Policy Scan
The following is a report that compares the respective language access policies of San Francisco, New York City (NYC), and Toronto, with their varying degrees of specificity and strength of enforcement.

These cities were chosen for their contextual similarity to Vancouver as ethnically and linguistically diverse urban centres. What can we learn from these cities' language strategies, and how can we apply them to our own cultural context?
An Introduction
The City of Vancouver prides itself on being
“one of the most ethnically and linguistically diverse cities in Canada with 52% of the population speaking a first language other than English”
(City of Vancouver, 2022).
These population patterns are seen consistently across the entire metropolitan region.

Despite this, the lack of language access policies providing a guideline or a mandate as to how information will be made accessible in non-official languages—was especially felt over the course of the COVID-19 Pandemic. Public health updates were initially provided only in Canadian official languages in Metro Vancouver, where 44.2% of the population speaks a language other than English or French at home (Statistics Canada, 2022).

Regardless of exact compositions of the population, in community contexts as linguistically diverse as these, translation and interpretation are a necessity in public engagement. Delays in access to information result in panic, misinformation, and delayed compliance with public health and safety directives, disproportionately affecting racialized communities.
Navigating This Page for Learning
We’ve conducted an analyses of several language policies found in San Francisco, New York City, and Toronto in response to the major equity issue of language (in)accessibility in Vancouver, in order to inform policy recommendations as part of the broader Language Access Project, in both the short- and long-term.
This page is segmented into 4 major parts with an introduction on the origins of each policy belonging to each city and a conclusion section with recap of learnings. Follow along by scrolling down to read each segment or jump to the topic that interests you by navigating through the index floating on the top right-hand corner. Or download the PDF version for easier offline reading.
Policy Origins
Oftentimes, policies form as a result of a reactionary response to a need, such as: Hiring an interpreter—  after observing that not all attendees are comfortable participating at an English-speaking town hall, or Contracting a translator—  after noticing that English language forms are consistently filled out incorrectly
However, these actions only occur after the fact, after people have experienced delays in critical information or other consequences of a lack of language support.
During the pandemic, the reactionary approach to language access resulted in an inability to access financial or social resources and delayed compliance with critical public safety guidelines for some communities. Adopting principles of Language in Practice demands moving beyond a reactionary approach, to a proactive building of infrastructural resources and systems that anticipate language needs.
Though San Francisco, New York City, and Toronto each created policies as a response towards a lack of language support, they differ in that certain provisions work collaboratively to create equitable and forward-thinking approaches to language access. Additionally, there is particular strategic value in incorporating these principles across jurisdictions as well, whether provincial/state, or regional. Regional coordination acknowledges and anticipates for the fluidity of livelihoods:
Many denizens of large metropolitan areas or urban centres live in a different municipality than their place of work;
There may be a regional transportation network that crosses municipal boundaries;
Public health information delivered at a provincial level may be reiterated and/or adapted across regional health authorities.
While bylaws or guidelines may vary from one city to the next, the functional vocabulary likely remains the same. Collaborating and coordinating on practical and tangible aspects of daily life provides consistency of support not only for target audiences, but also for communications and engagement teams, leading to improved accessibility and compliance overall.
Policy Timeline
Policy work is continual that requires adjustments and updating. The following is a timeline of how each City’s Language Policy has evolved overtime.
Click on a city to view the evolution of each policy.
San Francisco
California, USA
New York City
New York, USA
Ontario, Canada
Reading Break!
Did you catch all of that?
Moving forward, we will introduce new terms and concepts to help with the flow of reading. Bolded words in blue will link you to a glossary of term definitions to help with clarity. Be sure to look at our “About” buttons (e.g. “About Terminology” below) is there to provide context and additional commentary on the highlighted policy strategies.

