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CH186-Staff Whose First Language is Not English Policy

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Staff Whose First Language is Not English Policy

1. Purpose

The purpose of this policy is to promote effective communication, equality, and safety by providing clear guidance on the recruitment, support, and development of staff whose first language is not English. At {{org_field_name}}, we value diversity in our workforce and are committed to ensuring that all staff, regardless of their linguistic background, are competent, supported, and able to deliver high-quality, person-centred care. This policy outlines how we maintain regulatory compliance, ensure service user safety, and uphold dignity through effective language support systems.

2. Scope

This policy applies to all staff working at {{org_field_name}}, including permanent, temporary, agency, and bank staff whose first language is not English. It is relevant to recruitment, induction, training, supervision, and day-to-day practice. It also guides managers in identifying and addressing language-related needs, ensuring that care delivery is not compromised by communication barriers.

3. Related Policies

4. Policy Statement and Responsibilities

Commitment to Equality and Inclusion

{{org_field_name}} is committed to promoting an inclusive working environment where linguistic diversity is respected. We acknowledge that staff whose first language is not English can offer valuable perspectives and cultural insights that enhance care delivery. However, all staff must have the level of spoken, written, reading and listening English that is necessary for their role, responsibilities and level of risk. This includes the ability to understand and follow care plans, risk assessments, safeguarding procedures, medication instructions, infection prevention and control guidance, emergency procedures, incident reporting requirements and instructions from health and social care professionals. This requirement will be applied in a fair, objective and role-specific way and will not be used to discriminate on the grounds of race, nationality, ethnic or national origin, religion, disability or any other protected characteristic. Where a communication need or language-development need is identified, {{org_field_name}} will consider appropriate support, training, supervision, reasonable adjustments and task allocation, provided this does not compromise the safety, dignity, rights or wellbeing of people using the service.

Role-Specific English Language and Communication Standards

{{org_field_name}} will identify the communication requirements of each role before recruitment and during employment. The required level of English will be proportionate to the role and the risks associated with the duties being performed. For example, staff who administer medication, complete care records, respond to emergencies, support people with consent decisions, liaise with visiting professionals, report safeguarding concerns, or work alone must be able to understand, record and communicate information accurately and promptly in English.

Managers must not assume that a person is unsuitable because English is not their first language. The assessment must focus on whether the person can safely and effectively perform the communication requirements of the role. Evidence may include interview responses, scenario-based questions, written exercises, observed practice, probation reviews, supervision records, competency assessments, care-record audits and feedback from people using the service, colleagues, families and professionals.

Staff must use English for professional records, handovers, medication documentation, incident reports, safeguarding records, communication with external professionals and any discussion where a person using the service, colleague, visitor or professional needs to understand the information being shared. Staff may use other languages where this supports a person’s care, comfort, culture or communication preferences, provided this is appropriate, agreed where necessary, accurately recorded, and does not exclude others from information they need to know.

Recruitment and Assessment

During recruitment, {{org_field_name}} will assess whether applicants have the communication skills required for the specific role. This may include interview questions, values-based scenarios, care-related vocabulary checks, written exercises, reading-comprehension tasks, medication or record-keeping scenarios, and discussion of safeguarding, consent, dignity and emergency situations. The assessment will be proportionate to the role and will be documented as part of the recruitment decision.

Where concerns are identified, the manager may request additional evidence of English language competence, such as relevant qualifications, training certificates, professional registration evidence, ESOL learning, IELTS or other recognised evidence, but this will only be requested where it is relevant and proportionate to the role. A formal English test will not be used as a blanket requirement unless it is necessary for the role, required by a professional regulator, required by immigration rules, or justified by the risks of the post.

Recruitment decisions must comply with safer recruitment requirements, Regulation 19 – Fit and Proper Persons Employed, right-to-work requirements, equality legislation, and the organisation’s recruitment policy. The service will complete and record all relevant checks before employment starts, including identity checks, right-to-work checks, references, Disclosure and Barring Service checks, employment history, qualifications, professional registration where applicable, and overseas checks where required or appropriate.

Where the applicant has been recruited internationally, {{org_field_name}} will follow the Code of Practice for the International Recruitment of Health and Social Care Personnel in England and will use only ethical and compliant recruitment routes and agencies. International recruits will receive fair employment terms, appropriate induction, pastoral support and professional support equal to other employees.

Induction and Orientation

All new staff, including those whose first language is not English, receive a thorough induction that covers:

Induction materials are delivered in accessible formats, and additional time is provided where needed to support understanding.

Probation, Shadowing and Safe Task Allocation

Staff whose first language is not English will be supported during probation through observation, shadowing, supervision and competency checks. The Registered Manager or delegated senior staff member will decide whether the staff member can safely undertake specific duties independently. This decision must be based on evidence, including observed communication, documentation quality, ability to understand instructions, ability to escalate concerns, and feedback from colleagues and people using the service.

