Language Access Plan
Table of Contents
Language Access Plan
IDHR's Language Access Plan for Serving Individuals with Limited English Proficiency
I: Purpose and Authorization
The purpose of this Limited English Proficiency Plan (Plan) is to ensure the Illinois Department of Human Rights (IDHR or Department) takes reasonable steps to eliminate or reduce – to the maximum extent practicable – limited English proficiency as a barrier to accessing existing Department services, programs, and activities. Further, this Plan:
- Establishes guidelines, consistent with Title VI of the Civil Rights Act of 1964 and its implementing regulations and guidance documents, for Department staff to follow when providing services to, or interacting with, individuals who are LEP.
- Establishes the Department’s responsibility to take reasonable steps to ensure that communications between the Department and LEP individuals are not impaired as a result of limited English proficiency LEP individuals. Failure to provide timely language assistance services may result in a denial of meaningful access to Department services, programs, or activities that are accessible to non-LEP individuals.
- Affirms the Department’s commitment to eliminate or reduce - to the maximum extent practicable - limited English proficiency as a barrier to accessing the IDHR’s programs or activities.
II: Policy
Commitment to Equity
- It is the policy of the Illinois Department of Human Rights (IDHR or Department) to take reasonable steps to provide limited English proficient (LEP) individuals with meaningful access to all Department services, programs, and activities.
Language Assistance Measures
- The Department shall develop methods for identifying LEP individuals who contact the Department through correspondence (via U.S. mail, fax, e-mail, or website inquiry), telephonically or in person, and who may need language assistance.
- The Department will also develop a method of tracking LEP individuals that contact the Department. Future case management software that is currently in development will also track the language of LEP individuals.
- All contact points that an LEP individual may encounter Department staff have bilingual staff members. The Department currently has bilingual office assistants who greet individuals and answer phones. The Department has recently hired seven new bilingual investigators to supplement its current bilingual investigator pool. The Department also has bilingual legal staff; office associates and attorneys as well as Training staff that are bilingual.
- Upon determining the need for language assistance services, the Department will take reasonable steps to ensure that all communication is conducted with assistive services, including the use of a bilingual staff member, or, when necessary, in light of the content of the communication, a qualified contract interpreter or translator, or through telephonic or video interpretation with qualified interpreters.
- The Department will take reasonable steps to ensure that vital documents related to the Department’s services, programs, and activities are translated into the most frequently encountered languages of those LEP individuals affected by the services, programs, and activities or are interpreted for the LEP individual.
- The Department’s website is available in multiple languages through the use of the WeGlot tool.
- Department staff who interact with the public will be trained on language access policies and procedures, including how to access language assistance services and to identify and work with LEP individuals, interpreters, and translators.
- Department staff shall maintain a record of their contact with LEP individuals and the primary languages spoken.
- The Department’s staff will inform the public of the availability of language accessible programs and activities.
- The Department will review the Plan and related documents on an annual basis.
III: Applicability
The policies, procedures, and responsibilities of this Plan apply to all Department staff, including contractors acting on behalf of the Department.
IV: Definitions and Glossary of Terms
IV-A: Definitions
- Bilingual Staff - A staff person who has demonstrated proficiency in English and reading, writing, speaking, or understanding at least one other language. For the purposes of this Plan, a bilingual staff member is a staff member hired under a bilingual position description.
- Effective Communication - Communication sufficient to provide the LEP individual with substantially the same level of services received by individuals who are not LEP. For example, staff must take reasonable steps to ensure communication with an LEP individual is as effective as communication with English proficient individuals when providing similar programs and services.
- Interpretation - The act of listening to a communication in one language (source language) and orally converting the communication to another language (target language) while retaining the same meaning.
- Language Assistance Coordinator (LAC) - An IDHR staff member who is responsible for ensuring that the IDHR offices provide meaningful access to agency programs and services to LEP individuals within their jurisdiction.
