Privacy Policy

Last updated 25/01/2022

1. Introduction
   At Crystal Clear Translation (CCT), we are committed to protecting your privacy and being transparent about how we use your data. We will only use the information we collect about you lawfully in accordance with UK Data Protection Law which includes the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA).
   This document (together with our website terms and conditions) will outline the details of what we collect and how we use and store your personal information. If you have any queries about our privacy policy, please contact us on info@crystalcleartranslation.com

1.2 How we collect information

CCT offers the following services:

• Interpreting (face to face, video, telephone, ad-hoc, simultaneous, and consecutive)
• Translation
• Proof reading
•  Audio transcription/subtitling
•  Voice-overs
•  British Sign Language (BSL) interpreting                                                                                                                                                                                                                                                                                                       *Services can be accessed and/or booked via telephone, app, email and our website portal. Some of the information you give to us will be held on central systems and accessed by authorised staff only.

1.3 Data transfer outside of the UK
Where data is transferred from the UK to an EEA Country or to a third country, CCT will ensure such transfers are protected by suitable and appropriate safeguards such as EU Standard Contractual Clauses (SCCs). Where necessary and subject to an assessment of risk, the use of such SCCs will be on a case- by- case basis. Until the 27 December 2022, these SCCS will remain in place , but as a result of the UK’s Brexit transition process, it is likely there will be some changes to SCCs after this date. Any changes made will be reflected in future updated versions of this Privacy Policy, so it is advised that you revisit it as and when.

1.4 What personal data we collect and how we use it
Any information we collect about you will:
• Be obtained and processed fairly and lawfully and shall not be processed unless certain conditions are met
• Be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with that purpose
• Be adequate, relevant and not excessive for those purposes
• Be accurate and kept up to date
• Not be kept for longer than is necessary for that purpose
• Be processed in accordance with the data subject’s rights
• Be kept safe from unauthorised access, accidental loss or destruction
• Not be transferred to a country outside the European Economic Area, unless that country has equivalent levels of protection for personal data.
The type and quantity of information we collect and how we use it depends on why you are providing it.

1.5 Customers and Organisations
Any customers and/or organisations who wish to use CCT’s services must complete an Account Registration form or – in some cases – sign a contract.
If you receive a quote from us and/or use our services, we will store this information on our database.
Data and documentation will be retained for a period of seven years beyond the last date of entry on the records. Any paper documentation will be disposed of by secure shredding.
Any electronic files will be permanently deleted IT Department in a safe, secure manner.

1.6 Suppliers
Any new suppliers to CCT will be asked to complete a Contract of Supply. The Contract, application forms, references, contact details and bank details are kept electronically.
Once the contract is complete, any documentation pertaining to it will be retained for a period of seven years beyond the last date of entry on the records. Any paper documentation will be disposed of by secure shredding. Any electronic files will be permanently deleted by the IT Department in a safe, secure
manner.

1.7 Complaints
CCT has a complaints procedure for our services. We ask that any complaints be reported in writing, either via an email or using the ‘contact us’ form which can be found on our website.
You may also complain to the Information Commissionerʼs Office (ICO) who regulate information rights in the UK. For further details, please go to their website here; https://ico.org.uk/make-a-complaint/

1.8 How we keep your data safe and who can access it
CCT is committed to establish client-company trust, and as such we always ensure that there are appropriate technical controls in place to protect your personal details. For instance, our online forms are always encrypted, and our network is protected, undergoing regular monitoring.
We regularly review who has access to the information that we hold to ensure that your information is only accessible by appropriately trained personnel.
We may use external companies to collect or process personal data on our behalf. We always carry out comprehensive checks on these companies before we work with them and put a contract in place that sets out our expectations and requirements, especially in regard to how they manage the personal data that they have collected or have access to.
If you have any further queries about this statement, please contact us at Crystal Clear Translation, The Enterprise Cube, Stag Hill, Guildford GU2 7XH or email us at info@crystalcleartranslation.com.

2. Using our website
   This section outlines how and why our company website collects and uses your information.

2.1 Use of Cookies
Our website uses cookies to collect information. Cookies are small data files which are placed on your device when you browse a website. Cookies are essential in aiding the effectiveness of a website and its overall performance, whilst also optimising your user experience.
Some cookies may collect information about browsing behaviour from the same device.
This includes information about the pages that device owner viewed.
CCT does not use cookies to collect or record any sensetive personal information such as name, address or other importatn contact details.

2.2 How do I disable cookies?
If you wish to disable the use of cookies on your device, you need to change your website browser settings to prevent cookies from being stored – how you do this will depend on the browser you use. A quick online search will bring up a list of results instructing you on how to disable cookies on your particular browser(s).

2.3 What happens if I disable cookies?
Depending on which cookies you choose to enable/disable, the web site may not operate properly or will operation with reduced functions/features.

2.4 IP Addresses
An IP (Internet Protocol) address is an address that identifies a device on a local network or on the Internet. An IP address may be collected by analytical systems upon connecting to our website, but they are not linked to individuals.

2.5 Your right to know about, make changes to or ask us to stop using the data we keep
CCT prides itself on a culture of transparency and fairness; all customers have a right to know about and access the information or data that we keep on them.

• Any private client who wishes to do this must contact the Director in writing using the info@crystalcleartranslation.com email address.
• CCT aims to comply with requests for access to personal information as quickly and effectively as possible, but will ensure that it is provided within one month as per the UK GDPR guidelines. This time frame can be extended where requests are complex or numerous, but the individual must and will be notified within one month of the receipt of the request and given an explanation as to why the extension is required.

3. Lawful Basis
   Adhering to the DPA, CCT processes data under the ‘conditions for processing’. Under the UK GDPR, this is our ‘lawful basis’ for processing personal data. This policy outline documents our lawful basis. The lawful basis for processing data includes the following aspects:
   a. Consent of the data subject
   b. Processing is necessary for compliance with a legal obligation
   c. Processing is necessary to protect the vital interests of a data subject or another person
   d. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
   e. Processing is necessary for purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests, rights or
   freedoms of the data subject.
   The conditions for special categories of data, formerly known as ‘sensitive’ data are as
   follows:
   a. Explicit consent of the data subject, unless reliance on consent is prohibited by UK Data Protection law
   b. Processing is necessary for carrying out obligations under employment, social security, social protection law or a collective agreement
   c. Processing necessary to protect the vital interests of a data subject where the subject is incapable of giving consent
   d. Processing is necessary for the establishment, exercise or defence of legal claims
   e. Processing is necessary for reasons of substantial public interest
   f. Processing is necessary for the assessing the working capacity of the employee
   g. Processing is necessary for reasons of public interest in the area of public health

3.1 Legal basis for processing
We rely on the following legitimate interest for processing:
• Provide services to customers
• Evaluate service delivery
• Market to potential customers

In regard to special categories, CCT will seek consent to collect, store and process their data.
In addition, in regard to special categories, processing is necessary for the establishment exercise or defence of any legal claims. Wherever we may use our Legitimate Interest to process personal data, you may object to such processing. If you wish to object the contact details can be found on our website.

4. Monitoring
   To reflect the ongoing changes to data and data processing in the UK, this Privacy Policy will be regularly reviewed and updated when necessary to accurately reflect these changes and prioritise our clients’ privacy rights.