Until competency is confirmed, the staff member must not work alone or undertake high-risk duties that require communication they have not yet demonstrated as safe and effective. This may include medication administration, lone working, completing care-plan updates, taking clinical instructions, receiving verbal orders, leading handovers, making safeguarding referrals, or communicating urgent changes in a person’s condition to external professionals.

Any restrictions, support plans or development actions must be recorded, reviewed regularly and removed when the staff member has demonstrated competence.

Communication Support and Resources

Where staff require support to improve work-related English or confidence in professional communication, {{org_field_name}} will provide or signpost to appropriate support. This may include ESOL learning, care-specific vocabulary resources, mentoring, buddying, supervised practice, additional explanation during induction, shadowing, written examples of good care records, communication templates, glossaries, reflective supervision and feedback from documentation audits.

Support must not reduce the requirement to provide safe care. Where a language or communication issue creates a risk to people using the service, the manager must complete a risk assessment, agree immediate controls, review duties, provide targeted support and monitor progress. Where safe communication cannot be achieved despite support, capability, conduct, redeployment or other employment procedures may be considered in line with HR policies and employment law.

Translation tools must not be used as a substitute for professional judgement, accurate care recording, safeguarding reporting, medication documentation or urgent clinical communication. If translation or interpreting support is required for a person using the service, this must be arranged through appropriate and confidential routes and recorded in the person’s care plan.

Supervision, Appraisal and Competency Monitoring

Communication competence will be monitored during probation, supervision, appraisal, spot checks, observations of practice, competency assessments, medication assessments where relevant, care-record audits, handover checks and feedback reviews. Managers will consider whether the staff member can safely understand instructions, communicate with people using the service, record care accurately, escalate concerns, report safeguarding issues, understand consent and mental capacity requirements, and communicate with colleagues and external professionals.

Where improvement is needed, the manager will agree a documented action plan with SMART objectives, support measures, review dates and clear expected outcomes. The plan must identify any temporary restrictions on duties required to protect people using the service. Progress must be reviewed at agreed intervals and recorded.

The Registered Manager will use information from supervision, audits, incidents, complaints, compliments, safeguarding concerns, medicine errors, handover issues and feedback to identify whether communication support is effective and whether any wider service improvement is needed.

Impact on Care Delivery and Risk Management

Language or communication difficulties must never compromise safe, dignified, effective or person-centred care. Where a staff member’s communication skills may affect their ability to carry out a task safely, the manager must assess the risk and put controls in place. Controls may include supervision, buddying, shadowing, restricting high-risk duties, additional training, reallocation of tasks, use of approved communication aids, or arranging appropriate interpreting support for the person using the service.

Staff must not be allocated to tasks that require communication competence they have not yet demonstrated. This includes, where relevant, medication administration, completion of care records, receiving or giving handovers, safeguarding reporting, consent discussions, responding to emergencies, making referrals, contacting families or advocates, and communicating with GPs, nurses, paramedics, pharmacists, social workers, commissioners or CQC.

Records must be accurate, complete, legible, dated, timed and written in English unless an agreed communication need of a person using the service requires otherwise. Any non-English communication relevant to care, consent, safeguarding, complaints or risk must be translated or summarised accurately in the care record so that staff and professionals can understand and act on it.

Person-Centred Communication

People we support must always be able to understand and be understood. If a person has communication needs (e.g., uses Makaton, interpreters, or requires simple language), we match them with staff who can meet those needs or provide appropriate support. We also ensure that the person’s right to consent (Regulation 11) and dignity (Regulation 10) is never compromised due to staff language barriers​.

Communication support must be based on each person’s assessed needs, preferences, capacity, culture, sensory needs and communication methods. This may include easy-read information, large print, pictures, communication boards, hearing support, advocacy, professional interpreters, family involvement where appropriate, Makaton, British Sign Language, translated information, or other personalised communication approaches.

Where a person wishes to communicate in a language other than English, the service will support this where reasonably practicable and safe. Staff language skills may be used to support communication only where the staff member is competent, the person agrees, confidentiality is protected, and the arrangement does not replace professional interpreting where this is required for consent, safeguarding, complaints, legal, clinical or complex decisions.

Staff must also support people to communicate with visitors, representatives, advocates and those important to them, in line with Regulation 9A on visiting and accompanying in care homes, hospitals and hospices.

Teamwork and Inclusion

We promote an inclusive and respectful workplace where all team members support one another. Cultural awareness and inclusive communication are embedded in our training programmes. Staff are encouraged to share cultural knowledge while maintaining the use of English for all professional communications and records.

Staff must not use any language, including a shared first language, in a way that excludes, intimidates, disadvantages or undermines a person using the service, colleague, visitor, professional or representative. In meetings, handovers, supervision, disciplinary discussions, safeguarding discussions, care reviews and professional conversations, the language used must enable all relevant participants to understand and contribute. Where another language is used to support a person’s care or wellbeing, the key information must be explained or recorded in English where others need to understand it for safe care.

