May 2018
Babylon Translations privacy notice
Babylon Translations is a provider of language and translation services operating in full compliance with all applicable legislation. With the entry into force of the General Data Protection Regulation (GDPR) in May 2018, the company upgraded its policies, procedures and practices for personal data protection. In all its activities, Babylon Translations abides strictly by the requirements of the GDPR, the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework.
These regulations require all controllers, processors and sub-processors to ensure the best possible protection of personal data. Babylon Translations achieves this through appropriate organisational and technical measures and through policies and procedures that require adequate data protection from all its staff, sub-processors and freelancers.
1. Applicability
Babylon Translations collects, processes and retains personal data only as needed to comply with the applicable legislation and to perform its services. The data collected from clients and sub-processors normally consist of business contact data. When personal data are present in documents such as agreements, these documents are handled according to best data-security practice.
The personal data collected from staff and freelancers are necessary to meet specific legal requirements and to fulfil the company's obligations to pay these persons and report to the relevant authorities.
Personal data of third parties may be present in documents provided for translation, and in many cases these data cannot be de-identified (for example, when the document itself relates to a person, such as an educational certificate, or when it is provided only as a scan). In all cases, these documents and their translations are treated in full confidentiality and are returned to the client, deleted or destroyed, as appropriate, when the job is complete.
2. Disclosure to third parties
Personal data may be disclosed to third parties only when required by law enforcement authorities or other public authorities with a legal right of access to these data. Disclosure to any other party is possible only with the explicit permission of the data subject.
Whenever possible, personal data in documents such as CVs are de-identified by pseudonymisation or other appropriate methods. Whenever personal data are transferred to countries outside the European Union or the Privacy Shield areas, all processors (for example, freelancers) are required to ensure the same level of data security. Whenever personal data are processed by individual employees and contractors of Babylon Translations, these persons are subject to the highest possible confidentiality obligations.
3. Personal data protection
Babylon Translations has developed appropriate policies and procedures to ensure compliance with all applicable laws and regulations on data security and personal data protection. These include, but are not limited to:
Organisational and technical security measures for the collection, processing and retention of hard copies and electronic files.
A GDPR-compliant Information Security Policy and Data Protection Policy with specific guidance for Babylon Translations employees and contractors.
Non-disclosure and confidentiality agreements with employees and contractors (sub-processors and freelancers).
Guidance to contractors and the requirement that they comply fully with the best possible data protection measures.
Appropriate procedures and methods for transferring data via secure communication channels, with additional measures such as encryption.
Appropriate policies for the retention of documents containing personal data and their deletion when the job related to a document is complete.
Adequate measures to protect documents from loss or destruction.
Continuous review of data-security practices to ensure full compliance with the applicable legislation and with client requirements set out in agreements or specific instructions.
Procedures to meet all obligations under the GDPR, such as providing access and enabling data subjects to exercise their rights under the GDPR, including the right to be notified of an actual or suspected personal data breach.
4. Information and complaints
This notice and all disputes arising under it are governed by the GDPR and the Bulgarian Personal Data Protection Act. All disputes of whatever nature, including non-performance and performance, are decided by the courts of the Republic of Bulgaria.
Complaints may be submitted to the Commission for Personal Data Protection, 2 Tsvetan Lazarov St., 1592 Sofia, Bulgaria (www.cpdp.bg).
Babylon Translations has appointed a Responsible Person for Data Protection, who provides additional information and explanations on personal data protection and accepts claims regarding data security. The Responsible Person can be reached by phone at +359 32 260 754; any change will be updated immediately.