Privacy Notice for Clients

Due to the nature of our work we are splitting this privacy notice into two sections. Section 1 is about your personal data (contact details, etc.) which you exchange with us in the course of setting up a business relationship with Wolfestone Holdings (Wolfestone Translation, Robertson Languages International, and VoiceBox).

Section 2 concerns personal data which may be present in the documents you provide to us for translation.

Section 1: Your personal data

Wolfestone Holdings, comprising Wolfestone Translation, Robertson Languages International, and VoiceBox, acts as a data controller and as such, has contractual reasons for obtaining and keeping personal data you provide to us as a representative of your company. We only collect basic personal data about you which does not include any special types of information or location-based information. This does, however, include name, company or personal email address, company or personal address, and one or two phone numbers (landline and/or mobile).

How we collect your data

Wolfestone Holdings only collects your data directly from you. We do not engage third parties to provide us with your personal data.

Why we need your data

We need to know this basic personal data in order to provide you with on-going organisational updates and information in line with our overall contract with you. We will not collect any personal data from you that we do not need.

What we do with your data

All the personal data we process is processed by our staff in the UK however for the purposes of IT hosting and maintenance this information is located on servers within the European Union.

Wolfestone Holdings staff use your data to contact you regarding business communication

If you are an individual and using a personal bank account to pay for commissioned work, your payment is processed by our third-party payment software. We do not store your bank details on our system.

No third parties have access to your personal data unless the law allows them to do so.

What if I no longer wish to work with Wolfestone Holdings?

If you no longer wish to work with us, you can request that we deactivate your profile and we will stop contacting you.

We cannot delete your record completely with immediate effect as we are required under UK tax law to keep your basic personal data (name, address, contact details) for 6 years after which time it will be destroyed.

However, you have a right to request data anonymisation and we will comply with your request when it is legally possible (some regulations may prevent us from anonymising some data, but we will be transparent and will provide you with detailed information shall we be forced to reject your request).

The limitations of our Project Management System means that your name will need to remain in our database as it is associated with projects in the system; we can, however, delete all other information on your profile.

Data Protection Officer

For any data protection queries, please contact our Data Protection Officer at: dpo@wolfestone.co.uk.

What are your rights

You have the right to be informed about how we use your data and who has access to it. If you have any questions about your data which are not addressed in this privacy notice, please contact our Data Protection Officer: dpo@wolfestone.co.uk
Under the GDPR you have the right of access, which means you can request for us to show you the data we have on you and tell you who has access to it. This is called a subject access request. Please see our Subject Access Request page on our website for more information: https://www.wolfestone.co.uk/gdpr/subject-access-request-policy/
You have the right to rectification, which means that, if at any point you believe the information we process on you is incorrect you can request to see this information and have it corrected or deleted. Please see our Subject Access Request page on our website for more information: https://www.wolfestone.co.uk/gdpr/subject-access-request-policy/
You have the right to erasure, which means you can ask for us to remove you from our records. In order to fulfil our legal obligations, we need to keep your data for 6 years, after which time all your data will be securely destroyed. Our legal obligations override the right to erasure in this context.
You have the right to restrict processing, which means that you can request that we don’t do anything with your data except store it.
You have the right to data portability, which means you can ask us to transfer your data to another data controller or send it to you in a structured, machine-readable format.
Right to object – as our grounds for collecting your data is based on legitimate interests, you may object to us processing some of the data that we ask for as part of your application process. This may, however, affect your application.
Rights related to automated decision making, including profiling – we do not use any automated decision making or profiling services when allocating project work.

For more information on your rights under GDPR and when they apply, please see:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

To exercise these rights please contact our Data Protection Officer: dpo@wolfestone.co.uk.

If at any point you believe the information we process on you is incorrect you can request to see this information and have it corrected or deleted.

If you wish to raise a complaint on how we have handled your personal data, you can contact the DPO to have the matter investigated.

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office https://ico.org.uk/

Section 2: Personal data contained within documents for translation

As the primary data controller it is your obligation to ensure that you have consent from the data subject or otherwise lawful grounds for sending us content containing personal data for translation.