Complaints, Concerns and Duty of Candour

People using the service, relatives, representatives, advocates, staff, visiting professionals and others may raise concerns where communication is unclear, unsafe, disrespectful, exclusionary or not person-centred. Concerns may relate to spoken communication, written records, handovers, medication communication, professional calls, safeguarding reports, consent discussions, complaints handling or staff interactions.

All concerns will be managed in line with the Complaints Policy, Safeguarding Adults Policy, Whistleblowing Policy and Duty of Candour Policy, as applicable. The service will ensure people are supported to raise concerns in a way they can understand, including through accessible information, advocacy, interpreting or other communication support.

Where a communication failure has caused, or may have caused, harm, the Registered Manager must ensure that immediate action is taken to protect people, investigate the concern, apologise where appropriate, share relevant information honestly, take learning action and make any required notifications. Learning from complaints, incidents, safeguarding concerns and feedback will be used to improve recruitment, induction, supervision, training, deployment and communication systems.

Agency, Bank and Temporary Staff

Agency, bank and temporary staff must meet the same communication standards as permanent staff for the duties they are asked to perform. The service will obtain assurance from agencies that workers supplied are suitable, competent, have completed required checks, and have the English language and communication skills necessary for the role.

Before starting a shift, agency or temporary staff must receive a local orientation that includes emergency procedures, key care-plan information, communication expectations, safeguarding reporting routes, incident reporting, medication arrangements where relevant, and how to seek help. If a communication concern is identified during a shift, the senior person on duty must take immediate action to protect people using the service and inform the Registered Manager.

Concerns about agency staff communication must be recorded, fed back to the agency, reviewed before further booking, and considered as part of governance and safe staffing oversight.

International Recruitment, Right to Work and Ethical Recruitment

Where {{org_field_name}} recruits or employs staff from outside the UK, the service will comply with current immigration, sponsorship, right-to-work and ethical recruitment requirements. This includes checking and recording the person’s right to work before employment starts, completing any required follow-up checks, ensuring the role and hours are consistent with any visa or sponsorship conditions, and maintaining records required by the Home Office and CQC.

International recruitment must follow the Code of Practice for the International Recruitment of Health and Social Care Personnel in England. The service will not knowingly use recruitment agencies or routes that breach the code, charge improper recruitment fees to candidates, actively recruit from red-list countries contrary to the code, or provide misleading information about pay, accommodation, duties, visa conditions or employment rights.

International recruits will receive appropriate induction, pastoral support, professional support, information about UK care standards, support to understand workplace rights and responsibilities, and access to English language development where needed. Support will be reviewed during probation and supervision.

Records, Confidentiality and Information Governance

Staff must maintain accurate, factual, timely and professional records in English. Records must clearly show the care provided, observations made, concerns identified, action taken, escalation completed, advice received and outcomes. Staff must not copy text they do not understand into care records, medication records, incident reports or safeguarding records.

Where a staff member requires support to improve written records, the manager must arrange supervision, examples, training and record audits. However, records must not be falsified, completed by another staff member without clear attribution, or delayed in a way that creates risk.

Confidential information must only be shared with people who have a legitimate need to know. Interpreting, translation, digital tools or colleague support must only be used in a way that protects confidentiality, dignity and data protection requirements.

Regulatory Compliance and Continuous Improvement

This policy supports compliance with the Health and Social Care Act 2008, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, CQC guidance for providers, the Equality Act 2010, employment law, data protection requirements and, where relevant, immigration and international recruitment requirements. In particular, it supports:

The Registered Manager will monitor the effectiveness of this policy through recruitment records, induction records, probation reviews, supervision and appraisal records, competency assessments, care-record audits, medication-record audits where relevant, incident analysis, safeguarding themes, complaints and compliments, feedback from people using the service and their representatives, agency staff feedback, staff surveys, and observations of practice. Findings will be reviewed through governance meetings and used to improve recruitment, training, supervision, deployment, communication systems and person-centred care.

5. Evidence of Compliance

{{org_field_name}} will retain evidence that this policy is being implemented. Evidence may include job descriptions showing role-specific communication requirements, interview notes, written assessments, recruitment checks, right-to-work records, agency assurance records, induction checklists, probation reviews, supervision notes, appraisal records, training records, competency assessments, care-record audits, medication audits, incident records, safeguarding records, complaints records, action plans, meeting minutes and feedback from people using the service.

The Registered Manager will ensure that evidence is available to demonstrate to CQC how the service assesses, supports, monitors and responds to communication-related risks while treating staff fairly and respecting equality, diversity and inclusion.

6. Policy Review

This policy will be reviewed at least annually and sooner where there are changes to legislation, CQC guidance, immigration or international recruitment requirements, safeguarding guidance, Equality Act requirements, contractual requirements, organisational needs, or learning from incidents, complaints, safeguarding concerns, audits or inspections. The Registered Manager is responsible for ensuring that staff understand this policy and that relevant managers apply it consistently, fairly and safely in recruitment, induction, supervision, deployment and performance management.

Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.

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