Updated: May 7, 2012 R:\Translation Services Program\KCE Translation Services Program.indd
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Executive summary
Executive summary 4
Compliance with Section 203
Summary of King County Election’s compliance with Section 203 requirements ... 6
55.2 Standards for measuring compliance ... 7
55.9 Coverage of political units within a county... 7
55.15 Affected activities ... 7
55.16 Standards and proof of compliance ... 9
55.17 Targeting ... 9
55.18 Provision of minority language materials and assistance ... 9
55.19 Written materials ...11
55.20 Oral assistance and publicity ... 12
Translation and distribution of election materials
Translation and distribution of election materials ... 16Translation process ... 17
Distribution process ... 20
Voter education and outreach program
Importance of voter eduction and outreach ... 22Executive summary
Section 203 of the Voting Rights Acts was enacted in 1975 and reauthorized in 1982, 1992, and 2006. This section of the Voting Rights Act requires all covered jurisdictions to provide language support in “any registration or voting notices, forms, instructions, assistance, or other materials or information relating the electoral process, including ballots.” A jurisdiction can become a subject to this legal requirement if more than 5 percent or 10,000 of its voting age citizens are members of a single language minority group and are limited-English proficient. The illiteracy rate of such language minority citizens is higher than the national illiteracy rate.
On July 26, 2002, King County Elections recieved notification from the Department of Justice that we were subject ot the bilingual election requirements of Section 203 of the Voting Rights Act, 42 U.S.C. 1973aa-1a, with respect to Chinese Americans. On October 19, 2011, King County Elections recieved notification from the Department of Justice that we were subject to the bilingual election requirements of Section 203 of the Voting Rights Act, 42 U.S.C. 1973aa-1a, with respect to persons of Chinese and Vietnamese heritage.
In accordance with this federal law, King County produces all voting materials in Chinese and Vietnamese and employs a full-time Chinese and Vietnamese translation staff.
King County Elections is committed to taking a proactive approach to complying with the language requirements of the Voting Rights Act. Using the guidelines provided by the United States
Department of Justice, Civil Rights Division, the following components are the foundation of King County Elections Translation Services Program:
• Consistent and quality translation
• Availability of voting materials and information • Voter education and outreach
In our efforts to comply with the requirements for language assistance as mandated by Section 203 of the Voting Rights Act, we have been able to provide a variety of bilingual election services to voters who need language assistance. We will continue to respond to the needs of voters and work with the Chinese and Vietnamese communities to increase participation in the election process.
Summary of King County Election’s compliance with Section 203 requirements
Implementing Section 203 requirements is explained within the Code of Federal Regulation, 28 C.F.R. Part 55. Below is a summary of the major facets incorporated in a Section 203 compliance program and King County Elections’ activites:
28 C.F.R. Part 55 King County Elections’ activities
55.2 Standards for measuring compliance Registration or voting notices, forms, instructions, assistance, or other materials or information relating to the electoral process including ballots are provided in the covered language.
55.9 Coverage of political units Uniform language requirements are applied to all elections administered by our office.
55.15 Affected activities Registration or voting notices, forms, instructions, assistance, or other materials or information relating to the electoral process including ballots are provided in the covered language.
55.17 Targeting King County Elections produces most of the voting materials such as ballots, mail ballot packet materials, and voter pamphlets in a single language. Voters who have requested to receive election materials in the covered language only receive materials in that language. All materials provided include a notice of the availability of Chinese and Vietnamese language materials.
55.18 Provisions of minority language
materials and assistance King County employs a full-time bilingual staff. All mailed materials include a notice of the availability of Chinese and Vietnamese language materials. Voters who have requested to recieve materials in the covered language are mailed materials in that language.
Notices of election and registration information are translated.
55.19 Written materials All translated materials are proofed for accuracy, ease of comprehension, and effective structure.
