Language Access Plan

I. DIRECTIVES        3

Overview        3

Statement of Responsibility        3

II. FOUR FACTOR SELF ASSESSMENT        4

Factor One: Population        4

Factor Two: Frequency        4

Potential Visits        4

Use of Interpretation        5

Non-English Circulation        5

Web Traffic        5

Factor Three: Importance        5

Factor Four: Resources        5

Third Party Interpretation Support        5

Certified Multilingual Staff        6

Translation Support        6

III. IMPLEMENTATION PLAN        6

Plan Administration        6

Written Translation        7

Interpretation Services        7

Staff Training and Resources        7

Signage and Communication        7

Community Engagement and Outreach        7

Budget and Evaluation        8

IV. PROTOCOLS AND PROCEDURES        8

Multilingual Staff        8

Identifying Language Support Needs        8

Identifying Language        9

Vital Documents        9

Sight Translation        9

Event Support        10

Data Collection, Monitoring, and Evaluation        10

Complaint Process        10

APPENDIX A: FOUR FACTOR ANALYSIS DATA        11

TABLE A        11

TABLE B        12

TABLE C        12

TABLE D        13

TABLE E        13

TABLE F        15

TABLE G        15

APPENDIX B: TERMS AND DEFINITIONS        16

APPENDIX C: VENDOR PRICING DETAILS        17

TABLE A        17

TABLE B        17

TABLE C        17

TABLE D        17

I. DIRECTIVES

Overview

The City and County of Denver (“Denver/CCD”), through its Denver Public Library (“the Library/DPL”) is committed to ensuring meaningful citywide access to public facing services and programs for individuals who have limited English proficiency (LEP) or are deaf and/or hard of hearing.  

Denver Public Library is the largest public library system in the Rocky Mountain West serving the entire Denver metropolitan area. Our mission is to create welcoming spaces where all are free to explore and connect.

With this Language Access Plan, we commit to establishing effective procedures and protocol for public services and communication to all individuals regardless of their primary language in alignment with our mission, as well as applicable federal and local laws, rules, and regulations including but not limited to:

• City and County of Denver Executive Order NO. 150
• City and County of Denver Comprehensive Plan 2040
• Title VI, U.S. Civil Rights Act of 1964
• Executive Order 13166
• Americans with Disabilities Act Title II (for state and local governments)
• Americans with Disabilities Act Title III (for businesses and public nonprofits)

As an independent agency, the Library is committed to providing citywide language support that aligns with our mission and strategic objectives while also collaborating with the City and County of Denver’s Language Access Program.

Statement of Responsibility  

It is the responsibility of Denver Public Library, and not any individual seeking language support, to:

• provide equitable language appropriate services to all library users
• prohibit the use of minor children as interpreters/translators
• discourage the use of family members, friends, or other informal parties as interpreters or translators unless explicitly requested by the individual or in an urgent situation when no other language services are available, in alignment with Denver’s Executive Order 150
• require staff at initial point of contact to make reasonable efforts to identify individuals in need of language support and determine their primary language
• provide certified multilingual staff who may assist customers in their primary language or connect individuals with professional interpreters when staff cannot meet language needs
• recognize circumstances for specialized interpretation and translation (i.e. HIPAA, confidentiality)
• develop policies and processes that integrate language access into standard operations so that all individuals are treated with respect and dignity

II. FOUR FACTOR SELF ASSESSMENT

Title VI and the IMLS implementing regulations require the Library to take reasonable steps to ensure meaningful access to its programs, services, and activities.^[1] To determine the appropriate balance of language services required for meaningful access, the Library conducted a preliminary four factor analysis, in accordance with guidance set forth by the U.S. Department of Justice (DOJ):

Factor One: Population

Denver Public Library serves the entire City and County of Denver (CCD) and anyone who visits or interacts with its 27 branch locations and three traveling bookmobiles.  However, language support for Library services is especially critical in neighborhoods with higher populations of persons with LEP.

Table A summarizes DOIRA’s CCD demographic analysis identifying 12 languages (including American Sign Language) that meet thresholds for vital document translation and six additional   languages with significant LEP populations in Denver based upon data provided by the Denver Office of Immigrant and Refugee Affairs (DOIRA).^[2] 

Factor Two: Frequency

How often persons with LEP are likely to interact with Library services determines the need for language support. The library is dedicated to providing welcoming spaces where individuals of all backgrounds can access services with complete privacy and confidentiality, in alignment with the American Library Association Bill of Rights.