- Language Assistance Services - Oral and written language services needed to assist LEP individuals to communicate effectively with staff, and to provide LEP individuals with meaningful access to, and an equal opportunity to participate fully in, IDHR’s services, activities, or other administered programs.
- Limited English Proficient (LEP) Individuals - Individuals who do not speak English as their primary language and who have a limited ability to read, write, speak, or understand English. LEP individuals may be competent in English for certain types of communication (e.g., speaking or understanding), but still be LEP for other purposes (e.g., reading or writing).
- Meaningful Access - Language assistance that results in accurate, timely, and effective communication at no cost to the LEP individual. For LEP individuals, meaningful access denotes access that is not significantly restricted, delayed, or inferior compared to programs or services provided to English proficient individuals.
- Primary Language - An individual's primary language is the language in which the individual most effectively communicates.
- Program or Activity - All of the operations of the IDHR.
- Translation - The replacement of written text from one language (source language) into an equivalent written text in another language (target language).
- Vital Document - Paper or electronic written material that contains information critical for accessing the IDHR's programs or activities or is required by law.
IV-B: Glossary of Acronyms
- IDHR – Illinois Department of Human Rights
- IHRA – Illinois Human Rights Act
- LAC – Language Access Coordinator
- LAWG – Language Access Working Group
- LEP – Limited English Proficiency
- PLAN – Language Access Plan
V: Language Access Plan
V-A: Determining Language Needs
- To fulfill the IDHR's obligations, the IDHR staff must understand the language needs of the populations within its jurisdiction. The development process for the Plan includes reviewing charge filing data and Census data and soliciting feedback from stakeholder groups to determine the language needs of individuals within their respective jurisdictions.
- The US Census Bureau states that from 2019-2023, 23.8% of individuals in Illinois spoke a language other than English in the home with 13.9% of people over the age of 5 speaking Spanish, 5.6% speaking other Indo-European languages, 3.09% speaking Asian and Pacific Islander languages and 1.2% who selected the category of “other” as the language spoken. IDHR has identified the following languages as the most commonly spoken languages outside of English: Spanish, Polish, Chinese and Korean.
- IDHR’s website has a function that allows an individual to “Contact IDHR” through a fillable form. The form asks for the user’s “Preferred Language”. Since the inclusion of the Preferred Language question through April 2025, IDHR received 4,764 form submissions. Of those, approximately 4% (194) of submissions noted a Preferred Language other than English, and 3.6% (175) of all submissions indicated Spanish as the preferred language. Other users selected the following languages:
- American Sign Language (4)
- Polish (4)
- Korean (2)
- Arabic (1)
- Italian (1)
- Japanese (1)
- Thai (1)
V-B. Providing Language Access
V-B-1: Identifying LEP Individuals
IDHR Staff should make every effort to identify and assess the language needs of constituents in order to best serve them. Ways in which IDHR staff can determine those needs include, but are not limited to:
- The LEP individual self-identifies either through verbal communication or on IDHR forms;
- The LEP person requests an interpreter;
- Asking professional, open-ended questions of the individual to determine the person’s ability to speak or understand English, such as, “who,” “what,” “when,” “where,” and “why” questions. Examples of these questions could be: “What kind of assistance do you need from IDHR?” and “Do you wish to file a charge of discrimination with IDHR?”
- Asking a bilingual staff person (if available) to verify an individual’s primary language. Although the use of informal interpreters, such as family members or companions of the LEP individual should be avoided, staff members may ask a family member or companion to identify the primary language.
- Once it is determined that the individual is LEP, the staff member should assess the primary language in which the individual is proficient and whether the individual requires interpretation services, translation services, or both.
- The staff member should than make a record of the individual’s primary language in the case management system and on any physical files for future reference and awareness of other IDHR staff.
V-B-2: Interpretation
Each service or activity of IDHR identified as warranting language services will arrange for timely oral language assistance to LEP individuals for in person, online, or telephone meetings. Such assistance may take the form of Bilingual Staff, oral interpreters, or telephonic language access services.
