UK LEGAL SERVICES TRANSLATION LIMITED
INTERPRETER / TRANSLATOR DATA PROTECTION, CONFIDENTIALITY AND INFORMATION SECURITY AGREEMENT
UK Legal Services Translation Ltd
Trading as: UKLST / National Translators Interpreters Service / NTIS UK Registered Office: Foreign House, 289 Cheetham Hill Road, Manchester, M8 0SN, United Kingdom
Company Registration Number: 10690194
Website: www.uklst.com
1. Purpose of this Agreement
This Agreement sets out the data protection, confidentiality and information security obligations that apply to all interpreters and translators engaged by UK Legal Services Translation Ltd ("UKLST", "we", "us" or "our").
Interpreters and translators may receive or have access to confidential and personal information when carrying out assignments for UKLST and its clients.
Such information may include sensitive personal information relating to legal proceedings, immigration, health, social care, education, criminal justice, family matters, financial circumstances or other confidential matters.
The purpose of this Agreement is to ensure that all personal and confidential information is handled lawfully, securely and only for authorised purposes
2. Data Protection Law
UKLST is committed to complying with applicable UK data protection legislation, including:
• the UK General Data Protection Regulation ("UK GDPR");
• the Data Protection Act 2018;
• applicable provisions of the Privacy and Electronic Communications Regulations; and
• any other applicable data protection or information security requirements.
UKLST may act as a data controller for some processing activities and as a data processor when processing personal data on behalf of a client.
Where UKLST acts as a processor, it will process personal data in accordance with the documented instructions of the relevant controller and the applicable contractual requirements.The interpreter/translator must comply with UKLST's instructions concerning the handling of personal data.
3. Personal Data
For the purposes of this Agreement, personal data includes information relating to an identified or identifiable individual.
Depending on the assignment, information accessed by an interpreter/translator may include:
• name and contact details;
• address;
• date of birth;
• identification information;
• nationality or immigration information;
• employment or financial information;
• legal or court information;
• medical or health information;
• information relating to children;
• information relating to criminal allegations, offences or proceedings;
• ethnic or racial information;
• religious or other sensitive information;
• documents containing personal information; and
• audio, video or written records containing personal information.
Some information may constitute special category data or information relating to criminal offences and therefore requires additional protection under applicable law.
4. Confidentiality
The interpreter/translator agrees to keep strictly confidential all information obtained through UKLST assignments.
The interpreter/translator must not:
• disclose confidential information to any unauthorised person;
• discuss an assignment with friends, family members, colleagues or other third parties;
• copy or retain client documents unless authorised;
• publish information about an assignment;
• use client information for personal purposes;
• use client information for marketing, training or portfolio purposes without prior
written authorisation;
• post or discuss assignments on social media;
• record an assignment unless expressly authorised;
• photograph or screenshot confidential information unless expressly authorised; or
• use confidential information for any purpose other than carrying out the authorised assignment.
The duty of confidentiality continues after the interpreter/translator's engagement with UKLST ends.
5. Professional Confidentiality
The interpreter/translator must maintain professional confidentiality throughout every assignment.
Where an assignment concerns legal proceedings, healthcare, social services, immigration, education, criminal justice or other sensitive matters, the interpreter/translator must exercise particular care.
Information learned during an assignment must not be disclosed to any person who is not authorised to receive it.
Where an interpreter/translator is uncertain whether information may be disclosed, they must contact UKLST before making any disclosure unless disclosure is legally required.
6. Access to Personal Data
The interpreter/translator must only access personal data that is necessary to perform the authorised assignment.
Access must not be shared with:
• family members;
• friends;
• other interpreters or translators;
• unauthorised employees;
• unauthorised contractors; or
• any other third party.
Login credentials, passwords and authentication information must never be shared.
Where UKLST provides access to an online system, the interpreter/translator must use their own authorised account.
7. Security of Documents and Information
The interpreter/translator must take appropriate technical and organisational measures to protect information against:
• unauthorised access;
• accidental disclosure;
• loss;
• theft;
• destruction;
• alteration;
• copying;
• malware or cyber attack; and
• other unauthorised processing.