55.20 Oral assistance and publicity King County employs a full-time bilingual staff. King County Elections also contracts with an interpreter service. If any of our bilingual staff are unavailable, staff can call the interpreter service and offer language assistance to customers.
55.2 Standards for measuring compliance
Implementation
• Materials and assistance should be provided in a way designed to allow members of the applicable minority language group to be effectively informed of and participate effectively in voting-connected activities.
• That an affected jurisdiction should take all reasonable steps to achieve that goal.
• The determination of what is required for compliance is the responsibility of the affected jurisdiction.
King County Elections’ compliance
As federally mandated, we provide registration or voting notices, ballots, forms, instructions, assistance, and other materials or information relating to the electoral process in the applicable language. All of these materials are proofed for accuracy, ease of comprehension, and effective structure by our in-house bilingual staff.
Our full-time bilingual staff also provide verbal assistance to Chinese and Vietnamese citizens.
55.9 Coverage of political units within a county
Implementation
Where a political subdivision (i.e., a county) is determined to be subject to Section 203, all political units that hold elections within that political subdivision (i.e., cities, school districts) are subject to the same requirements as the political subdivision.
King County Elections’ compliance
We conduct all elections held within the County and the same language requirements are applied in all elections that are administered by our office. In addition to federal, state, and county elections, King County conducts elections for more than 143 local jurisdictions.
55.15 Affected activities
Implementation
Language minority requirements apply with regard to the provision of “any registration or voting notices, forms, instructions, assistance, or other materials or information relating to the electoral process, including ballots.” The basic purpose of the Section 203 requirement is to allow members of applicable language minority groups to be effectively informed of and participate effectively in voting-connected activities. Accordingly, the quoted language should be broadly construed to apply to all stages of the electoral process, from voter registration through activities related to
conducting elections, including, for example the issuance, at any time during the year, of notifications, announcements, or other information materials concerning the opportunity to register, the deadline for voter registration, the time, places and subject matters of elections, and the absentee voting process.
King County Elections’ compliance
When developing the Translation Services Program, King County Elections determined what
materials needed to be translated to provide citizens with an opportunity to register, learn the details of the election, and cast a free and effective ballot. Below are examples of materials that we currently translate:
• Ballot
• Mail ballot packet materials (envelopes and inserts) • Email ballot packet materials (ballot and instructions)
• Online ballot for overseas and service voters (MOVE Act compliance) • Voters’ pamphlet
• Voter registration form • Voter notification card • Request for cancellation
• Accessible voting center forms and posters (accessible voting application and oath, provisional ballot envelope, your voting rights poster, identification requirements poster, vote directional signs, etc.)
• Ballot drop box decals and signs • Notices of election
• Signature challenge letters • Other letters sent to voters
• Web (online voter guide, ballot tracking, how to register to vote, accessible voting information, ballot drop box information, etc.)
55.16 Standards and proof of compliance
Implementation
A jurisdiction is more likely to active compliance with Section 203 if it has worked with the cooperation of organizations representing members of the applicable language minority group. In planning
its compliance with Section 203, a jurisdiction may, where alternative methods of compliance are available, use less costly methods if they are equivalent to more costly methods in their effectiveness. King County Elections’ compliance
We maintain a close and cooperative relationship with community organizations and collaborate with them and incorporate their recommendations in our implementation of minority language assistance when appropriate.
55.17 Targeting
Implementation
Targeting refers to a system in which the minority language materials or assistance required by Section 203 are provided to fewer than all persons or registered voters. It is the view of the Attorney General that a targeting system will normally fulfill the Act’s minority language requirements if is is designed and implemented in such a way that language minority group members who need minority language materials and assistance receive them.
King County Elections’ compliance
King County Elections provides most of the voting materials such as ballots, mail ballot packet materials, and voter pamphlets in a single language. When ballots and other materials have more than one language, we found that voters in general, have difficulty reading the materials and express confusion. All materials provided include a notice of the availability of Chinese and Vietnamese language materials.
