EMERGENCY PREPAREDNESS PLAN AND RESPONSE POLICY

1. Purpose

Alliance for African Assistance is committed to maintaining the continuity, safety, security, and availability of its interpreter and language-access services during emergencies. This policy establishes a high-level framework for preparing for, responding to, and recovering from public health emergencies, natural disasters, man-made hazards, technology disruptions, and other events that may affect the Company’s operations or the ability of Members, clients, providers, or other stakeholders to access interpreter services.

This policy is intended to support continuity of essential language-access services while protecting confidential and sensitive information and complying with applicable federal and California laws, regulations, contractual obligations, and governmental emergency directives.

2. Scope

This policy applies to all employees, interpreters, contractors, subcontractors, vendors, and other personnel involved in providing or supporting interpreter services, including:

• Over-the-phone and video remote interpreting.
• In-person interpreting.
• Scheduling and customer/member support.
• Information technology and telecommunications.
• Quality assurance and operations.
• Subcontracted interpreter and language-access services; and
• Business functions necessary to maintain continuity of service.

3. Emergency Preparedness and Response Plan

The Company maintains an Emergency Preparedness and Response Plan that includes, at a minimum:

1. A Business Continuity Emergency Plan addressing continuity of critical business operations.
2. A Service Recipient Emergency Preparedness Plan addressing continued access to interpreter and language-access services; and
3. Policies and procedures governing emergency response, communications, staffing, technology, information security, service continuity, reporting, training, drills, and recovery.

The Emergency Preparedness and Response Plan is reviewed and updated as necessary and at least annually. Material changes to operations, technology, service delivery, applicable laws, contractual requirements, or identified risks prompt an interim review.

4. Business Continuity

The Company maintains procedures to continue critical interpreter services during an emergency. The Business Continuity Emergency Plan addresses potential disruptions involving:

• Personnel and interpreter availability.
• Telecommunications, internet, telephone, video, and other communication systems.
• Information technology and cybersecurity.
• Facilities and physical access.
• Utilities and power outages.
• Interpreter scheduling and dispatch.
• Subcontractors and vendors.
• Critical supplies and equipment.
• Customer/member communication.
• Data and records.
• Billing, and other essential administrative functions; and
• Relocation or remote-work requirements.

The Company identifies critical services and establishes reasonable recovery priorities, alternate methods of service delivery, and procedures for restoring normal operations.

5. Emergency Risk Assessment

The Company conducts an emergency preparedness risk assessment at least annually and when significant operational changes occur.

The assessment considers emergencies that could affect the Company’s service area or operations, including, as applicable:

• Pandemics and epidemics.
• Earthquakes, fires, floods, severe storms, and other natural disasters.
• Power, telecommunications, or internet outages.
• Cybersecurity and information technology incidents.
• Hazardous materials incidents.
• Workplace violence, security incidents, or intrusions.
• Evacuations or facility closures.
• Civil disturbances.
• Public health emergencies; and
• Other events that could materially disrupt interpreter services.

The Company assesses the likelihood and potential impact of identified risks and establishes reasonable mitigation and continuity measures.

6. Emergency Management Team

The Company has designated an Emergency Management Team and appropriate backup personnel responsible for implementing the Emergency Preparedness and Response Plan.

Responsibilities include:

• Activating the emergency response process.
• Assessing operational impacts.
• Coordinating staffing and interpreter resources.
• Communicating with employees, interpreters, clients, Members, providers, subcontractors, and other stakeholders.
• Coordinating with technology and telecommunications personnel.
• Protecting confidential information.
• Monitoring service availability and response times.
• Escalating significant issues to executive leadership; and
• Coordinating recovery and corrective actions.

Emergency personnel have clearly defined responsibilities and communication procedures.

7. Emergency Communications

The Company maintains a current emergency contact information for key employees, interpreters, subcontractors, vendors, clients, providers, governmental entities, and other essential parties.

Emergency contact information is reviewed and updated as changes occur and at least every six months.

The Company maintains multiple communication methods, as appropriate, such as telephone, text messaging, email, online communication platforms, and other available channels to support continuity when one method becomes unavailable.

During an emergency, communications provide timely information regarding:

• Service availability.
• Changes to operating procedures.
• Interpreter availability.
• Technology or telecommunications disruptions.
• Alternative methods for obtaining services.
• Safety instructions.
• Escalation procedures; and
• Recovery status.

8. Continuity of Interpreter Services

The Company has established procedures to provide continued access to interpreter services to the extent that is possible during an emergency.

Depending on the circumstances, continuity measures may include:

• Expanding remote or telephonic interpreting capacity.
• Transitioning in-person assignments to remote services when appropriate.
• Utilizing alternate interpreter pools or qualified subcontractors.
• Prioritizing urgent or medically necessary interpreting requests.
• Establishing alternate scheduling and dispatch procedures.
• Redirecting calls or requests to alternate service locations or systems.
• Extending operating hours when operationally feasible; and
• Coordinating with clients, providers, and other authorized entities regarding alternate service arrangements.

Emergency service modifications are implemented in a manner consistent with applicable contractual, legal, privacy, accessibility, and language-access requirements.

9. Service Recipient and Member Support

The Company maintains procedures to communicate with Members, clients, providers, and other service recipients before, during, and after an emergency.

Where applicable, emergency communication explains:

• How to request interpreter services.
• Available telephone, video, or in-person interpreting options.
• Changes to normal service procedures.
• Alternative methods for accessing services.
• How to report urgent service needs.
• How to obtain assistance when normal communication channels are unavailable; and
• How to escalate unresolved or urgent language-access needs.