- A. Bilingual Staff - Nearly all of the LEP individuals who contact the IDHR seek to learn about their rights or to file a charge of discrimination. In some instances, LEP individuals may visit an IDHR office for this purpose. In these instances, to ensure the accuracy, quality, neutrality, and consistency of the information provided, the IDHR's preferred method of communication with LEP individuals is by using a bilingual staff member, when available. In addition to assisting LEP individuals who visit or contact an office, bilingual staff may also conduct outreach to community groups, advocacy organizations, and members of the business community who assist LEP applicants, employees, and employers, to notify them of their respective rights and responsibilities.
The IDHR recruits, interviews, and hires bilingual employees based on the applicant's ability to speak, interpret, and translate fluently, and to perform the duties and functions required by the position. As of March 2026, the IDHR had 32 employees in bilingual positions. Recently, the IDHR hired 7 more bilingual investigators to supplement its pool.
If an LEP individual speaks a language in which bilingual staff are unavailable or unable to interpret, reception staff should follow the office's procedures for securing telephonic interpretive services, as indicated below. Staff should contact the (LAC) to assist in the coordination of language services, as needed.
- B. Telephone Interpretation. The IDHR receives numerous intake calls, many from LEP individuals. Bilingual intake staff who handle these intake calls are instructed to provide interpretive services to LEP individuals directly. If the LEP individual requests interpretation and there is no bilingual staff person available or able to speak the primary language, IDHR staff will utilize Propio Language Services which provides telephonic interpretation by professional certified linguists.
- C. Exigent Circumstances. In some instances, LEP individuals may request that a friend or family member serve as an interpreter during an intake interview. As indicated above, the IDHR's preferred method of communication with an LEP individual who is seeking to file a charge is through a bilingual staff member. However, in exigent circumstances in which the deadline to file is imminent, a bilingual staff member is unavailable to assist, and staff are unable to obtain qualified interpretive services on short notice, the IDHR may allow the LEP individual’s relative or friend to serve as an interpreter during the intake interview. However, once the charge is filed, the IDHR should obtain a qualified interpreter, as necessary, for subsequent enforcement activity, such as interviewing witnesses or Respondents or conducting mediation. Note that use of a friend or family member to serve as an interpreter should be used only in exigent circumstances and is not the preferred method to provide interpretation services to LEP individuals.
V-B-3: Translation of Vital Documents
- A. To enhance communication with LEP individuals, the IDHR has translated a number of documents into languages other than English. The IDHR selected languages for translation of IDHR documents based on the language needs of the IDHR’s constituents as identified by IDHR staff and by looking at census information. The documents selected for translation are, for the most part, "vital documents" in that they provide critical information about the rights IDHR enforces, parties’ rights, charge filing requirements, and charge processing information. IDHR has also translated documents, such as, brochures, FAQ’s, and other public facing documents. IDHR will also translate responsive documents to the LEP individual.
The process for translation of documents is for the IDHR staff member to submit a request through a Google Form created for such requests. The request goes directly to the designated office associate who submits the request to the state-contracted translation services. Upon receipt of the translated document, a designated bilingual staff member reviews the document for accuracy and upon completion the office associate returns the document to the IDHR staff member. The office associate keeps a log of all translated documents.
- B. Examples of IDHR documents that may be considered "vital" include: complainant information forms, dismissal letters, substantial evidence letters, lack of substantial evidence letters, notices of rights to sue, other time-sensitive notices, settlement agreements, forms or other written material related to rights and responsibilities, emails and other communication to and from the LEP individual and notices regarding the availability of language assistance services for LEP individuals.
- C. In general, documents that could be classified as "vital" fall into two categories:
· specific communication regarding a charge, case, or matter between an individual (usually a potential Complainant or a Respondent) and the IDHR; or
· documents primarily intended for the general public or a broad audience.