55.18 Provision of minority language materials and assistance
Implementation
Materials provided by mail. If materials provided by mail (or by some comparable form of
distribution) generally to residents or registered voters are not all provided in the applicable minority language, the Attorney General will consider whether an effective targeting system has been
developed. For example, a separate mailing of materials in the minority language to persons who are likely to need them or to residents of neighborhoods in which such a need is likely to exist, supplemented by a notice of the availability of minority language materials in the general mailing (in English and in the applicable minority language) and by other publicity regarding the availability of such materials may be sufficient.
Public notices. The Attorney General will consider whether public notices and announcements of electoral activities are handled in a manner that provides members of the applicable language minority group an effective opportunity to be informed about electoral activities.
Registration. The Attorney General will consider whether the registration system is conducted in such a way that members of the applicable language minority group have an effective opportunity to register. One method of accomplishing this is to provide, in the applicable minority language, all notices, forms and other materials provided to potential registrants and to have only bilingual persons as registrars. Effective results may also be obtained, for example, through the use of deputy registrars who are members of the applicable language minority group and the use of decentralized places of registration, with minority language materials available at places where persons who need them are most likely to come to register.
Polling place activities. The Attorney General will consider whether polling place activities are conducted in such a way that members of the applicable language minority group have an effective opportunity to vote. One method of accomplishing this is to provide all notices, instructions, ballots, and other pertinent materials and oral assistance in the applicable minority language. If very few of the registered voters scheduled to vote at a particular polling place need minority language materials or assistance, the Attorney General will consider whether an alternative system enabling those few to cast effective ballots is available.
Publicity. The Attorney General will consider whether a covered jurisdiction has taken appropriate steps to publicize the availability of materials and assistance in the minority language. Such steps may include the display of appropriate notices, in the minority language, at voter registration offices, polling places, etc., the making of announcements over minority language radio or television stations, the publication of notices in minority language newspapers, and direct contact with language minority group organizations.
King County Elections’ compliance
Materials provided by mail. As previously stated, all voting materials provided by mail include a notice of the availability of minority language materials. In addition, voters who have elected to receive voting materials in the covered language recieve materials in that language.
Public notices. We translate notices of election, publish them in Chinese and Vietnamese newspapers, and post them on our website.
Registration. We translatio voter registration notices, forms and other registration materials. A bilingual staff person also attends all community outreach events.
Polling place activities. King County Elections votes entirely by mail. We do however have Accessible Voting Centers (AVC), which are available for voters who may have difficulty completing their mail ballot without assistance and would like to vote privately and independently. All notices, instructions, and ballots available at an AVC location are translated. In addition a bilingual staff person is works at each location.
Publicity. We include a notice regarding the availability of minority language materials on materials including the English mail ballot packets sent out to all active registered voters eligible for each election, the local voters’ pamphlet, etc. English, Chinese, and Vietnamese voting materials are also equally displayed at all Accessible Voting Centers.
55.19 Written materials
Implementation
Types of materials. It is the obligation of the jurisdiction to decide what materials must be provided in a minority language. A jurisdiction required to provide minority language materials is only required to publish in the language of the applicable language minority group materials distributed to or
provided for the use of the electorate generally. Such materials include, for example, ballots, sample ballots, informational materials, and petitions.
Accuracy, completeness. It is essential that material provided in the language of a language minority group be clear, complete and accurate. In examining whether a jurisdiction has achieved compliance with this requirement, the Attorney General will consider whether the jurisdiction has consulted with members of the applicable language minority group with respect to the translation of materials.
Ballots. The Attorney General will consider whether a jurisdiction provides the English and minority language versions on the same document. Lack of such bilingual preparation of ballots may give rise to the possibility, or to the appearance, that the secrecy of the ballot will be lost if a separate minority language ballot or voting machine is used.