To protect the personally identifiable information of all individuals who access Library services, estimates of the frequency and manner of access have been made using potential visits, use of interpretation services, the circulation of non-English materials, and website traffic. While the following data does not provide a holistic view of the frequency with which library customers with LEP meaningfully access materials, it does provide us with a baseline for predicting the frequency and manner of access for individuals with LEP.

Potential Visits

According to the American Community Survey, ^[3] 9.5% of Denver residents have LEP.  Table B offers estimates for potential visits for individuals with LEP were created by assuming 9.5% of verified door counts at each branch location.

Use of Interpretation

The Library offers telephonic interpretation as well as American Sign Language (ASL)/Communication Access Real-time Transcription (CART) in partnership with CCD. Table C reflects the usage of these centralized interpretation services.

Non-English Circulation

From January 2021 to August 2023, Library customers checked out a total of 77,474 world language materials across six non-English languages. Table D provides the total number of checkouts for each language collection.  

Web Traffic

The Library used webmaster analytics to assess the frequency with which customers have viewed three primary access points on Denverlibrary.org: the Library homepage, the ‘Get a Library Card’ page, and the 24/7 ‘Ask Us’ page. All content on the Library's website (Denverlibrary.org) is also currently accessible in Vietnamese, Spanish, and English.

Table E presents the number of page views for each primary access point, by languages currently available.

Factor Three: Importance

Denver Public Library offers a variety of programs and services, both in person and online, to meet the diverse needs and interests of the community. Important library services may include but are not limited to Community Resources and Peer Navigation, Computers and Technology, Appointment Services, and Library Card Registration.

In addition, when information, services, or interactions may have a significant impact on the livelihood, welfare, policies, and rights of a library customer, language support is also considered essential. 

Factor Four: Resources

Current budget and resources are sufficient to offer translation and on demand interpretation to any Library customer upon request, at no cost to the individual.

Third Party Interpretation Support

Verbal interpretation services are made available through a third party vendor via on demand telephonic interpretation for individuals with LEP in over 200 languages at no cost to the individual.

Nonverbal language assistance in the form of American Sign Language (ASL) interpretation or Communication Access Realtime Translation (CART) is available upon request through the Denver Office of Deaf & Hard of Hearing Services at  deafhhservices@denvergov.org, 720-913-8487.

Certified Multilingual Staff

Multilingual Library staff whose current role does not require but benefits from the use of a non-English language may be eligible for certification resulting in a pay stipend through the City and County of Denver’s Office of Human Resources (OHR).

Table F reflects the totals for OHR certified multilingual library staff members as of August 2023.

Translation Support

The Library employs a systematic approach to manage translation operations across the organization and uphold quality standards. A full time Language Coordinator oversees the translation quality assurance and workflow with a translation platform that uses machine translation, Computer Aided Translation (CAT), and human translation in over 280 languages with a marketplace of certified linguists. The Language Coordinator may also work with an internal translation review team with members who support non-English written communication in pre and post edits for translated materials to ensure localization, cultural relevance, and consistency with brand standards.

As of August 2023, the Library has processed 260 translation requests in at least 14 languages. Additional annual translation totals are provided in Table G.

III. IMPLEMENTATION PLAN

Plan Administration

The Denver Public Library employs a permanent, full time Language Access Administrator (Languageaccess@denverlibrary.org, 720-384-4221) to coordinate the implementation and evaluation of this plan while serving as a liaison for staff, stakeholders, and community members. The Administrator also established a diverse team of internal stakeholders throughout the organization representing the following teams and departments:

• Collection Services
• Cultural Inclusivity
• Equity, Diversity, and Inclusion & Engagement
• Facilities
• Grant & Resource Development
• Information Technology
• Marketing
• Neighborhood Services
• Strategy & Evaluation

As the primary point of contact for this plan, the Language Access Administrator reports to the Marketing Manager of the Communications and Community Engagement sub-division.

