Information about translation services and technologies
Freedom of information request reference no: 01.FOI.23.033866
I note you seek access to the following information:
1. What is the size of the resident population that your organisation serves?
Response:
2. What percentage of the resident population in the area that your organisation serves are non-native English speakers?
Response:
3. Does your organisation predict that the number of non-native English speakers living in the area that you serve will increase, reduce or stay the same in the next 5 years?
Response:
4. Does your organisation hire any professional written translation or spoken interpreting services to aid communication with people who may have difficulties understanding English?
Response: [Yes/No]
5. If your organisation hires professional translation or interpreting services, for what type of material do you use these services?
(E.g., do you hire professional translation services to translate website content, correspondence, legal documents? Do you hire interpreting services for meetings, interviews, anything else?)
Response:
6. If your organisation hires professional translation or interpreting services, can you please provide figures for how much was spent by your organisation on these services and what percentage of your total expenditure this amounted to for the last 4 financial years?
Response:
Financial year Translation & interpreting expenditure % of total expenditure
2018/19: £ %
2019/20: £ %
2020/21: £ %
2021/22: £ %
7. Does your organisation predict that the percentage of spending on translation and interpreting services will increase, reduce or stay the same in the next 5 years?
Response:
8. Is machine translation (e.g. a translation app such as Google Translate) used in any way in your organisation?
Response: [Yes/No]
9. If machine translation is used in your organisation, under what circumstances is it used?
(Please specify by whom, in which context, using which tools, and the reason of use.)
Response:
10. Does your organisation follow a formal policy approving, prohibiting or regulating the use of machine translation tools in your organisation?
Response: [Yes/No]
11. If your organisation follows a formal policy for the use of machine translation, can you attach a copy of such policy to your response and/or provide a link to where it can be accessed?
Response:
12. Has your organisation carried out a risk assessment of possible consequences, for your organisation and/or for the people the organisation serves, from the use of machine translation?
Response: [Yes/No]
13. If your organisation has carried out a risk assessment of the use of machine translation, please can you specify the risks your organisation identified?
Response:
14. Do you have an established line of accountability in the event of negative outcomes that may arise from the use of machine translation?
(E.g., an incident caused by misinformation in an important document, or by miscommunication between staff and member of the public using a phone app.)
Response: [Yes/No]
15. If you have an established line of accountability, can you explain how this guides response procedures to a possible negative outcome from the use of machine translation?
Response:
16. Is any training provided on the use of machine translation in your organisation?
Response: [Yes/No]
17. If training is provided on the use of machine translation in your organisation, can you please provide an overview of the training offered?
Response:
18. Does your organisation have any other procedures in place to adjust your communication strategy for people who may have difficulties understanding English? If so, please explain.
Response:
19. If we would like to follow up with your organisation for the purpose of further research relating to translation and/or interpreting in your organisation, could you please provide the most suitable email address to contact?”
CLARIFICATION -
“In response to your question, we asked specifically for the financial years up to 2022 because it was not certain if the data for 2023 would already be available to share. However, if you do hold this information, we would appreciate it if you could please provide figures for 2022/23 as well as for the four financial years specified in Question 2.2.”
CLARIFICATION -
“With regard to the professional translation and interpreting services you hire, we would be interested to know the total combined expenditure on these services. Please can you provide the sum of internal and external translation and interpreting services in your answers.”
Please note: your questions above have been numbered to ensure clarity in our response.
Decision
I have today decided to disclose some of the requested information. Some data has been withheld as it is exempt from disclosure and therefore this response serves as a Refusal Notice under Section 17 of the Freedom of Information Act 2000 (the Act) by virtue of the following exemptions:
Section 21(1) – Information reasonably accessible by other means
Section 43(2) – Commercial Interests
Reason for decision
At your question 1 you have asked “What is the size of the resident population that your organisation serves?” I am pleased to be able to inform you that the MPS holds an estimated figure in relation to this question and this is already in the public domain. The information is published on the MPS website and can be accessed direct via the following link: Metropolitan Police - Jurisdiction
Because the information above is reasonably accessible by other means Section 21 of the Act has been applied to refuse disclosure.
Section 21(1) – Information reasonably accessible by other means - The information requested has been identified as being accessible via other means as it is already published. Where information is already in the public domain we are not required to re-publish the data; instead public authorities are required to direct you to the information, which we have done in this instance. Section 21 absolute exemption
which means there is no requirement to carry out a public interest test.
At your questions 3 and 7 you have asked us to provide predictions on the number non-native English speakers in the London area in the next 5 years, and whether our spending on translation and interpreting services will increase, reduce or stay the same in the next 5 years. Please be advised that these questions are not valid under Section 8 of the Act as they are not seeking recorded information. Section 84 of the Act defines information as being ‘information recorded in any form’. The Act therefore only extends to recorded information held by a public authority and does not extend to new information, context or opinion unless that information is already held in recorded form, which in the case of these questions, it is not.
Section 84 – Recorded information in any form - Information is defined in section 84 of the Act as 'information recorded in any form'. The Act therefore only extends to requests for recorded information. It does not require public authorities to answer questions generally; only if they already hold the answers in recorded form. The Act does not extend to requests for information or advice about legislation, policies or their implementation, or the merits or demerits of any proposal or action - unless, of course, the answer to any such request is already held in recorded form.
With reference to your question 9, Section 43 of the Act has been applied to refuse disclosure of information prejudicial to the commercial interests of public bodies.
Section 43(2) - Commercial Interests - With regard to your request, you have asked, in the event that machine translation is used in our organisation, under what circumstances it is used, and specifically, by whom, in which context, using which tools, and the reason of use.
The specific information you are seeking above would prejudice Commercial interests and for this reason section 43(2) of the Act is engaged.