Voting machines. Where voting machines that cannot mechanically accommodate a ballot in English and in the applicable minority language are used, the Attorney General will consider whether the jurisdiction provides sample ballots for use in the polling booths. Where such sample ballots are used the Attorney General will consider whether they contain a complete and accurate translation of the English ballots, and whether they contain or are accompanied by instructions in the minority language explaining the operation of the voting machine. The Attorney General will also consider whether the sample ballots are displayed so that they are clearly visible and at the same level as the machine ballot on the inside of the polling booth, whether the sample ballots are identical in layout to the machine ballots, and whether their size and typeface are the same as that appearing on the machine ballots. Where space limitations preclude affixing the translated sample ballots to the inside of polling booths, the Attorney General will consider whether language minority group voters are allowed to take the sample ballots into the voting booths.
King County Elections’ compliance
Types of materials. As previously stated, King County Elections translates materials to provide citizens with an opportunity to register to vote, learn the details of the election, and cast a free and effective ballot. Essential information that can be directly used by a voter to participate in the electoral process has been translated and made available to voters.
Accuracy, completeness. The success and effectiveness of the King County Elections Translation Services Program is based on whether the program helps voters. The translation must first and foremost be understood by those who read it. Accuracy is important as inaccuracies, errors,
ballot measures, comprehend voter pamphlet statements, and vote. Common usage and dialects need to be considered. We use the following elements to determine the quality of translation:
1. Accuracy. A translation is considered accurate when essential ideas and concepts described in English are described without any omission in the language translation.
2. Ease of comprehension. The translation must be easily understood by the reader. Clear organization and presentation of ideas and appropriate choice of words must be demonstrated. 3. Effective structure. The translation has the appropriate organization and order of interrelated
language elements that are conductive to ease of comprehension.
To build a consistent and quality translation program with the above elements, King County Elections has implemented the following:
• Language testing. King County Elections requires all potential contractors and bilingual staff to take verbal and written translation exams. These tests are graded on the three essential elements of translation: accuracy, ease of comprehension, and effective structure.
• Elections Acculturation Manual. King County Elections developed an Election Acculturation Manual containing a glossary of translation for election terms and phrases. All King County Elections staff and contractors use this manual to maintain consistency and reliability in the quality of translation from election to election and amongst staff.
• Know your audience. King County Elections staff spend time with users, observing them and listening to them. This can improve the effectiveness of the Translation Services Program. As previously noted, King County Elections employees also participate in other aspects of the election. An overall understanding of elections has improved the quality of translation as translation staff have a better idea of each document’s purpose to the voter.
Ballots. Paper ballot packets are produced in English, Chinese, and Vietnamese then sent to voters in the requested language. Electronic ballots and instructions are also produced in English, Chinese, and Vietnamese and voters are able to self-select their preferred language.
Voting machines. Our voting system can accommodate a ballots in English, Chinese, and Vietnamese.
55.20 Oral assistance and publicity
Implementation
General. Announcements, publicity, and assistance should be given in oral form to the extent needed to enable members of the applicable language minority group to participate effectively in the electoral process.
Assistance. The Attorney General will consider whether a jurisdiction has given sufficient attention to the needs of language minority group members who cannot effectively read either English or the applicable minority language and to the needs of members of language minority groups whose languages are unwritten.
Helpers. With respect to the conduct of elections, the jurisdiction will need to determine the number of helpers (i.e., persons to provide oral assistance (in the minority language) that must be provided.
In evaluating the provision of assistance, the Attorney General will consider such facts as the number of a precinct’s registered voters who are members of the applicable language minority group, the number of such persons who are not proficient in English, and the ability of a voter to be assisted by a person of his or her own choice. The basic standard is one of effectiveness.
King County Elections’ compliance
To provide verbal assistance to the language minority groups in the electoral process, we have full-time staff who are fluent in the Chinese and Vietnamese and native speakers of the language. During election time, we also hire additional language staff to assist with the translation of the local voters’ pamphlet and work at our accessible voting centers.
