RID has been working to develop a Criminal Conviction Policy [CCP] in response to the growing requests from consumers and government agencies serving the interests of deaf people to have a policy in place regarding a criminal background disclosure as part of the certification and recertification process. On June 17, RID released an invitation seeking comment on a proposed Criminal Conviction Policy (CCP). Some of the key aspects of the current iteration of a proposed policy are:
- The CCP will apply to both candidates for certification and recertification and is a self-disclosure. RID will not be conducting criminal background checks.
- There are three categories of criminal convictions that must be disclosed:
- Any felony conviction;
- Any conviction (felony or misdemeanor) involving moral turpitude; and/or
- Any conviction (felony or misdemeanor) related to the provision of interpreting services.
- Candidates for recertification must disclose relevant criminal convictions as part of their annual renewal. The policy is not retroactive; only convictions that happened since the last annual renewal must be disclosed.
- Candidates for certification who disclose a criminal conviction related to the provision of interpreting services will be denied credentials but may request review by an EPS adjudication panel.
- All other relevant criminal convictions will be referred to an EPS adjudication panel for review. Narratives can be submitted by impacted individuals as part of the adjudication process.
The comment period was open until 11:59 PM EST on July 15, 2016. We received 110 timely responses, which are summarized below.
We want to thank everyone who took the time to submit comments and provide thoughtful, constructive feedback. There were several common themes that emerged as areas of concern for members and underscore the need for further dialogue and consideration about the scope and administration of a CCP. As a result, we are delaying the August 1, 2016 publication date for a finalized policy.
What the themes do not reflect are the personal stories that were or have been shared as part of the overall policy development process. These stories–some from the perspective of victims, some from the perspective of individuals potentially impacted from the policy–are a critical part of the development process as they give insight into the overall impact of such a policy. Each story provided will be respectfully considered as part of the ongoing revisions.
In the coming weeks, the Board and Headquarters staff will continue to review and incorporate feedback, as appropriate, into the CCP. The feedback provided will likely lead to a more narrow policy and a more robust explanation of the implementation procedures and due process involved. We will also engage members and stakeholders in further dialogue as we move toward a finalized policy. We will continue to provide updates to you as they are available. One such update will be a more substantive article that addresses the feedback received in more detail, along with further explanation of the various aspects of policy implementation. In the meantime, you may direct questions to firstname.lastname@example.org.