Written Translation

Denver Public Library will prioritize, collect, translate, and update written forms and documents based on their support of core library services including:

1. Library card registration and usage
2. Language specific collection signage/services
3. Primary materials generated in support of technology/collections (i.e. research aids, tech help materials)
4. Official Documents (i.e. policies)

The Library's Vital Documents procedure will be applied to ensure vital documents are translated into Denver’s top 12 languages: Amharic, Arabic, Burmese, Chinese (simplified), Farsi, French, Karen, Nepali, Russian, Spanish, and Vietnamese. Written notices of the right to receive free language support will also be available in Korean, Urdu, Haitian, Khmer, Armenian, and Swahili.

Interpretation Services

The Library regularly interacts with individuals in person, by phone, and online via email and live chat. Third party interpretation services will be made available at no cost to the individual by following the Library's established language support procedures.

Staff Training and Resources

All Denver Public Library staff will be trained on language access policies and procedures. All Library staff who regularly have direct and substantial interactions with the public will receive additional technical training in support of this plan, supporting procedures, and available resources.

Signage and Communication

Notification of available language support will be visible at library service desks and will be included on the Library's official website (denverlibrary.org). Denver Public Library may also collaborate with community organizations and stakeholders to share the availability of language support throughout the City and County of Denver. Communication methods may include but are not limited to “I Speak…” materials used to help individuals express their language needs by visually identifying their primary language.

Community Engagement and Outreach

Denver Public Library is also committed to providing culturally relevant language support to actively build and maintain relationships with local language communities, organizations, and media.

By sharing information, knowledge, and insight with community organizations and nonprofits the Library will seek to ensure that valuable services and information are accessible to all.

Budget and Evaluation

The Marketing department will initially fund all centralized language support services until usage exceeds the current budget. Annual evaluations will assist with requests for additional funding based on usage. Appendix C details the third party costs associated with translation and interpretation services.

IV. PROTOCOLS AND PROCEDURES

Upon arriving at any DPL location, customers in need of language support must be identified and supported with interpretation services and translation of vital documents. To ensure that all Library customers have equal access to information and services regardless of primary language, staff must not discourage or refuse services to any customer, especially those in need of language support.

Multilingual Staff

Certified multilingual staff who work directly with the public may provide informal, in language support and help bridge language gaps while connecting customers to formal language supports. Multilingual staff may only use their certification for verbal service interactions within the scope of their job duties and not for translating written material. Library staff are prohibited from using children under the age of 18 as interpreters or translators.

Identifying Language Support Needs

Language proficiency varies by context, circumstance, and communication type (i.e. verbal, written). Staff should avoid making assumptions about a customer’s primary language, support needs, or ability to read. Someone may be in need of language support if they:

• request an interpreter
• have significant trouble fully understanding/participating in English;
• self identify or is identified by a companion;
• use available visual aids/documents to indicate their need;
• are identified by multilingual staff or professional interpreter;
• use hand gestures to communicate

Identifying Language

To determine someone’s primary language, staff may use:

• “I Speak”/language identification cards

• Note: Not every spoken language has a written form

• Posted signage/notices
• [1-833-737-2379] for direct or 3- way calls

• Dial 0 to speak to an agent who can assist you

Once a need for language support is identified along with the primary language needed, staff may offer any of the following third party services:  

• Telephone Interpretation
• In person Interpretation

Vital Documents

The Language Access Administrator will maintain a Vital Document Inventory in collaboration with program/service leads and managers throughout the organization. The inventory will track documents identified as vital as well as translation need/status.

Community requests to translate additional vital documents or other essential written communication should be submitted to the Marketing Department at languageaccess@denverlibrary.org.

Sight Translation

If an important written communication has not been translated into a customer’s primary language, or if the customer is unable to read, staff should arrange for sight translation. Sight translation involves reading written material and immediately interpreting it into another language. Library staff may facilitate sight translation by contacting LanguageLine and reading the document aloud while the interpreter provides the information in the customer’s language.  

Form Processing

If a customer in need of language support also needs to complete a library form, staff may assist the customer in completing the form through the following procedure:

1. Confirm the customer’s language.
2. Obtain an English version of the form.
3. Call LanguageLine and state the language needed.
4. State that the purpose of your call is to sight translate a form that you will be helping the customer complete.
5. Read the document to the interpreter, pausing after each field to allow for interpretation.
6. Listen to the English interpretation and record the customer’s information in English on the form.