Okay, let’s get into it!
This section will explore methods that other cities have used to decided which languages are prioritized and for which context. Would any of these strategies work for you and your organization?
When creating a language access policy, organizations and institutions must determine the languages they will prioritize for translation and interpretation services for logistical purposes. The following section outlines the methods that San Francisco, NYC, and Toronto utilize to determine which languages are prioritized in their services.
San Francisco
California, USA
Which Languages Receive Support?
Using both US Census data and the data submitted by the Departments, San Francisco’s Office of Civic Engagement and Immigrant Affairs (OCEIA) determines which languages are to be offered in each City Department. The following details which data OCEIA uses to inform their decisions:
≥ 10,000 people; or
5% of the citywide population
Currently, the languages with the “Substantial Number” designation in San Francisco are Chinese, Spanish, and Tagalog. (2)
The Language Access Ordinance (LAO) mandates that Departments must also offer language services to a “Concentrated Number of Limited English Speaking Persons”, which can either indicate:
≥ 5% of a San Franciscan District in which the Department is located; or
≥ 5% of the population that uses a given Departmental service.
To determine this number, Departments conduct an annual language survey for a duration of at least two weeks.

The methodology is determined by each Department, though it must be reported to OCEIA in addition to the survey results and records of interactions and encounters with LEP persons.
New York City
New York, USA
Which Languages Receive Support?
Using data found in the US Census and by the Departments, NYC’s designated citywide languages are determined by the Office of the Language Services Coordinator, the Mayor’s Office of Immigrant Affairs, and the Mayor’s Office of Operations. 

At a citywide level, NYC by default offers language services in 10 different languages—more than San Francisco, though this may not be feasible for a city or organization with a smaller operating budget. NYC’s designated citywide languages are:
The top 6 LEP languages spoken in NYC (determined using US Census data); and 
The top 4 LEP languages spoken by the populations served or likely to be served by the Departments of NYC. These four languages are determined based on language data collected by the Department of Education. 
Departments are not limited to providing services in only the 10 designated citywide languages. Each Covered Department (a Department that falls under the jurisdiction of the language policy) must create an implementation plan, which includes an evaluation of the needs of their service population, in order to consider other languages that should be offered as well. Data collection that was used to support the Departments’ evaluations of needs can include but are not limited to: 
Relevant survey data;
Language data collected by the Department through intake processes (i.e. generally, forms given upon initial contact requiring personal information such as name, date of birth, address, etc.); and
Data collected by the Department regarding language access services rendered or requested
Ontario, Canada
Which Languages Receive Support?
Toronto’s language offerings depend heavily on the circumstances surrounding perceived language needs. Language support is primarily determined according to whether it is identified as Critical Information or designated for a Localized Area:
1. For Critical Information
2. For a Localized Area
Though the policy seems to account for local linguistic needs at the most minute level, the limited criteria may result in more people being excluded, left to slip through the gaps of their policy. Targeting localized areas or particular language groups may seem cost-effective at first, but it is also unrealistic for smaller linguistic groups or for groups that are spread out over wide areas. 

The policy is also heavily dependent on the opinion and assessment of the Department responsible; there are no measures included in the policy for accountability or transparency beyond reporting a rationale to the Division of Strategic Communications.
Information that is not critical nor targeted at a local area or group will be translated according to the Director’s own discretion. Information regarding the provisions for the City’s marketing information was not included for brevity.
Service Provisions
This section will show how each city manages interpretation and translation in their services.
At a high level, language services can be divided into 2 distinct categories:
Many language access policies emphasize translation work, building a glossary or a library of translated documents. A well-translated document or signage in a person’s primary language is an extension of respect and an invitation to engagement.
Although it is easier to anticipate the labour involved in translating documents, it is equally important to include interpretation work in any language access policy.

Beyond a verbatim interpretation of one language to another, interpreters ideally should be aware of the context of the encounter, any specific cultural or political implications, and the community’s linguistic history, as to interpret with respect to people’s languages, identities, values, and ideas (read more in Multilingual Staffing).

Furthermore, some community members may be unable to read in their primary language. An overemphasis on translated documents will not serve these community members. Therefore, language access policies should include interpretation work and an option for information to be presented in audio-visual formats.
San Francisco
California, USA
New York City
New York, USA
Ontario, Canada
This section explores the ways each city approaches internal translation teams and staff.
At the most basic level, language services require multilingual people to act as interpreters and translators, whether they are internal staff or vendors. A language policy may encourage a given department to hire multilingual staff or to locate multilingual volunteers. But without proper compensation, it is difficult to retain the talent required to conduct proper interpretation and translation work

Ultimately, it is important to compensate multilingual staff for their labour; institutions must demonstrate their commitment to building lasting relationships with interpreters, translators, and communities through their budget and infrastructure. Furthermore, institutions should continue soliciting feedback from those engaged in language access initiatives from all ends. Not only do translators and interpreters require feedback for their services, institutions should also seek feedback from the public to ensure that language services are accessible.

