Language Access Policy

A. Policy

Pangea Properties (“Pangea”) is committed to providing equal opportunity housing in full compliance with all Federal, State and local laws, including all regulations governing Fair Housing and Equal Opportunity in housing. Further, Pangea will take reasonable steps to ensure that individuals with Limited English Proficiency (“LEP”) have meaningful access to apply for, rent, and reside in the properties Pangea manages. Pangea will provide translated copies of vital documents, access to interpretation services, and a clear method to request additional services. All translated documents, interpreters, and other aids provided by Pangea in compliance with this policy shall be provided without cost to the individual being served, and applicants and residents will be informed of the availability of such free assistance. All staff will be notified of this policy, and staff that may have direct contact with LEP individuals will be trained in effective communication techniques.

Pangea will conduct a regular review of the language access needs of our applicants and residents by analyzing four factors (“Four-Factor Analysis”): (1) the number and proportion of LEP individuals in Pangea’s eligible service population; (2) the frequency of contact Pangea has with LEP individuals; (3) the nature and importance of the services Pangea provides to LEP individuals; and (4) the available resources and cost to Pangea. Pangea will ensure that this policy is properly implemented and updated, as necessary.

B. Identifying LEP Individuals and Their Language

Pangea will promptly identify the language and communication needs of each LEP individual. Pangea’s application for rental housing will include a preferred language question so that LEP individuals may self-identify. Staff at each Zone Office will use a language identification card to help determine which language a LEP individual speaks. Once a LEP individual’s language has been identified, it will be updated on their Yardi resident page (or on the corresponding page of any other future property management program used by Pangea).

C. Providing Translated Copies of Vital Documents

Pangea will use relevant data provided by the U.S. Census Bureau to determine which language(s) vital documents should be translated into. Pangea will translate the appropriate documents, distribute them to Zone Offices, and store them on the Pangea Knowledge Base so that staff can easily access and print them.

Pangea will offer a Language Access Request Form that residents can use to request additional translation at no cost. Additionally, when notified, staff will submit documents for translation to the Language Access Google Group & Liaison tracker. All translated documents provided to LEP individuals will be in final, approved form with updated and accurate information. Documents will be reviewed during Pangea’s regular review of language access needs in order to ensure that any changes to the original English documents are reflected in the translated documents.

D. Providing Oral Interpretation

Pangea will create and maintain a list of bilingual staff, their phone numbers, and their availability to interpret for LEP individuals. Pangea uses Telelanguage for our translation provider and their phone number is 503-535-2178, see more information at Pangea staff must take and pass a competency test in the language in order to be qualified to provide interpretation for LEP individuals. Additionally, Pangea will select and contract with a telephonic translator service. Pangea will also use a non-emergency LEP hotline to allow LEP individuals to leave messages for Pangea in their language and have them interpreted. If a LEP individual needs interpretation, staff will contact a bilingual staff person if currently available, call the telephonic translator, or in limited circumstances, direct the LEP individual to the hotline. The decision on which method to use will be determined by availability and ease of use for the LEP individual.

If a LEP individual requests to have a family member or friend interpret, Pangea will honor this request only after making it clear that translation services are provided at no charge to the LEP individual, and the LEP individual still rejects translation services. The LEP individual’s request will be documented on their Yardi resident page (or on the corresponding page of any other future property management program used by Pangea). However, Pangea will not honor a request for a minor child to interpret for the LEP individual. In the instance of such a request, staff will use one of the above-listed methods of translation in order to ensure accurate communication.

E. Providing Notice to LEP Individuals

Pangea will inform all current residents of the availability of free of charge language assistance by sending notice by email after this policy is implemented. Pangea will inform future applicants and residents by incorporating notice of LEP services in automated application and move-in emails. Notices and signs will be posted in Zone Offices, and notice of LEP services will be included on Pangea’s website.

F. Staff Training

Pangea will notify staff after this policy is implemented. Pangea will train staff who may have direct contact with LEP individuals in meetings and through the Pangea University. Pangea will create additional training if this policy changes or if staff behavior does not comply with the policy.

G. Monitoring Language Needs and Implementation

On an ongoing basis, Pangea will assess changes in demographics, types of services or other needs that may require reevaluation of this policy and its procedures. In addition, Pangea will regularly conduct the Four-Factor Analysis, to ensure that this policy is reasonable. Pangea will access the mechanisms it uses to attain oral and written interpretation and update those mechanisms as more reasonable or more streamlined mechanisms become available. Pangea will solicit and review feedback for LEP individuals in order to update this policy to better serve their needs.