Privacy Policy

Introduction

At Translit, we prioritise your privacy and are dedicated to safeguarding your personal information. This Privacy Notice outlines how we collect, use, and protect your data, ensuring compliance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

The objective of this policy is to provide all Translit employees, agency staff and contractors (linguists) with information about how Translit collects and processes their personal data. However, the information we will process about you will vary depending on your specific role and personal circumstances.

How We Collect Your Information

We collect your information from various sources, depending on your role and personal circumstances. These sources are:

• Directly from you
• From an employment agency or referees
• Security clearance providers
• Occupational Health and/or other health service providers
• Providers of staff benefits/services
• Pension administrators and other government departments, for example tax details from HMRC
• CCTV images from our landlords and/or taken using our own CCTV

Information We Collect

We gather several types of personal and sensitive data to collaborate with you, depending on your role and personal circumstances.

Personal Data

• Full name
• Address
• Email address
• Phone Number
• Date of Birth
• Personal Public Services Number (PPS) or National Insurance Number
• Passport / ID numbers (right to work information)
• Photograph
• Ethnic Origin
• Emergency contact details
• Work History
• Qualifications

Special Category Data

• Financial/bank details
• Billing information
• Information related to criminal offences.
• Medical/health information

We also collect technical information, including IP addresses, login details, usage data and CCTV images to ensure the security and functionality of our IT systems and premises.

How We Use Your Information

Your personal data is used for several key purposes:

Service Delivery and Management

• Personal Data: Full name, address, email address, phone number, date of birth, PPS, passport number, ID number, photograph, ethnic origin, emergency contact details, work history, qualifications
• Special Category Data: Financial/bank details, billing information, information relating to criminal offences, medical/health information.
• Purpose: To manage and deliver our services effectively, ensuring that we meet our contractual obligations to you and our clients, for example checking your right to work in the country in which you reside.

Processing payments

• Personal Data: Financial/bank details, billing information
• Purpose: To process payments for services provided and to manage financial transactions securely

Communication

• Personal Data; Email address, phone number.
• Purpose: To communicate with you regarding updates, announcements, and other relevant information.

IT Security

• Personal Data: Full name, email address, phone number, IP address, CCTV images
• Special Category Data: Information relating to criminal offences.
• Purpose: To ensure the security and functionality of our IT systems and premises

Service Enhancement and User Experience

• Personal Data: Full name, email address, phone number.
• Special Category Data: Medical/health information (occupational health)
• Purpose: To improve our services and enhance user experience

Legal compliance and Dispute Management

• Personal Data: Full name, address, email address, phone number, date of birth, PPS, photograph, ethnic origin, emergency contact details.
• Special Category Data: Financial/bank details, billing information, information relating to criminal offences, medical/health information.
• Purpose: To comply with legal obligations and manage disputes effectively

Legal Basis for Processing

Depending on the processing activity, we rely on the following lawful basis’s for processing your personal data under the GDPR:

• Article 6(1)(b) which relates to processing necessary for the performance of a contract.
• Article 6(1)(c) so we can comply with our legal obligations as your employer.
• Article 6(1)(d) in order to protect your vital interests or those of another person.
• Article 6(1)(e) Processing necessary for the performance of a task conducted in the public interest or in the exercise of official authority vested in us.
• Article 6(1)(f) for the purposes of our legitimate interest

Where the information we process is special category data, for example your health data, the additional bases for processing that we rely on are:

• Article 9(2)(a) your explicit consent
• Article 9(2)(b) which relates to carrying out our obligations and exercising our rights in employment and the safeguarding of your fundamental rights.
• Article 9(2)(c) to protect your vital interests or those of another person where you are incapable of giving your consent.
• Article 9(2)(f) for the establishment, exercise or defence of legal claims.

We process information about staff criminal convictions and offences. The lawful basis we rely on to process this data are:

• Article 6(1)(e) for the performance of our public task. In addition, we rely on the processing condition at Schedule 1 part 2 paragraph 6(2)(a) of the DPA 2018
• Article 6(1)(b) for the performance of a contract. In addition, we rely on the processing condition at Schedule 1 part 1 paragraph 1 of the DPA 2018

Our Appropriate Policy Document provides further information about this processing.