It should be noted that LCS is responsible for the delivery of linguistic services within the MPS. This includes translation and interpreting services. With over 300 languages and a vast range of diverse cultural requirements, LCS supports victims, witnesses and suspects of crime by ensuring they can effectively communicate with us 24/7, 365 days a year. Given the importance of this service the details of the translation app being trialled would be of significant commercial interest to suppliers of the translation app being trialled, and to the suppliers of similar apps/tools.
Significantly, the MPS has not yet received the data results of the trial.
If the trial was successful and subsequently led to the MPS being interested in purchasing the app for live operational purposes, the release of any information at this stage would significantly disadvantage the MPS in any procurement process.
Alternatively, if the trial were to highlight deficiencies in the capability and effectiveness of the app, if it was brought into service, this would lead to both the supplier of the app we are trialling, and the MPS, being commercially disadvantaged.
To disclose the information you are seeking would prejudice the MPS’ negotiating power with suppliers in relation to future competition for any contract, not just for translation apps, but for other products and services.
If the trial were to highlight deficiencies in the capability and effectiveness of the app, if it was brought into service, this would lead to both the supplier and the MPS being commercially disadvantaged.
In addition to this, the release of the requested data could harm relationships with existing suppliers for other products and services.
The National Police Chiefs Council argues that ‘companies compete by offering something different from their rivals. The difference will often be reflected in their price and may also relate to the quality or specification of the product or service they offer’.
The release of the requested information would supply the specifics of the service offered, and provide an advantage to one company over another depending on the result of the trial.
We consider that the benefit that would result from the information being disclosed does not outweigh the considerations favouring non-disclosure.
Please see the advice and assistance section for advice under Section 16 of the Act.
Disclosure
Q2 - What percentage of the resident population in the area that your organisation serves are non-native English speakers?
No information is held by the MPS in relation to this question.
Q4 - Does your organisation hire any professional written translation or spoken interpreting services to aid communication with people who may have difficulties understanding English?
Yes.
Q5 - If your organisation hires professional translation or interpreting services, for what type of material do you use these services?
(E.g., do you hire professional translation services to translate website content, correspondence, legal documents? Do you hire interpreting services for meetings, interviews, anything else?)
An officer can request an interpreter for any part of an investigation. The most common translated material would be any written data extracted from a phone or computer, general correspondence, international letters of request (this list is not exhaustive).
Q6 - If your organisation hires professional translation or interpreting services, can you please provide figures for how much was spent by your organisation on these services and what percentage of your total expenditure this amounted to for the last 4 financial years?
| Financial year | Total spend | Percentage of total MPS spend |
| 2018-2019 | 5,038,222.00 | 0.19% |
| 2019-2020 | 6,077,893.21 | 0.22% |
| 2020-2021 | 5,898,285.51 | 0.21% |
| 2021-2022 | 6,377,567.58 | 0.22% |
| 2022-2023 | 6,471,436.14 | 0.21% |
| 2023-2024 (YTD Nov-23) | 4,942,965.66 | 0.22% Year to date to November |
Q8 - Is machine translation (e.g. a translation app such as Google Translate) used in any way in your organisation?
There is no machine translation tool in live operation within the MPS. However the MPS is just starting to explore the maturity, implications and possibility of using machine translation tools and LCS are trialling a translation app at the moment.
Q9 - If machine translation is used in your organisation, under what circumstances is it used?
(Please specify by whom, in which context, using which tools, and the reason of use.)
There is no machine translation tool in live operation within the MPS. As previously disclosed, LCS are currently trialling a translation app.
Disclosure of any further information in relation to our trial of this app would prejudice commercial interests and for this reason Section 43 of the Act has been applied to refuse disclosure of any further information. Please see ‘Reason for decision.’
Q10 - Does your organisation follow a formal policy approving, prohibiting or regulating the use of machine translation tools in your organisation?
No.
Q11 - If your organisation follows a formal policy for the use of machine translation, can you attach a copy of such policy to your response and/or provide a link to where it can be accessed?
N/A.
Q12 - Has your organisation carried out a risk assessment of possible consequences, for your organisation and/or for the people the organisation serves, from the use of machine translation?
No.
Q13 - If your organisation has carried out a risk assessment of the use of machine translation, please can you specify the risks your organisation identified?
N/A.
Q14 - Do you have an established line of accountability in the event of negative outcomes that may arise from the use of machine translation?
(E.g., an incident caused by misinformation in an important document, or by miscommunication between staff and member of the public using a phone app.)
N/A. There is no machine translation tool in live operation within the MPS.
Q15 - If you have an established line of accountability, can you explain how this guides response procedures to a possible negative outcome from the use of machine translation?
N/A
Q16 - Is any training provided on the use of machine translation in your organisation?
No.
Q17 - If training is provided on the use of machine translation in your organisation, can you please provide an overview of the training offered?
N/A.
Q18 - Does your organisation have any other procedures in place to adjust your communication strategy for people who may have difficulties understanding English? If so, please explain.
The MPS uses Language Line, an ‘app’ used by officers if an individual needs translation or if they have difficulties understanding English.
Q19 - If we would like to follow up with your organisation for the purpose of further research relating to translation and/or interpreting in your organisation, could you please provide the most suitable email address to contact?
It would be necessary to submit a new FOIA request for any further questions.
Advice and assistance
With reference to your questions 1 and 2, I have conducted a cursory search of the internet and located two websites which may be of interest to you (it should be noted that further searches could locate more relevant information). Please access these via the links below:
Number of people living in London where English is their second language
With reference to your questions 3 and 7, you may wish to consider the ICO’s guidance titled ‘How to access information from a public body’, in particular the guidance under the headings ‘How should I word my request to get the best result’ and ‘Information dos and don’ts’ which is available via the link: ICO - How to access information from a public authority.