- D. A list of vital documents that have been translated is available upon request.
- E. Since 2023, IDHR has published new legal guidance and key service publications, including this Language Access Plan, as web-hosted content that is immediately accessible in 7 languages and which can be reproduced on a case-by-case basis or for specific non-English users. IDHR is working toward ensuring online access to all new content it creates or produces. If it is required by statute or Administrative Rules to produce a publication in printable format or static PDF format, the Department is slowly migrating content to online format to enhance both IT and language accessibility (with printable or mailable and accessible hard-copy options for LEP individuals, stemming from the original online version). IDHR is also currently in an active project to redesign its website, along with a rebrand for IDHR, that will aggregate existing or longstanding PDF publications to a more navigable user experience.
V-B-4: Notification of Free Language Access Services
- The IDHR maintains and will continue to develop close ties to community organizations that assist immigrant groups and persons with limited English proficiency. The IDHR will notify these groups about the availability of free language assistance services.
- Where vital documents that have been translated into other languages are reprinted or updated, the IDHR will include a statement in each document about the availability of free language assistance services.
- IDHR staff will update the Department’s website to notify the public that language assistance is available at no charge, as needed. In addition, the Plan will be disseminated to relevant stakeholders, as well as to the general public, and posted on the Department’s website.
V-B-5: Language Access Complaint Process
- Any individual who believes that they have been denied or restricted access to IDHR language services or feels that they have not had meaningful access to the programs or services of IDHR due to their inability to speak, write, or understand English may file an IDHR Language Access Complaint.
- A complaint can be initiated verbally or in writing. It must be made within 180 days of the issue/situation that is the basis of the complaint. If the complaint is made verbally, the client should contact the Language Access Coordinator who will complete the IDHR Language Access Complaint Form. If the complaint is in writing, the individual should complete the IDHR Language Access Complaint Form. A copy of that form is available upon request.
IDHR staff will assist individuals in contacting the Language Access Coordinator or in obtaining and completing the form if assistance is requested. The completed form should be sent to:
Language Access Coordinator
Illinois Department of Human Rights
555 West Monroe Street, 7th Floor
Chicago, IL 60661
Or email to: IDHR.LEP@Illinois.gov
- Once a complaint has been filed, the LAC will conduct an investigation into the complaint. This may include a review of documents and interviews with individuals involved in the charge. The LAC will provide a written recommendation within 30 business days of receiving the completed complaint form. The recommendation will be in writing.
- The LAC will work with the individual and others to resolve any issues related to the individual’s access to language services and will advise the individual of the resolution.
- If the individual does not believe their complaint has been resolved with IDHR, they may elevate their complaint to gov.newamericans@illinois.gov.
V-C: Staff Guidance & Training
The IDHR will train front-line and managerial staff on the policies and procedures of working with LEP individuals as described in this Plan. Front-line staff are those employees who interact with the public on a regular basis. Key initiatives include, but are not limited to, required annual training, new employee orientation and onboarding programs. The IDHR will also draft and issue guidance and instructions to staff regarding the Plan and IDHR’s obligation to provide language assistance.
Written policies and procedures should address the following areas:
- Provision of language services;
- Identification and assessment of language needs;
- Interpretive (oral) language assistance services;
- Written translations;
- Oral and written notification of the availability of languages;
- Staff training on language service provision; and
- Monitoring access to language assistance.
V-D: Community Engagement and Outreach
The IDHR recognizes the importance of conducting outreach to and developing and maintaining relationships with LEP communities across the state. The IDHR will continue to develop cooperative relationships with federal, state, and local agencies, consulates, community-based organizations, and other interested stakeholders to coordinate outreach and enforcement on behalf of LEP individuals. The IDHR has a designated Outreach division and participates in many programs that impact LEP individuals and regularly provides information about the IDHR and language accessibility.
