Tēnā koutou,

I am requesting the following information under the Official Information Act 1982 relating to subcontracting practices, NAATI credential compliance, and interpreter pay arrangements within translation and interpreting services procured by or through the Department of Internal Affairs (DIA).

SECTION A: SUBCONTRACTING ARRANGEMENTS

1. Whether DIA's Translation Service or any external translation or interpreting providers contracted to DIA are permitted to subcontract assignments to third parties, including overseas-based agencies or individual contractors located outside New Zealand.

2. Any conditions or restrictions in DIA's contracts with translation or interpreting providers regarding the use of subcontractors, including any requirements that subcontractors be based in New Zealand or hold an appropriate New Zealand work visa.

3. Whether DIA requires providers to disclose the identity, location, or credentials of individual translators or interpreters — including subcontractors — who carry out assignments on DIA's behalf.

4. Whether DIA has any knowledge of, or has sought information about, assignments being routed to interpreters or translators located outside New Zealand.

5. Any instances where DIA became aware that an assignment was conducted by a person located outside New Zealand or by an uncredentialled subcontractor, and any action taken as a result.

SECTION B: NAATI CREDENTIAL COMPLIANCE

6. What mechanism, if any, DIA uses to verify that individual translators and interpreters carrying out assignments on its behalf — including those engaged through subcontracting arrangements — hold a valid NAATI credential or Working Towards NAATI (WTN) status.

7. Whether DIA requires its translation or interpreting providers to maintain and supply a current register of credentialled practitioners working under DIA contracts, and if so whether DIA has received and reviewed such registers.

8. Any audits, spot checks, or compliance reviews conducted by DIA on its translation or interpreting providers since 1 July 2024 to verify NAATI credential compliance, including the methodology and findings of any such reviews.

9. Any instances since 1 July 2024 where a provider was found to have used a translator or interpreter who did not hold the required NAATI credential or Working Towards NAATI (WTN) status, and any consequences or remedial action taken.

10. Any complaints received by DIA since 1 July 2024 from staff, clients, or members of the public regarding the qualifications or conduct of a translator or interpreter engaged through DIA's services.

SECTION C: INTERPRETER AND TRANSLATOR PAY VISIBILITY

11. Whether DIA has any information about the rates or fees paid by its external providers to individual translators or interpreters for assignments conducted on DIA's behalf.

12. Whether DIA has ever sought, as part of contract negotiations, tendering processes, or performance reviews, any information about the pay or working conditions of translators or interpreters engaged through its provider contracts.

13. Any internal policies, briefings, risk assessments, or correspondence within DIA regarding the fair remuneration or employment conditions of translators and interpreters working under its contracts, including any concerns raised about the margin between rates paid to providers and rates passed on to practitioners.

14. Whether DIA's tendering or procurement criteria for translation and interpreting services include any consideration of whether providers pay practitioners at or above a minimum rate, living wage, or industry standard.

If any part of this request is refused, please:
- Identify the specific OIA provision relied upon for each withholding;
- Consider whether the public interest in transparency around publicly funded services and the fair treatment of workers outweighs any commercial sensitivity; and
- Release any information that can be made available in redacted or aggregated form.

I am happy to receive this information in electronic format.

Ngā mihi