This is especially true for content containing special categories of personal data.

Wolfestone Holdings, comprising Wolfestone Translation, Robertson Languages International, and VoiceBox acts as both a data processor and a joint controller of personal data present in files for language related work. This is because in order to fulfil our contracts with you, we need to engage sub-processors, and therefore have responsibility over how your data reaches them.

By ‘language-related work’ we mean: translation, transcription, voiceover, subtitling, language training, interpreting, and any other language-related service commissioned by our clients.

What we do with personal data in content you provide for language-related work

We do not extract personal data in content for language-related work for processing outside the context of the project.

For the purposes of IT hosting and maintenance the files are stored on servers within the European Union.

All relevant Wolfestone Holdings staff have access to content for language-related projects.

Content for language-related projects is shared using secure means with approved and compliant third-party language service suppliers as part of pre-contractual enquiries and then as part of the contract fulfilment.

Third Country Data Transfers

For fulfilment of some contracts, we will need to transfer the data to language service suppliers outside of the EU and EU’s list of Adequate Countries. This is because most Chinese translators, for example, are based in China. If we need to send a document outside the EU/EEA in order to fulfil your contract (in accordance with article 49b of the GDPR regulations), we will inform you. It is up to you to make sure the data subject is also aware of this and gain their explicit consent or redact the personal data within the content. For more information please see our Third Country Transfer Policy.

Special Categories of Personal Data

If your files contain special categories of personal data belonging to a third party data subject, it is your obligation to obtain the relevant consent and establish lawful grounds for processing of that data according to articles 6 and 9 of the regulations.

We will make every effort to identify special categories of personal data within documents you provide to us prior to starting the project workflow so appropriate measures can be taken.

We might ask you to redact identifiable information in order for us to minimise risk to the data subject before starting the project workflow, especially if the contract would necessitate sending the document to language service suppliers outside of the EU/EEA.

No documents containing special categories of personal data will be stored in a TM. All documents containing personal data which are processed using a TM, will have segments containing personal data deleted immediately after completion of the translation.

Data Relating to Children

If your files contain data relating to children who cannot consent to the processing of their data, it is your obligation to obtain consent from their parent or guardian prior to commissioning work from us.

How long we keep your data

We are required under UK tax law to keep project files 6 years after which time they will be destroyed.

Data Protection Officer

For any data protection queries, please contact our Data Protection Officer at: dpo@wolfestone.co.uk.

What are your rights

You have the right to be informed about how we use your data and who has access to it. If you have any questions about your data which are not addressed in this privacy notice, please contact our data protection officer, Norbert Pietrzak: dpo@wolfestone.co.uk.
Under the GDPR you have the right of access, which means you can request for us to show you the files we have and tell you who has access to them. This is called a subject access request. Please see our Subject Access Request page on our website for more information: https://www.wolfestone.co.uk/gdpr/subject-access-request-policy/
You have the right to rectification, which means that, if at any point you believe the information we process is incorrect you can request to see this information and have it corrected or deleted. Please see our Subject Access Request page on our website for more information: https://www.wolfestone.co.uk/gdpr/subject-access-request-policy/
You have the right to erasure, which means you can ask for us to remove project files from our records. In order to fulfil our legal obligations, we need to keep the files for 6 years, after which time all the files will be securely destroyed. Our legal obligations override the right to erasure in this context.
You have the right to restrict processing, which means that you can request that we don’t do anything with the files except store them.
You have the right to data portability, which means you can ask us to transfer the files to another data controller.
Right to object – our grounds for processing data are based on fulfilment on a contract with you, so objection rights do not apply here.
Rights related to automated decision making, do not apply in this context.

For more information on your rights under GDPR and when they apply, please see:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

To exercise these rights please contact our Data Protection Officer: dpo@wolfestone.co.uk.

If at any point you believe the information we process on you is incorrect you can request to see this information and have it corrected or deleted.

If you wish to raise a complaint on how we have handled your personal data, you can contact the DPO to have the matter investigated.