Where documents are stored electronically, the interpreter/translator must use appropriate password protection, device security and access controls.
Devices used to access UKLST or client information must be appropriately secured and kept under the control of the interpreter/translator.
Where possible, devices should use:
• strong passwords or passcodes;
• automatic screen locking;
• up-to-date operating systems;
• current security software;
• appropriate encryption;
• secure internet connections; and
• multi-factor authentication where available and required.
8. Email and Electronic Communications
Client and assignment information must only be transmitted using communication methods authorised by UKLST.
The interpreter/translator must take reasonable steps to ensure that information is sent to the correct recipient.
Confidential documents must not be sent to personal or unauthorised email addresses unless specifically authorised by UKLST.
Where confidential information is accidentally sent to the wrong recipient, UKLST must be notified immediately.
9. Remote Working
Where an interpreter/translator works remotely, they must ensure that confidential information cannot be viewed or overheard by unauthorised persons.
This includes taking reasonable precautions when working:
• at home;
• in public places;
• in shared offices;
• in vehicles;
• in hotels;
• using public Wi-Fi; or
• using shared or borrowed equipment.
Confidential telephone, video or remote interpreting sessions must be conducted in an environment where unauthorised persons cannot hear the conversation.
10. Recording
Interpreters/translators must not record telephone, video, face-to-face or remote assignments unless:
1. UKLST has expressly authorised the recording; and
2. the relevant client/authority has authorised the recording where required. Unauthorised audio, video, screen or photographic recording is prohibited.
11. Use of Artificial Intelligence and Translation Tools
The interpreter/translator must not upload, paste, submit or otherwise disclose client or personal information to:
• public AI systems;
• online translation tools;
• publicly available machine-translation platforms;
• generative AI systems;
• online transcription services; or
• other third-party technology
unless UKLST has expressly authorised the particular system and the processing has been assessed and approved.
This includes using confidential documents, names, case details, medical information, legal information or other identifying information as prompts or inputs.
12. Retention and Deletion
The interpreter/translator must not retain UKLST or client information longer than necessary to complete the authorised assignment.
Unless UKLST provides different written instructions, assignment documents should be securely deleted or returned when they are no longer required.
Paper documents containing personal or confidential information must be securely destroyed and must not be placed in ordinary household or public waste.
Electronic information must be securely deleted where appropriate.
13. Data Breaches and Security Incidents
The interpreter/translator must notify UKLST immediately if they become aware of, suspect or cause a personal data breach or security incident.
Examples include:
• sending information to the wrong person;
• losing a laptop, phone or document;
• theft of a device;
• unauthorised access to an account;
• disclosure of confidential information;
• accidental publication of information;
• malware or ransomware;
• unauthorised recording;
• loss of paper documents; or
• unauthorised access to client systems.
The interpreter/translator must provide UKLST with all relevant information necessary to investigate and respond to the incident.
UKLST may need to notify the relevant client, contracting authority or Information Commissioner's Office depending on the circumstances.
14. Data Subject Rights
Where an individual contacts an interpreter/translator regarding their personal data or asks to exercise a data protection right, the interpreter/translator must not respond substantively unless authorised by UKLST.
The interpreter/translator must forward the request to UKLST promptly.
UKLST maintains procedures for dealing with applicable data subject rights, including:
• access;
• rectification;
• erasure;
• restriction;
• objection; and
• data portability.
15. International Working and Transfers Outside the UK
Where an interpreter/translator is located outside the United Kingdom, or where personal data may be accessed from outside the UK, UKLST will assess whether the UK GDPR rules on international transfers apply.
The interpreter/translator must not transfer, disclose or make personal data accessible to another person or organisation outside the UK without UKLST's prior authorisation.
Where an international transfer is permitted, UKLST will ensure that an appropriate transfer mechanism or safeguard is in place where required by law.
This may include an adequacy decision, appropriate contractual safeguards or another lawful mechanism.
The interpreter/translator agrees to comply with any additional data protection or security requirements notified by UKLST in connection with international working.
16. Subcontracting and Delegation
The interpreter/translator must not transfer an assignment to another person without prior written approval from UKLST.