The IDHR website contains information for respondents on their legal responsibilities and information for constituents seeking assistance with discrimination issues. As indicated above, the IDHR’s website can be instantly translated into other languages using the built-in State of Illinois enterprise-level website translation tool (WeGlot) and, as demonatrated on this webpage, will maintain a posted a copy of this Plan.
V-E: Review and Monitoring the Plan
- Responsibility and Accountability. The Department will establish and maintain a Language Access Working Group (LAWG or Working Group) that reflects the Department’s organizational structure and whose membership is representative of Department services, programs, and activities, as appropriate. The Working Group will be responsible for implementing this Plan. The Working Group will be composed of representatives from each of the Department’s divisions and units who will monitor the implementation of the Department’s LEP Plan.
- Language Access Coordinator (LAC). The LAC is responsible for making certain that the IDHR complies with the Plan’s directives. The LAC will also ensure that questions regarding the LAP from staff members or the general public are responded to in a timely manner. The general public can submit questions via the following email: IDHR.LEP@illinois.gov. The current LAC is Deanne Medina who can be reached at (312)-814-6491.
- Language Access Working Group (LAWG). The LAWG is responsible for monitoring the Plan and ensuring LEP individuals continue to have meaningful access to IDHR services, programs, and activities. The LAWG is chaired by the LAC. The LAWG Chair, in consultation with the LAWG, is responsible for the oversight, training, performance, coordination, and implementation of all aspects of the IDHR's language assistance services to LEP individuals. The LAWG Chair will periodically brief the Director or their designee on the IDHR's activities pursuant to this plan.
- a. LAWG Membership. The LAWG Members will consist of representatives of each various division and unit within the IDHR along with the LAC.
- b. LAWG Duties:
- The LAWG meets quarterly and reviews agency programs and activities for language accessibility and implements changes as necessary to ensure that LEP individuals have meaningful access to those programs and activities.
- In its quarterly meetings, the LAWG analyzes the IDHR's current data related to language access and assesses how the information may be used to further the IDHR's efforts to ensure meaningful access to agency programs and services to LEP individuals.
- IDHR staff, in coordination with the LAWG, will review and propose updates to IDHR's public website as needed to ensure that the website includes vital information about the IDHR’s activities, including information about the IDHR’s jurisdiction and mission, information about how to file a charge, information about how to contact the IDHR, and the availability of free language assistance services.
- To ensure the continued language capability of IDHR staff, the LAWG will assess the training needs of bilingual staff and make recommendations to the IDHR’s Training Institute Director regarding how any internal training needs might be met.
- In addition to Census data, the LAWG will review charge filing data and solicit feedback from stakeholder groups to determine if members of various ethnic groups have been reached and are using the IDHR’s enforcement services.
- The LAWG will also review complaints from the public and respond, pursuant to the process outlined in the Language Access Complaint Form.
VI: Budget
The Department will ensure that its budget planning process considers language assistance services discussed in its Plan, and that adequate funds are available to carry out that plan. Execution of the commitments outlined in this Plan are dependent on IDHR resources and the relative costs associated with providing language access services. On an ongoing basis, the IDHR will explore the most cost-effective means of delivering competent and accurate language services before limiting services due to resource limitations.
VII: Conclusion
The IDHR is mindful of its responsibility to promote justice and equality of opportunity. This responsibility carries particular weight in relation to LEP individuals, who may be particularly vulnerable to discrimination and unaware of, or reluctant to take advantage of, available legal protections. The IDHR also has responsibility to assist employers, housing providers and other LEP respondents, who may not understand their responsibilities under the IHRA. Through this Plan, the IDHR continues its commitment to ensure that LEP individuals have meaningful access to the IDHR’s programs and services. The IDHR will continue to provide outreach and education, as well as technical assistance, to LEP individuals and communities. In addition, the IDHR will continue to use its enforcement authority to ensure that LEP individuals enjoy the legal rights and freedoms to which they are entitled.