An effective language access policy incorporates these components at every level of the institutional or organizational structure, creating a network of support not only for people seeking language assistance, but also for interpreters and translators.

Select the following cities to learn about their process in employing Multilingual Staffing:
San Francisco
California, USA
New York City
New York, USA
Ontario, Canada
Structure & Accountability
How do we ensure that Language in Practice becomes a sustainable approach within our organization? A policy, despite its best intentions, may be ineffective if there is no accountability.
This section shows how the following cities have created a chain of command to keep their language policies in check.
San Francisco, NYC, and Toronto each have provisions and policies relating to language access, but differences lie in their enforcement:
San Francisco’s Language Access Ordinance (LAO) and NYC’s Local Law 30 (LL30) are both local laws and enforced as such; the roles and responsibilities of the government bodies and offices are formalized.

On the other hand, Toronto’s Multilingual Information Provisions Policy (MIPP) acts more as a guideline provided for Departments. Toronto’s only structure of enforcement is internal, where each Director is responsible for their respective Department’s language access services.
Select the Following Cities Below to Learn More:
San Francisco
California, USA
New York City
New York, USA
Ontario, Canada
Policy Recommendations
Although San Francisco, NYC, and Toronto have created language access policies, none are perfect. Policy work must be ongoing, which simultaneously requires a proactive anticipation of and a flexible response to people’s needs. Language access policies will look vastly different for every region, as each community’s needs are different. The following policy recommendations can only offer a starting point for a deeper dive into language access policy development.
01 —
Determining Languages
Strong data on language use in a given region is required in order to decide which languages to prioritize for translation and interpretation. Unfortunately, current language-use data made accessible for the public is limited, and most census data do not adequately represent the functional and day-to-day application of language skills across the spectrum of proficiency. Ideally, language proficiency data should be captured across axes of reading, speaking, writing, and comprehension. This would provide better insights into translation and interpretation needs.

To better address language barriers as an equity issue, we recommend that public institutions advocate for better data collection at a federal census level, and in the interim, build & facilitate localized surveys to assess the linguistic needs of the communities that they interact with.
02 —
Service Provision: Translations & Interpretation
Language in Practice is readily available. Front-facing services and information should take into account the multiple and compounding barriers that many equity-denied communities face. This often requires strategic coordination across communications platforms and departments to ensure seamless turnaround access to services. Language access policies should consider the following for language services:

1. Provide Multiple Methods of Disseminating Information
2. Anticipate Needs for Assistance
3.  Limit Use of Auto-Translation
4. Address Technological Barriers
5. Create Centralized Spaces & Resources
6. Think Beyond Emergency Response
03 —
Multilingual Staffing
Language in Practice should be well funded. The presences of multilingual staff will improve organization’s ability to quickly mobilize language accessibility and strategically allocate resources. As well, multilingual staff will provide invaluable knowledge on the experiences that affect their community and how to better advocate for change.

However, in order to succeed, these staff members must be provided the adequate resources from their team, support from upper-level management, and are compensated respectfully by the organization. Failing to do so would simply push these individuals into extreme burn out after being left in a tokenistic role in an under resourced department or position. Multilingual staff and staff with lived experience are not only coordinators, programmers, and assistants. They are managers, project leads, and department heads.

1. Hire Staff with Cultural & Contextual Knowledge
2. Properly Compensate Interpretation & Translation Labour
3. Implement Staff Training for Sustainable Language Work
4. Consider Staffing Allocations
04 —
Structure & Accountability
Language in Practice is responsive. Language accessibility is a commitment to the fluid nature of our communities and responding to challenges as they arise. This means keeping track of major shifts to local demographics and how this may affect the services that are provided. Transparency and accountability show communities that they have a right to understand the choices being made and that their feedback is valuable.