King County Elections also contracts with an interpreter service. If any of our translation staff are unavailable, staff can call the interpreter service and offer language assistance to customers.
Translation and distribution of election materials
Scope of election material translation
To ensure accessibility of election information for limited English proficiency voters, King County Elections provides translated voting materials in Chinese and Vietnamese. We translate essential information that can be directly used by a voter to participate in the electoral process.
The types of election materials our offices translates can be divided into five categories:
1. Registration materials. Voter registration form (paper and electronic), voter notification card, requests for cancellation, etc.
2. Voting materials. Electronic ballots (text and audio), paper ballots, mail ballot packets,
replacement ballot request forms, voting instructions for Accessible Voting Centers, ballot drop box decals, etc.
3. Election publications. Notice of election and local voters’ pamphlet.
4. Voter outreach and education. Print materials about registration and voting, such as brochures and flyers.
5. Website information. King County Election provides all information on our website in the above four categories in Chinese and Vietnamese.
Number of words translated per election
This chart details the number of words translated for primary and general elections since 2006.
Election Words translated
2011 General 114,377 2011 Primary 29,439 2010 General 88,461 2010 Primary 47,052 2009 General 146,419 2009 Primary 26,397 2008 General 81,962 2009 Primary 61,858 2007 General 69,153 2007 Primary 21,587 2006 General 6,759 2006 Primary 34,865
Translation process
The Election Operations Division is responsible for the implementation and management of the Translation Services Program for King County Elections.
King County assigns an employee to function as an election materials coordinator that is responsible for being familiar with the concepts of Design for Democracy; the design standards set by the
Department of Elections; ensuring that all election materials are translated pursuant to Section 203 of the Voting Rights Act; coordinating voter pamphlet materials for all language versions of the voters pamphlet; and having knowledge of Adobe InDesign and Acrobat Standard. The election materials coordinator is not required to read, speak, or write in an alternative language. They are responsible for coordinating the translation of materials for any language that King County Elections is currently required to produce and may be required to produce in the future.
We also have four permanent part-time translation employees; two who are fluent in reading,
speaking, and writing English and Chinese and two who are fluent in reading, speaking, and writing English and Vietnamese. Our permanent part-time employees work a unique schedule, they work 20 hours a week during the months of October – May and each person takes four months off, so we only have one person per language in the office at a time. During our peak months for translation (June through September), all language staff work 40 hours a week. We also hire approximately two - six short-term temporary employees to help edit and proof all translated materials.
In addition to translating election materials, all of our permanent staff participates in other functions such as insertion, candidate filing, accessible voting centers, etc. Participating in other areas of the election allows employees to broaden their knowledge and understanding of the election process. King County Elections also contracts with an interpreter service. If any of our translation staff are unavailable, staff can call the interpreter service and offer language assistance to customers.
Consistent and quality translation
The success and effectiveness of the King County Elections Translation Services Program is based on whether it helps voters. The translation must first and foremost be understood by those who read it. Accuracy is important as inaccuracies, errors, omissions and extraneous elements could adversely affect how voters follow instructions, understand ballot measures, comprehend voter pamphlet statements, and vote. Common usage and dialects need to be considered. To build a consistent and quality translation program with the above elements, King County Elections has implemented the following:
• Language testing. King County Elections requires all potential contractors and translation staff to take a written translation exam. All translation staff that work in our office are also required to take a verbal exam. These tests are graded on the three essential elements of translation: accuracy, ease of comprehension, and effective structure.
key elements of quality translation:
1. Accuracy
2. Ease of comprehension 3. Effective structure
• Translation memory software. In 2011, King County Elections purchased a translation memory software program. This software program helps to ensure that translated documents are consistent, including common definitions, phrasing, and terminology.
• Elections Acculturation Manual. King County Elections developed an Election Acculturation Manual containing a glossary of translation for election terms and phrases. This manual is used by all King County Elections staff and contractors to maintain consistency and reliability in the quality of translation from election to election and amongst staff.