The Company considers individuals with disabilities, limited activities of daily living, cognitive impairments, limited English proficiency, and other circumstances that may increase barriers to communication during an emergency.

10. Technology, Information Security, and Data Recovery

The Company maintains emergency procedures designed to protect confidential and sensitive information, including Protected Health Information (PHI), personally identifiable information, client information, interpreter information, and other protected records.

Business continuity procedures address:

• Backup and recovery of critical electronic information.
• Protection of information during remote operations.
• Alternate technology and communication systems.
• Cybersecurity incident response.
• Access controls and authentication.
• Recovery of critical applications and systems; and
• Secure handling and disposal of information.

Critical electronic information is backed up on a regular schedule. At a minimum, full backups are performed weekly and offsite backup information is updated at least monthly, unless a more stringent contractual, legal, or security requirement applies.

The Company periodically assesses restoration capabilities and maintains reasonable procedures for determining recovery priorities and estimated restoration times.

11. Staffing, Training, and Emergency Drills

The Company maintains an emergency training program for new and existing personnel.

Training address, as applicable:

• Emergency roles and responsibilities.
• Business continuity procedures.
• Emergency communications.
• Remote work and alternate operating procedures.
• Technology and cybersecurity contingencies.
• Protection of confidential information.
• Safety and evacuation procedures.
• Continuity of interpreter services; and
• Incident escalation and reporting.

The Company conducts emergency preparedness exercises or drills at least annually, as appropriate to the Company’s operations. Drill results are documented, vulnerabilities are identified, and corrective actions are assigned and tracked to completion.

Personnel who participate in governmental or client-coordinated emergency exercises when required or requested.

12. Equipment and Supplies

The Company maintains reasonable equipment, technology, communication capabilities, and supplies necessary to support continuity of interpreter services during an emergency.

Critical resources are be identified and, where appropriate, maintained at alternate locations or through redundant systems.

13. Subcontractors and Vendors

The Company evaluates critical subcontractors, interpreter vendors, technology providers, telecommunications providers, and other essential vendors for their ability to maintain services during emergencies.

Contracts or agreements with critical subcontractors and vendors where appropriate, require:

• Emergency preparedness and business continuity procedures.
• Timely notification of material disruptions.
• Maintenance of adequate staffing and resources.
• Protection of confidential information.
• Cooperation during emergency response; and
• Participation in corrective actions when service disruptions occur.

The Company maintains communication procedures for receiving and providing emergency information to critical subcontractors and vendors.

14. Coordination With Governmental and Community Resources

The Company cooperates, as applicable, with federal, State, county, and local emergency preparedness organizations and governmental authorities.

Where applicable to its contractual obligations and service area, the Company maintain appropriate emergency contact information and participate in relevant emergency preparedness activities.

The Company complies with applicable California emergency management requirements, including relevant requirements associated with California’s Standardized Emergency Management System (SEMS), when applicable to the Company’s contracted services.

15. Emergency Reporting and Escalation

The Company maintains established procedures for promptly identifying, documenting, escalating, and reporting emergency-related service disruptions.

Significant events are escalated to designated Company leadership and, when required, reported to clients, governmental agencies, contracting entities, or other authorized parties within applicable timeframes.

Emergency reports address, as applicable:

• Nature and geographic scope of the emergency.
• Operational disruptions.
• Interpreter and staffing availability.
• Technology and telecommunications status.
• Service requests and unmet needs.
• Client or Member impacts.
• Subcontractor or vendor disruptions.
• Actions taken to maintain service continuity; and
• Outstanding risks and corrective actions.

Where a contract or governmental directive establishes specific reporting requirements or timelines, those requirements govern.

16. Governmental and Contractual Emergency Directives

The Company promptly evaluates and implements applicable emergency directives, contractual requirements, regulatory guidance, and other authorized instructions issued by governmental agencies or contracting entities.

Where an emergency directive temporarily modifies normal contractual or operational requirements, the Company documents the directive, effective date, responsible personnel, implementation actions, and termination or expiration requirements.

17. Recovery and Corrective Action

Following an emergency, the Company conducts an appropriate after-action review to evaluate:

• Effectiveness of the emergency response.
• Service continuity and accessibility.
• Staffing and resource adequacy.
• Communication effectiveness.
• Technology performance.
• Vendor and subcontractor performance.
• Information security and privacy protections.
• Identified vulnerabilities; and
• Opportunities for improvement.

Corrective actions are documented, assigned to responsible parties, given reasonable completion timelines, and tracked to resolution.

Lessons learned will be incorporated into subsequent revisions of the Emergency Preparedness and Response Plan.

18. Records and Documentation

The Company maintains documentation demonstrating implementation of this policy, including as applicable:

• Emergency risk assessments.
• Emergency Preparedness and Response Plans.
• Training records.
• Drill and exercise records.
• Emergency communications.
• Incident and disruption reports.
• Corrective action plans.
• Backup and recovery documentation.
• Emergency contact lists; and
• Governmental or contractual emergency directives.

Records are maintained in accordance with applicable legal, regulatory, contractual, privacy, and records-retention requirements.

19. Policy Review

This policy is reviewed at least annually and revised as necessary to reflect changes in applicable laws, regulations, contractual requirements, Company operations, technology, identified risks, and lessons learned from emergency events or exercises.

The Company ensures that this policy and its supporting procedures remain consistent with applicable federal and California requirements and does not replace any additional emergency preparedness obligations imposed by law, regulation, contract, or governmental authority.

Last approved on 8/28/2026