1. Have Complaint Forms in Multiple Formats & Languages
2. Create a System for Quick Responses to Complaints
3. Launch Surveys Regularly to Assess Language Needs
4. Use Data to Regularly Inform Language Service Plans
5. Establish a Comprehensive Reporting Structure
a term used in NYC’s Local Law 30. For purposes of readability and consistency, we have chosen to use Department as the term of reference.
Critical Information (TO)
a term used specifically in Toronto’s Multilingual Information Provisions Policy to refer to “information that will or may impact the health and safety of Toronto residents and/or communication about a long-term or sudden disruption of the City’s critical services” (MIPP, 2017, p.1).
Critical Services (TO)
a term used specifically in Toronto’s Multilingual Information Provisions Policy to refer to “City services that must be provided immediately without which, loss of life, infrastructure destruction, and/or significant loss of revenue may result. These services normally require resumption within 24 hours to ensure that the health, safety, security and economic well-being of Toronto residents is maintained” (MIPP, 2017, p.1-2).
Concentrated Number of Limited English Speaking Persons (SF)
Defined under San Francisco’s Language Access Ordinance as either:
≥ 5% of a San Franciscan District in which the Department is located; or
≥ 5% of the population that uses a given Departmental service.
an administrative division of a government that specializes in a particular area (e.g. Department in San Francisco, Agency in NYC, Division in Toronto).
Department (Covered)
a department that falls under the jurisdiction of the relevant (language access) policy or law. For language access policies, it generally means Departments that provide direct services to the public.
the person in charge of the Department (e.g. Division Head in Toronto).
a term used in Toronto’s Multilingual Information Provisions Policy. For purposes of readability and consistency, we have chosen to use Department as the term of reference.
the oral process of rendering a spoken message from one language into another.
Language Access Coordinator (NYC)
the individual(s) responsible for coordinating tasks relating to language access within individual Departments. This role is distinct from NYC’s Language Services Coordinator (defined in NYC’s Local Law 30) who oversees the performance of Covered Departments.
Language Access Ordinance (LAO) (SF)
San Francisco’s local ordinance regarding language access. It is also known as Chapter 91 of San Francisco’s Administrative Code.
Language Access Policy
a policy providing a guideline or a mandate as to how information will be made accessible in non-official languages.While a policy defines a course of action for a government, it does not hold the weight of law. A law is a rule or principle that must be adhered to by all, including organizations and institutions. Toronto’s Multilingual Information Provisions Policy (MIPP) helps to outline the intentions of the government, but it does not hold the same enforceable weight of law as San Francisco’s Language Access Ordinance (LAO) or NYC’s Local Law 30 (LL30).
Language Services Coordinator (NYC)
a role defined in NYC’s Local Law 30 that is responsible for overseeing the performance of Covered Departments as it relates to language access. This role is distinct in that Language Access Coordinators oversee language access within individual Departments, while Language Services Coordinators monitor language access across all Departments.Duties include collecting annual reports from each Department regarding their language access implementation plan; establishing criteria for providing services in langauges other than languages other than English; and maintaining a central library of translated materials accessible to the public.
Limited English Proficiency (LEP)
a designation used in American legislation across municipal, state, and federal legislatures. An LEP speaker is a self-identified individual that has difficulty communicating effectively in English, often because English is not their primary language.
Local Law 30 (LL30) (NYC)
NYC’s local law regarding language access.
Localized Area
a specific geographic area, a neighbourhood, and/or a ward or adjacent wards in the city.
Multilingual Information Provisions Policy (MIPP) (TO)
Toronto’s policy regarding language access. A policy, distinct from a law, outlines an institution’s intentions, but may not necessarily be enforced.
Office of Civic Engagement and Immigrant Affairs (OCEIA) (SF)
a Department in San Francisco that oversees areas relating to Civic Engagement, Community Safety, Grant making, Integrated Immigrant Services, and Language Access. They are tasked with monitoring compliance to the Language Access Ordinance (LAO).
Office of Immigrant Affairs (NYC)
Or also called the Mayor’s Office of Immigrant Affairs. As part of their duties relating to New York City’s Local Law 30, the Office of Immigrant Affairs advises the Mayor and city council in developing and implementing policies designed to assist immigrants and non-English language speakers in the city.
Substantial Number of Limited English Speaking Persons (Substantial Number) (SF)
defined under San Francisco’s Language Access Ordinance as either:
10,000 people or more, or
5% of the citywide population.
Currently, the languages with the “Substantial Number” designation in San Francisco are Chinese, Spanish, and Tagalog.
Telephonic Interpretation
language interpretation conducted over the phone
“the process of rendering a written document (printed or in digital form) from one language into another.”