• Know your audience. King County Elections translation staff also participate in other aspects of the election to help build a knowledge base of elections as a whole. An overall understanding of elections has improved the quality of translation as they have a better idea of each
document’s purpose to the voter. Tracking translations
One of the biggest obstacles faced by election officials when providing voting materials in additional languages is the compact election schedule. Already there are very compressed schedules for ballot building, designing voter pamphlets, etc. Developing procedures that incorporate the translation staff into the entire process and having a stringent quality control process is important.
The Election Materials Coordinator is responsible for tracking the translation of the document from beginning to end. We have developed a translation request form and a database that tracks these documents through the process. This database helps us in our work plan by estimating the amount of work pending so that we can develop staffing
plans.
Proofing process
Proofing. It is essential to develop good proofing procedures that take into account all languages, including English. It is essential that any changes made to the original English text are made in any other languages before distribution to voters and the general public. To ensure that all changes made to English documents are incorporated into additional languages, King County Elections has one person from the translation staff participate in the English proofing process. In addition, we have developed a proofing track sheet for documents such as ballots to track changes made and verify that the corrections are made to all languages.
Editing. Upon receipt of a draft translation from a contracted translator, an in-house translation employee reviews the document and compares against the English text to check for any errors in accuracy, ease of comprehension, and effective structure. After
careful review, corrections are made to the translation and then forwarded to another in-house staff person for a final review.
Final review. After a translated document has been edited, a second in-house translation employee proofreads the document before it is finalized. Once the final review is completed, the document is approved.
Distribution process
King County Elections is a vote by mail county. All voting materials are translated in both Chinese and Vietnamese and distributed to the voter based upon their language preference. Voters can request to receive voting materials in Chinese or Vietnamese by visiting our office, calling our office, or registering to vote using a Chinese or Vietnamese voter registration form.
Materials provided by mail. All mailed voting materials are sent to the voter in the language they have selected. All materials include a notice of the availability of Chinese and Vietnamese materials. Materials available electronically. Voters can view information about registration and voting on the King County Elections website. Electronic ballot materials are available for voters in both Chinese and Vietnamese.
Public notices. Notices of election are translated, published in Chinese and Vietnamese newspapers, and posted on our website.
Accessible Voting Centers. All notices, instructions, local voters’ pamphlets, and ballots available at an AVC location are translated.
Importance of voter eduction and outreach
An important component of the Translation Services Program is to educate and inform voters.
Translated materials and information have become a factor in all voter education and outreach events conducted by King County Elections.
King County Elections also works with the Chinese and Vietnamese community to educate and inform voters about voter registration, how to vote, and other election-related information. Our office relies on social service agencies, Chinese/Vietnamese business organization, activist groups within the Chinese/Vietnamese community, and media within the Chinese/Vietnamese community.
King County Elections has been recognized by the Federal Elections Assistance Commission as one of the “best practice” counties in providing language assistance to Asian Pacific American voters with limited English proficiency. King County Elections takes great strides to provide all voters with the opportunity to register, learn the details of the election, and cast a free and effective ballot.
Voter Education and Outreach
Through voter education and outreach, King County Elections can educate, listen and encourage the citizens of King County to participate in the election. It is an opportunity to register voters, answer their questions, update their voter information, explain processes, and share online tools available to them.
King County Elections does voter eduation and outreach at local fairs, festivals, corporate events and cultural events including; Bumbershoot, Umojafest, Dragon Festival in Chinatown/International District, Tet festival, Renton River Days, Naturalization ceremonies and Boeing employee events. King County Elections also coordinates and trains organizations on voter education and outreach. Some of the organizations or groups include the League of Women Voters, CIDBA (Chinese International District Business Area), University District Conversation on Homelessness, Social Security Administration – Naturalization, high school students, and others in the community.