Your Rights

You have the following rights regarding your personal data:

• Right to Access: Request access to your personal data.
• Right to Rectification: Correct inaccurate data.
• Right to Erasure: Request deletion of your data under certain conditions.
• Right to Restrict Processing: Limit how we use your data.
• Right to Object: Object to certain types of data processing.
• Right to data portability:Ask that we transfer the information you gave us from one organisation to another, or give it to you

To exercise these rights, please contact our Data Protection Officer at DPO@Translit.com

Data Principles

• Minimal Data Collection: We do not collect more information than is necessary. We ensure that the data we gather is relevant and limited to what is required for the purposes for which it is processed.
• Purpose Limitation: We do not use your data for purposes other than those specified. Your data is only processed for the specific, explicit, and legitimate purposes that we have communicated to you.
• Data Retention: We do not keep your data if it is no longer needed. We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
• Data Sharing: We do not share your data with third parties for marketing purposes. Your personal data is not sold, rented, or otherwise disclosed to external parties for their marketing activities.
• Data Accuracy: We take all reasonable steps to ensure that the personal data we hold is accurate and kept up to date. If any inaccuracies are identified, we promptly rectify them.
• Data Security: We implement appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction, or damage.
• Transparency: We are transparent about how we collect, use, and share your personal data. Our privacy notices and policies are clear and accessible, providing you with detailed information about our data processing activities.
• Individual Rights: We respect your rights regarding your personal data. You have the right to access, rectify, erase, restrict processing, object to processing, and data portability. We provide mechanisms for you to exercise these rights easily.
• Accountability: We are accountable for our data protection practices. We regularly review and update our data protection policies and procedures to ensure compliance with applicable laws and regulations.

Data Sharing

We may share your data with third-party processors for specific business purposes, These third parties are carefully selected and are required to adhere to GDPR and other relevant data protection regulations. We ensure that any data shared is managed securely and used only for the intended purposes. The types of third-party processors we may share your data with include:

• Payment Processors: To handle transactions and process payments.
• IT Support Providers: To maintain and support our IT systems.
• Security Services: To ensure the security of our premises and IT systems.
• Cloud Storage Providers: To securely store and manage translation files and data.
• Data Analytics Services: To analyse translation performance and improve service delivery.
• Marketing and Communication Platforms: To send updates, announcements, and other relevant information to clients and stakeholders.
• Clients: To provide contact information if required to attend a booking

These measures ensure that your data is always kept secure and that your privacy rights are protected.

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected. This retention period is determined by considering legal, regulatory, tax, accounting, and reporting requirements. Once the data is no longer needed, it is securely deleted or anonymised to protect your privacy.

More information on data retention can be found in our Data Retention Policy.

International Transfers

When transferring your data outside the EU or EEA, we implement appropriate safeguards to ensure your data remains protected. These safeguards include:

• Standard Contractual Clauses (SCCs): We use SCCs approved by data protection authorities to ensure that your data is protected during international transfers.
• Binding Corporate Rules (BCRs): Where applicable, we use BCRs to ensure that all members of our corporate group provide adequate protection for personal data.
• Adequacy Decisions: We transfer data to countries that have been deemed to provide an adequate level of data protection by the European Commission.
• Exceptions: In specific situations, we may rely on exceptions for specific situations as outlined in Article 49 of the GDPR, such as your explicit consent or the necessity of the transfer for the performance of a contract.

These measures ensure that your data is always kept secure and that your privacy rights are protected during international transfers.

Contact Information

For any questions about this Privacy Notice or to exercise your data protection rights, please contact our Data Protection Officer at DPO@Translit.com. For written correspondence please send to our Head Office Address: 18 Mallow Street Upper, Limerick, V94 N12Y. We are committed to addressing any concerns you may have and ensuring your data is managed responsibly.

Changes to This Notice

We may update this Privacy Notice from time to time to reflect changes in our practices or legal requirements. Any changes will be communicated to you via email, our website or other appropriate.

This Privacy Notice is reviewed annually or whenever there is a change that impacts the contents.

Effective date 24.01.2025.