1. Be sure to note the customer’s primary language on the form (Sight Translation, Date, Language)

7. Once the form is complete, reread the transcribed English information with the interpreter and the customer to confirm accuracy.

Event Support

In addition to on demand services, staff may request in person interpretation services for events based on the nature, format, communication requirements, and potential impact on a person’s life or livelihood.

Data Collection, Monitoring, and Evaluation

The Language Access Administrator will coordinate data collection and management with the Strategy & Evaluation department. The overall effectiveness of this plan will be evaluated and published each year in alignment with annual goal setting/progress regarding systemwide interpretation and translation support; data collected, types and frequency of support, summary of staff training, complaints/resolutions, and the process for gathering community feedback.

The Library will conduct an annual evaluation of this Plan to assess its overall effectiveness and identify emerging language access needs or gaps in service. The Language Access Administrator will coordinate data collection, analysis, and reporting with the Strategy & Evaluation department. Evaluation criteria and methods will align with Language Access implementation goals regarding systemwide interpretation and translation support; data collected, types and frequency of support, staff training, complaints/resolutions, and the process for gathering community feedback. Annual evaluation will also include a review of the four factor self assessment to inform any necessary updates.

Complaint Process

The Library empowers residents to provide feedback on gaps in service, noncompliance with local and federal statutes, and/or other barriers to high quality, customer centered service.  

Library customers who believe they have been excluded from, denied the benefits of, or otherwise subjected to discrimination because of their language may file a Title VI complaint with the City and County of Denver.

Complaints for federally funded programs may also be submitted to the U.S. Department of Justice in any of the following ways:

• Email FCS.CRT@usdoj.gov
• Call the Title VI Hotline at 1-888-TITLE-06 (Voice/TDD)
• Submit a report online through the Civil Rights Division Portal
• Visit the Federal Coordination and Compliance Website 

For general questions about Denver Public Library’s Language Access Plan, contact languageaccess@denverlibrary.org.

APPENDIX A: FOUR FACTOR ANALYSIS DATA

TABLE A

TABLE B

TABLE C

TABLE D

*includes Bookmobiles and Interlibrary Loan

Note: Circulation has been impacted by COVID-19 closures and recovery as well as bond renovations and will continue to be monitored as library hours, programs and services continue to stabilize.

TABLE E

TABLE F

TABLE G

APPENDIX B: TERMS AND DEFINITIONS

Bi/Multilingual Staff: An employee who has proficiency in English and demonstrated the ability to read, write, or speak in at least one other language.  

Customer: any person who interacts with, or may interact with the Library.

Customer in need of language support: A person  whose primary language is one other than English i.e. sign language, CART

Essential Library Services: Information, interactions, or services that may have a significant impact on the livelihood, welfare, policies, and rights of a Library customer.

In Language: Direct communication in a language other than English between multilingual staff and a person in need of language support, e.g., a certified multilingual employee supporting a customer in their preferred language.

Interpretation: Converting a spoken or signed message from one language into another without changing its original meaning.

Language Support: Oral, written, and nonverbal language services required for an individual to communicate effectively with the Library and have equal access to, and participation in essential services, offerings, and events.

Language Access Plan: a management document that outlines how an organization will offer accurate, timely, and effective language assistance and comply with federal standards.

Language Access: the legally protected civil right to access information, programs, and services equitably, regardless of primary language; It is the process of removing language barriers.

Limited English Proficiency (LEP): a legal term used by the government to describe a person who:

• Does not speak English as their native language
• has a limited ability to read, speak, write, or understand English.

The Library uses the inclusive, people first term “customers in need of language support” instead of ""LEP"". This includes individuals who are deaf or hard of hearing and use sign language or other auxiliary aids and services to communicate effectively. The term "LEP" is used in the four factor analysis to align with federal standards/guidance.

Meaningful Access: the provision of language support resulting in accurate, timely, and effective communication available at no cost to the individual.

Primary Language: The language a person can communicate most effectively in.

Translation: Converting written communication from one language into another without changing its original meaning.

Vital Documents: Paper or electronic written material containing information that is required for meaningful access to essential services.

APPENDIX C: VENDOR PRICING DETAILS

TABLE A

TABLE B

TABLE C

TABLE D