ISO 17100 Clause 3 Resources: Competence Records and Infrastructure Requirements

Why Clause 3 Is the Backbone of ISO 17100 Compliance

If you have read through ISO 17100 and found yourself spending the most time in Clause 3, you are not alone. This is the clause that defines what a translation service provider must actually have in place before a single word gets translated. It covers the human resources, the technical infrastructure, and the documented evidence that ties them together. For auditors, it is one of the richest areas to examine. For providers, it is one of the hardest to maintain consistently.

ISO 17100 Clause 3 resources requirements sit at the heart of the standard because translation quality depends almost entirely on the people doing the work and the tools they use. Unlike manufacturing standards where you can inspect a physical product, in translation services the process and the people are the product. Get Clause 3 wrong and everything downstream in Clauses 4, 5 and 6 becomes unreliable.

This article walks through what Clause 3 actually requires, what auditors look for when they examine it, and where providers consistently fall short.

The Structure of Clause 3: Human Resources and Technical Resources

Clause 3 divides into two broad areas. The first covers human resources, meaning the translators, revisers, reviewers, project managers and any other personnel involved in the translation workflow. The second covers technical resources, meaning the tools, software, terminology databases, reference materials and infrastructure that support the work.

Both areas carry specific requirements. The standard does not allow providers to simply assert that their people are competent or that their tools are adequate. Evidence is required, and that evidence must be documented, maintained and available for review.

Who Counts as a Human Resource Under Clause 3?

ISO 17100 identifies several roles that must meet defined competence requirements. These include translators, revisers, reviewers, project managers, and in some cases specialists in subject matter or terminology. Each role carries its own competence criteria, and the standard is explicit that not just anyone can fill these roles.

Translators must meet one of the qualification pathways defined in the standard. The 2015 edition and the 2017 amendment describe three recognised pathways, covering formal translation qualifications, combinations of language and subject matter qualifications, and demonstrated professional experience. The provider must be able to show which pathway each translator meets and provide documented evidence to support it.

Revisers must be competent in both the source and target language and must have translation competence in the relevant field. This is a specific requirement that many providers struggle with. It is not enough to assign a bilingual employee or a junior team member to the revision role. The reviser must meet the same calibre of qualification as the translator, and the provider must be able to demonstrate this.

Reviewers, where used, must have the subject matter expertise relevant to the content being reviewed. Project managers must have the competence to manage the workflow, coordinate resources, communicate with clients, and oversee quality. The standard does not prescribe specific qualifications for project managers, but it does require that their competence be defined and assessed.

Competence Records: What the Standard Actually Requires

This is where many providers fall short. ISO 17100 requires that providers maintain documented information about the competence of every person involved in the translation workflow. This is not a one-time exercise. Records must be current, accurate and retrievable.

What Goes Into a Competence Record?

A compliant competence record for a translator typically includes copies of relevant qualifications, evidence of language combinations, subject matter specialisations, professional experience, and any continuing professional development. For revisers, the record must also demonstrate competence in revision itself, not just translation.

The standard requires that competence be assessed, not just assumed. Providers who simply collect CVs and consider the matter closed will find themselves with a nonconformity. The assessment process must be defined, applied consistently, and documented. This might involve a trial translation, a review of past work quality, references from previous clients, or a structured evaluation against defined criteria.

In practice, auditors will ask to see the competence records for the translators who worked on recent projects and then trace those records back to the projects themselves. If a provider assigns a translator to a legal translation and that translator has no documented legal specialisation, that is a finding. If the competence record exists but has not been updated in three years despite the translator completing additional qualifications, that is also a finding.

The Freelancer Problem

Many translation service providers rely heavily on freelance translators rather than in-house staff. ISO 17100 accommodates this, but it does not reduce the requirements. The provider is responsible for ensuring that every translator they use, whether employed or contracted, meets the competence requirements of the standard.

This means the provider must have a process for assessing and documenting the competence of their freelance pool. Simply having a signed contract with a freelancer is not sufficient. The provider needs to hold the same quality of competence evidence for freelancers as for employees. Auditors will check this. A provider who has excellent records for their three in-house translators but patchy records for their fifty freelancers has a significant gap.

For more on what auditors look for when examining competence records under ISO standards, the article on auditing competence and training records provides practical guidance that applies directly to this area.

Technical Resources: Infrastructure That Supports Quality

Clause 3 also addresses the technical resources that a provider must have in place. This includes translation memory tools, terminology management systems, machine translation post-editing tools where applicable, reference materials, style guides, glossaries and any other technology used in the production process.

What the Standard Expects From Technical Infrastructure

ISO 17100 does not mandate specific software or tools. It does not require that providers use any particular translation memory platform or terminology database. What it does require is that the provider has access to appropriate technical resources for the work they undertake, and that those resources are maintained and used consistently.

If a provider lists translation memory software as part of their quality process, auditors will want to see evidence that it is actually being used. If a client-specific glossary exists, auditors will check whether translators have access to it and whether it is being applied. If a style guide has been developed for a particular client, the provider must demonstrate that it is integrated into the workflow, not sitting in a folder somewhere.

The connection between technical resources and documented information is important here. Providers must be able to show that their technical infrastructure is fit for purpose and that it is being used as described in their quality management documentation. Gaps between what the quality manual says and what actually happens in production are a common source of nonconformities under Clause 3.

Terminology Management

Terminology is a specific area of focus within technical resources. ISO 17100 expects providers to have processes for managing terminology, whether that involves client-supplied glossaries, internally developed term bases, or publicly available resources. The key requirement is that terminology management is systematic, not ad hoc.

In practice, this means the provider should have a defined process for receiving, storing, updating and applying terminology resources. If a client provides a glossary, there must be a process for making it available to the relevant translators and ensuring it is used. If the provider develops terminology during a project, there must be a process for capturing and maintaining it.