The interpreter/translator must not appoint another interpreter, translator, assistant or subcontractor to access UKLST or client information without prior authorisation.
Where a subcontractor is authorised, UKLST may require appropriate confidentiality and data protection agreements to be completed before access to personal data is provided.
17. Data Protection Training and Compliance
The interpreter/translator agrees to:
• comply with UKLST's data protection policies and procedures;
• maintain confidentiality;
• follow reasonable security instructions;
• complete any data protection or security training required by UKLST or a contracting
authority;
• cooperate with reasonable compliance checks;
• report suspected breaches promptly; and
• keep their contact and compliance information provided to UKLST accurate and up to date.
18. Legal and Professional Obligations
Nothing in this Agreement prevents an interpreter/translator from complying with a legal obligation.
Where an interpreter/translator believes that disclosure of confidential information is legally required, they should, where legally permitted, contact UKLST before making the disclosure.
The interpreter/translator must continue to comply with all applicable professional codes, confidentiality obligations and contractual requirements.
19. Return of Information
At the end of an assignment or upon request from UKLST, the interpreter/translator must:
• return requested documents;
• securely delete electronic copies where instructed;
• securely destroy paper copies where instructed;
• cease access to UKLST systems; and
• confirm compliance where requested.
UKLST may retain information where required by law, contract, regulatory requirements or legitimate record-keeping requirements.
20. Monitoring and Compliance
UKLST may take reasonable steps to monitor compliance with its data protection and information security requirements.
Where appropriate, UKLST may request evidence that an interpreter/translator has complied with confidentiality, security or data protection requirements.
Failure to comply with this Agreement may result in:
• removal from an assignment;
• suspension of access to UKLST systems;
• termination of the interpreter/translator's engagement;
• reporting to the relevant client or authority where appropriate; and/or
• further action where required by law or contract.
21. Privacy Information for Interpreters and Translators
UKLST will process the personal information of interpreters and translators for legitimate and necessary business purposes, including:
• registering and managing interpreters/translators;
• arranging assignments;
• communicating with interpreters/translators;
• verifying identity, qualifications and experience;
• managing payments;
• maintaining business records;
• meeting legal and contractual obligations;
• maintaining appropriate safeguarding and security arrangements; and
• managing compliance with client and public-sector contractual requirements. UKLST will process personal data in accordance with applicable data protection law. Further information is available through UKLST's privacy information and policies.
22. Lawful Basis
UKLST will identify an appropriate lawful basis for each processing activity. Depending on the circumstances, processing may be based on:
• performance of a contract;
• taking steps at the request of an individual before entering into a contract;
• compliance with a legal obligation;
• legitimate interests; or
• consent where consent is genuinely the appropriate lawful basis.
Where consent is relied upon, UKLST will maintain appropriate records of that consent and provide information about withdrawal of consent.
Consent will not be treated as a blanket requirement for all processing where another lawful basis is applicable.
23. Special Category and Criminal Offence Data
Where an assignment involves special category personal data or information relating to criminal offences, additional safeguards will apply.
UKLST will identify the appropriate lawful basis and additional legal condition where required.
Interpreters/translators must treat such information as strictly confidential and must only process it for the authorised purpose.
24. Acknowledgement and Undertaking
I confirm that I have read and understood this Data Protection, Confidentiality and Information Security Agreement.
I agree to comply with UKLST's requirements when handling personal data and confidential information.
I understand that:
1. I must keep all client and UKLST information confidential.
2. I must only access and use information for authorised assignments.
3. I must not disclose information to unauthorised persons.
4. I must not use public AI or translation platforms with confidential/client information unless expressly authorised.
5. I must report suspected data breaches or security incidents to UKLST immediately.
6. I must comply with UKLST's instructions concerning personal data.
7. I must not appoint another person to carry out an assignment or access client information without prior approval.
8. Additional safeguards may apply where information is accessed or processed outside the UK.
9. My confidentiality obligations continue after my engagement with UKLST ends.
10. Failure to comply with these requirements may result in termination of my engagement and/or other appropriate action