever, sufficient to

use machine translation without

having a human who is trained in

translation available to review

and correct the translation to

ensure that it is conveying the

intended message

The Proper Role of Machine Translation

• For emergency situations to

translate short sentences, always

with a human available who is

fluent in that language and trained

as a translator.

• As a tool to facilitate further

processing – such as using

machine translation of an

email so it can be forwarded

to the correct program office.

Transitioning Towards A Multilingual Site

 Assess the size and

concentration of LEP

populations

Español

中文

русский

Tiếng

Việt

 Translate information into

frequently encountered

and less frequently

encountered languages

 Ensure the accuracy of the

translated materials before

they are on your website

Transitioning Towards A Multilingual Site

 LEP individuals must

“be effectively informed

about, or able to

participate in, the

program or activity”

 Consider alternative

methods of providing

vital information to LEP

populations

http://bit.ly/TPB7Zc

Transitioning Towards A Multilingual Site

 Helpful

 In Plain English

 Accessible

www.plainlanguage.gov

 Before you translate, seek the input and advice

of LEP communities to help ensure that the

English version is:

Best Practices: Non-English Indicators

Best Practices: Use Audio and Visual

Choice of language by interactive audio map

Audio version of content in the non-English language

Best Practices: Create a Similar Experience

•Design and navigation are similar to the English version

•Content is equivalent to the English version

Note: English-only Content

Indicate if information is not yet available in English

The indicator needs to be in the non-English language

Best Practices: Use Translation Memory

Reduces cost

Provides consistency

Quicker turnaround

Easy to make revisions

Translation Memory (TM)- Database a translator uses

that captures translations for later use

http://bit.ly/1hTD9CI

Resources

 Civil Rights Center, Department of Labor

http://www.dol.gov/oasam/programs/crc/external-

compliance-assistance.htm

 Title VI and LEP Videos, http://go.usa.gov/EFi

 DOJ, Common Language Access Questions, Technical

Assistance, and Guidance for Federally Conducted and

Federally Assisted Programs, page13,

http://go.usa.gov/8htm

 GSA, 10 Best Practices for Multilingual Websites,

http://go.usa.gov/8hzB

 GSA, Automated Translation—Good Solution or Not?,

http://go.usa.gov/8hzQ