Auditors will often ask translators directly whether they have access to the relevant terminology resources for a project and whether they know where to find them. Responses that reveal confusion or inconsistency about how terminology is managed will prompt deeper investigation.

How Auditors Examine Clause 3 in Practice

When auditing against Clause 3, the approach is to follow the evidence. You start with a sample of recent translation projects and then work backwards through the resources used.

Sampling Translator Records Against Projects

Select three or four recent projects that cover different language combinations and subject matter areas. For each project, identify who performed the translation and who performed the revision. Then pull the competence records for each of those individuals.

Check that the translator's documented language combination matches the project. Check that their subject matter specialisation is relevant to the content. Check that the reviser meets the competence requirements for revision, not just translation. Check that the records are current and that any assessment process has been completed and documented.

If the provider uses a roster or database of approved translators and revisers, examine how entries are added to that roster. What assessment process is used? Who approves new entries? How often are records reviewed? These questions reveal whether the competence management process is genuine or cosmetic.

Checking Technical Resource Documentation

Ask to see the technical resources that were used for the sampled projects. Were translation memories applied? Were client glossaries available? Were style guides followed? Ask the project manager to walk you through how a typical project is set up in their system and how resources are made available to translators.

Look for consistency between what the quality management documentation describes and what actually happens. If the documentation says that translation memories are always applied but the project manager reveals that this depends on the translator's preference, that is a gap worth investigating.

For a broader view of how auditors gather and evaluate evidence in this type of examination, the article on audit evidence types and how to record it covers the methods that apply across all ISO standard audits.

Common Nonconformities Under Clause 3

Based on audit experience across translation service providers of varying sizes, several patterns of nonconformity appear repeatedly under Clause 3.

Incomplete or Outdated Competence Records

This is the most common finding. Providers often have competence records that were collected when a translator was first engaged but have not been updated since. Qualifications expire or become irrelevant. Subject matter areas evolve. Translators develop new specialisations that are not reflected in their records. The provider has a responsibility to keep records current, and many do not have a systematic process for doing so.

No Defined Assessment Process

Some providers can produce competence records but cannot describe how they assessed competence before adding a translator to their approved pool. Collecting a CV is not the same as assessing competence. The standard requires that competence be assessed, and the assessment process must be defined and documented. Providers who rely on informal judgement or word-of-mouth recommendations without a structured process will receive a nonconformity.

Freelancer Records Not Maintained to the Same Standard

As noted earlier, the gap between in-house and freelance records is a persistent issue. Some providers maintain excellent records for employees but have minimal documentation for freelancers. This is not compliant. The standard applies equally to all personnel involved in the workflow regardless of their employment status.

Technical Resources Not Integrated Into the Workflow

Providers sometimes list technical resources in their documentation that are not consistently used in practice. Translation memories that are not regularly updated, glossaries that are not shared with translators, or style guides that exist but are not referenced during production are all examples of this pattern. The resource exists on paper but is not functioning as part of the quality system.

No Process for Managing Terminology

Providers who lack a defined process for terminology management will struggle to demonstrate compliance. This does not require sophisticated software. A simple, consistent process for receiving, storing and applying terminology resources is sufficient. What is not sufficient is an informal arrangement where each project manager handles terminology differently.

What Good Looks Like Under Clause 3

A provider who manages Clause 3 well will have a structured, maintained database of approved translators and revisers. Each entry will include documented evidence of qualifications, language combinations, subject matter specialisations and any assessments completed. The database will be reviewed regularly and updated when circumstances change.

Technical resources will be integrated into the production workflow in a way that is consistent and verifiable. Translation memories will be maintained and applied. Terminology resources will be accessible to the relevant translators. Style guides and reference materials will be version controlled and current.

Project managers will be able to demonstrate, for any recent project, which resources were used, why they were selected, and how they were made available to the production team. The connection between the resource management processes and the actual work will be clear and traceable.

For providers working towards ISO 17100 certification or preparing for a surveillance audit, understanding what auditors look for in Clause 3 is essential preparation. The article on What Is ISO 17100? The Translation Services Standard Explained provides useful background on the standard as a whole before diving into individual clauses.

Preparing for a Clause 3 Audit: Practical Steps for Providers

If you are a quality manager at a translation service provider preparing for an audit, here is where to focus your attention on Clause 3.

First, conduct a review of all competence records for active translators and revisers. Identify any records that are incomplete, outdated or missing. Prioritise records for personnel who have worked on projects in the past twelve months. Collect any missing documentation and update records that are no longer current.

Second, document your competence assessment process if it is not already formalised. Define what criteria you use to assess translator competence, how the assessment is conducted, who approves the outcome, and how the result is recorded. Apply this process consistently going forward.

Third, review your technical resource documentation. Check that the tools and resources described in your quality documentation are actually being used in production. If there are gaps between documentation and practice, either update the documentation to reflect reality or implement the processes that the documentation describes.

Fourth, establish a regular review cycle for competence records. This might be annual or triggered by specific events such as a translator taking on a new subject matter area. The important thing is that the review is systematic and documented.

Auditors who work across multiple ISO standards will recognise many of these principles from other standards. The competence requirements in ISO 17100 Clause 3 have clear parallels with the resource requirements in ISO 9001 Clause 7, and auditors with experience in quality management systems will apply similar evidence-gathering techniques.

If you are building your auditing skills across multiple ISO standards or preparing to audit translation service providers as part of a broader quality management audit scope, Audit Workshop offers practical training for internal and lead auditors across ISO 9001, ISO 14001 and ISO 45001. The skills developed in those programmes transfer directly to auditing specialised standards like ISO 17100, particularly in areas like competence evaluation, evidence gathering and nonconformity writing.