Privacy Notice
Introduction
Data protection is concerned with safeguarding the privacy rights of individuals in relation to the processing of their personal data. Personal data is defined under GDPR (General Data Protection Regulation GDPR 2018) as any information relating to a living individual who can be identified or is identifiable. This may include details such as your name, location data, voice or image recordings, among others.
This Data Privacy Notice relates to how DCU Language Services processes Personal Data in relation to the linguistic services it provides which includes, but is not limited to translation, audio transcription and interpreting, how it manages communications, and how it fulfils its legal or contractual obligations.
Data Controller
Dublin City University (DCU) is the Data Controller responsible for processing your personal data in connection with projects carried out by DCU Language Services.
Contact
Cláudia Buttura, Translation Services Manager
translations@dcu.ie
01 700 8077 | 01 700 8066 | 085 260 6203
Categories of Personal Data Collected and Processed
In order to fulfil the services, the following categories of personal data are collected, created, or processed:
- Names
- Email addresses
- Phone numbers
- Postal addresses
- Personal data contained within text documents and scanned documents submitted by clients for translation
- Personal data contained within audio files submitted by clients for audio transcription
Nature of Processing
Personal data will be processed through the following steps:
1) Recording: temporarily retaining client contact information (name, surname, email address, and postal address if needed for project delivery) in our project database solely for the communication purposes and for fulfilling the requested project.
2) Transcription: audio files are converted into written text. This process is entirely human-based, and no transcription software or automated processing is used. Translation: written materials are translated preserving the content of the original text.
3) Proofreading and quality review: translated materials are reviewed and corrected for accuracy.
4) Secure delivery: completed translations, proofread materials and audio transcriptions are returned to the client.
Legal Basis for Processing
DCU processes your personal data primarily under the following legal basis: for the performance of contractual services and legitimate business interests, including responding to ad-hoc requests and contractual requests, and completing and delivering translation, proofreading, and audio transcription services as required.
Data Sharing
Data is shared amongst the project team (e.g., Project Managers, Language Services Administrators, Linguists and Graphic Designers, as applicable) solely for the purpose of fulfilling clients’ project goals.
Data Retention
DCU LS adheres to the principle of storage limitation, retaining personal data only for as long as necessary for the purpose for which it was processed.
- Translated and proofread materials are retained for three years from the date of project delivery under a project reference number, unless the client requests a different retention period.
- Private customer details retained for communication purposes (name, surname, email address, telephone number, and postal address if applicable) are anonymised immediately upon project completion.
- Voice recordings and other audio files are securely deleted immediately after delivery of the transcription. Transcriptions(text files) are retained for three years from the date of delivery, unless the client requests a different retention period.
Data Security
DCU takes all reasonable measures to ensure that personal data is retained securely and is protected from accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. Measures include secure internal storage systems with appropriate access controls and reliance on contractual agreements (Data Processing Agreements) with third-party processors that mandate specific security standards.
1) Confidentiality Agreements
– All in-house team members and freelance partners are bound by non-disclosure agreements.
– When required by clients, our team and freelancers can sign Official Secrets Act 1963 Declarations.
2) Access Control
– Use of Microsoft Multi-Factor Authentication (MFA) to secure account access.
3) Data Encryption
– All translations and communications are encrypted by default.
– Translations are processed in a secure Translation Management System (TMS) certified to ISO 27001 standards.
4) Network and Cybersecurity Monitoring
– Our network is continuously monitored for viruses and other security threats.
– Staff receive monthly cybersecurity training to stay up to date with best practice.
Your Data Protection Rights
Under data protection law, you have certain rights regarding your personal data. DCU is committed to facilitating these rights. The rights available to you are:
- Right to be informed: You have the right to be informed about how your personal data is processed. This Privacy Notice provides you with this information.
- Right of access: You have the right to request a copy of the personal data DCU holds about you. You can make a Data Access Request to the DCU Data Protection Officer.
- Right of rectification: You have the right to correct inaccurate or incomplete personal data held by DCU.
- Right to erasure: In certain circumstances, you can ask for your personal data to be erased.
- Right to restriction: You have the right to restrict the processing of your data where certain conditions apply.
- Right of portability: This right applies to data processed based on consent or contract. As processing for this project is based on public interest, the right to data portability generally does not apply.
- Right to object: You have the right to object to processing of your data. Any objections will be handled in accordance with DCU procedures.
- Right to object to profiling or automated decision making: You have rights regarding decisions based solely on automated processing that produce legal or similarly significant effects.
How to Exercise Your Rights, Queries, and Complaints
Should you wish to exercise any of your data protection rights, or if you have any queries or concerns about how your personal data is processed in connection with this pilot project, please contact the DCU Data Protection Officer. While you have the right to lodge a complaint with the Irish Data Protection Commission (DPC), we encourage you to contact the DCU Data Protection Officer in the first instance to allow us the opportunity to address your concerns directly.
Contact Information DCU Data Protection Officer
Mr. Martin Ward
Email: data.protection@dcu.ie
Postal Address: Data Protection Officer, Office of the Chief Operations Officer, Albert College, DCU Glasnevin Campus, Collins Avenue Extension, Dublin 9, D09 V209.
For general information on how DCU collects, uses, and discloses personal data, as well as your data protection rights, please refer to the full DCU Data Privacy Policy, available on the DCU website.
Policy Review
This policy will be reviewed as required by changes in legislation or business practice. This section of DCU Language Services’ website is administered by DCU Language Services’ Marketing Team in accordance with Dublin City University’s Data Protection guidelines. At Dublin City University, the Data Protection Unit within the Office of the Chief Operations Officer is responsible for creating and maintaining data protection policies throughout the university and those relating to our campus company.