Below is an outline of the kind of data that is stored with K.E.S. Translations and for whom, how and why it is processed, and your rights in respect of this data.
Who is K.E.S. Translations?
Who are the data subjects?
Data subjects may be personnel at translation agencies, an agency’s end client, other translators, a supplier or someone whose personal data is included in the text for translation/revision or its reference material.
What kind of personal data may be stored?
Name, email address, billing address, VAT number (where applicable), phone number, website, social media contact details, company number, or job title. Due to the nature of my services, I rarely receive sensitive personal data such as data relating to health, religion or sexual orientation, for example. However, should I receive such data as part of a translation task, it is the obligation of the data controllers (agency, end client) to ensure that they have the necessary permissions to share this data with me as the data processor. Regardless, I commit to ensure that this data is held securely, confidentially, and deleted when the work on that particular text is completed.
Where does the personal data come from?
I only collect, store and process personal data that has been provided by a translation agency, its end client or another translator, as well as collecting, storing and processing data for a supplier in order to enlist their services. I may also collect, store and use personal data that is made publicly available, e.g. on an agency’s website.
Where personal data is included in a text for translation/revision, I commit to comply with the agency’s or end client’s policy and confidentiality agreement and I will not use that data for any other purpose than to translate the text. It is the obligation of the agency and/or the end client to ensure that they have the necessary permissions to share this data with me as the data processor.
Why is the data processed?
Data relating to personnel at translation agencies, their end clients, other translators who contract out work, and suppliers is processed as part of contractual obligations and legal compliance. The contractual obligations include performing the translation task assigned to me and instructing a supplier to carry out services for the business. The legal compliance includes keeping records for tax and accounting purposes. This data will not be processed for any other purposes.
I may store data of other translators as colleagues to contact regarding a work opportunity or industry-related event. These details will be given voluntarily by the other translator for purposes of keeping in contact and will not be used for any marketing or other processing.
How long is the data retained?
Personal data is retained according to its purpose:
- for legal compliance with financial and tax information, it will be retained according to the statutory period (5 years);
- for contractual obligations, data for administrative purposes will be retained for as long as there is a contractual relationship in force;
- for the personal data of colleagues for the purposes of keeping in contact for industry and business-related activities (not marketing), this data will be retained until the individual withdraws consent or the business ceases operation;
- for personal data included in texts for a translation/revision project, it will be retained in accordance with the agency’s or end client’s regulations; where there are none in force, the project files will be retained until payment has been received for that particular project and then it can be deemed completed and closed.
What are your rights in respect of the data stored at K.E.S. Translations?
You may contact me in writing at any time using the contact details above to make a request in respect of your GDPR rights and you can expect a reply within a month. Your rights are:
- right to be informed: you may request processing information regarding your personal data – the purpose for processing, how long it is stored for, who it is shared with, etc.;
- right of access: you may request information about which personal data is stored;
- right to rectification: you may request that inaccurate data be rectified or completed;
- right to erasure (right to be forgotten): you may request for your personal data to be deleted, provided that it does not interfere with my compliance with legal requirements;
- right to restrict processing: you may request for your data to be restricted in how it is processed by K.E.S. Translations;
- right to data portability: you may request for your data to be transferred.
You can contact me to raise a complaint and I will reply within a month. You can also contact the Information Commissioner’s Office if you suspect that your data has been unlawfully processed and are not satisfied with the response from an initial request to K.E.S. Translations.
Who has access to the data?
Any data that I process is accessed by myself as the sole operator at K.E.S. Translations. Where the data is stored in emails, cloud storage, or software such as accounting or administrative tools, these are GDPR compliant and are subject to security measures.
I do not have any access to the data collected by these third-party services.