PRIVACY NOTICE
Synergy Language Services Ltd. (the “Company”) is committed to protecting the privacy and security of your personal data. This privacy notice details how we collect and use personal information about translators and other contractors during and after the working relationship, in accordance with the General Data Protection Regulations (“GDPR”).
The Company is a “data controller” and are responsible for deciding how we hold and use personal information about you and for communicating that with you.
The Company may issue other privacy notices on specific occasions and you should read this and any other privacy notices so that you are aware of how and why we are using such information.
Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way;
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- Relevant to the purposes we have told you about and limited only to those purposes;
- Accurate and kept up to date;
- Kept only as long as necessary for the purposes we have told you about; and
- Kept securely.
Personal data we hold about you
Under the GDPR “personal data” means any information about you from which you can be identified. It does not include anonymous data. There are also “special categories” of more sensitive personal data which require a higher level of protection.
We will collect, store, and use the following categories of personal information about you:
- Personal contact details such as name, title, addresses, telephone numbers
- Bank account details
- Rates
- CV
How do we collect your personal data?
We collect personal information through the recruitment of freelance suppliers, either from resources in the public domain (e.g. Proz.com) or directly from the individual. We may sometimes collect additional information from third parties including former employers (or other background checking agencies).
We will collect additional personal information in the course of job-related activities throughout the period of you working for us.
How we use your personal data
We will only use your personal information when the law allows us to, most commonly in the following circumstances:
- Where we need to perform the Translator Service Agreement with you;
- Where we need to comply with a legal obligation; and
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest or for official purposes.
Situations in which we will use your personal information
We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
- Making a decision about your translation services;
- Deciding the terms on which you work for the Company and/or a client of the company;
- Paying you for the services you performed;
- Dealing with administration;
- Administering our Translator Service Agreement or sub-contractor arrangement with you;
- Business management and planning, including accounting and auditing;
- Conducting performance reviews, managing performance and deciding performance requirements;
- Making decisions about fees;
- Assessing qualifications for a particular job or task;
- Making decisions about your continued engagement and/or its termination;
- Dealing with legal disputes involving you;
- To prevent fraud;
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you), or we may be prevented from complying with our legal obligations.
Change of purpose
We will only use your personal data for the purposes which we collected it for, unless we reasonably need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Do we need your consent?
In limited circumstances, we may approach you for your written consent to allow us to share your personal data with other third parties. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
Data sharing
We may have to share your data with third parties, including third-party service providers. We require any such third parties to respect the confidentiality and security of your data and to treat it in accordance with our instructions and the law.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
Which third-parties process my personal information?
“Third parties” includes third-party service providers (including Banks and professional advisers).
We may also share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business or to our professional advisers for the purposes of taking legal, tax or other advice. We may also need to share your personal information with a regulator or to otherwise comply with the law.
Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Data retention
How long will you use my information for?
We will only retain your personal information for as long as necessary for the purposes we collected it for. When deciding the appropriate retention periods for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
If appropriate, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Unless we have reasonable grounds for lawfully holding your personal data for a longer period, our normal retention periods for paper or electronic records are as follows:
| Type of record | Standard retention period |
| Purchase Orders | 6 years from date of issue |
| Translator Invoices | 6 years from date of issue |
| CVs and other information provided | For as long as necessary for the purposes we collected it for |
| Bank details for payments | Only whilst relevant bank account |
| Written particulars/contracts of service and changes to terms and conditions | For as long as necessary for the purposes we collected it for |
| Consents for processing personal and sensitive data | For as long as necessary for the purposes we collected it for |
Rights of access, correction, erasure and restriction
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights regarding personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Sabina Clark at sabina.clark@synergylanguageservices.com or Kerry Gillies at kerry.gillies@synergylanguageservices.com in writing.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Sabina Clark at sabina.clark@synergylanguageservices.com or Kerry Gillies at kerry.gillies@synergylanguageservices.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information. The most up to date version of this privacy notice will be accessible through our website www.synergylanguageservices.com.
If you have any questions about this privacy notice, please contact
Sabina Clark at sabina.clark@synergylanguageservices.com, or
Kerry Gillies at kerry.gillies@synergylanguageservices.com.