Data Protection and Privacy Policy
This Privacy Policy applies to Personal Data we hold about individuals. It does not apply to information we hold about companies and other organisations.

Introduction
Smart Planning UK  is the trading name for Smart Translations Limited (“SPUK”, “we”, “us”), a leading provider of multilingual translations and language consultancy to private and public companies, as well private individuals seeking an attentive and personalised service. We are Full Member of ATC (Association of Translation Companies in UK) since 1993 and comply with its Code of Professional Conduct.
Confidentiality is important to us. You can rely on us to keep your details confidential and to meet all the obligations under General Data Protection Regulation (Regulation EC 2016/679 “GDPR”) in the European Union (“EU”) and in the UK. We’ll only show details of our clients, and linguists and other professionals to third parties, such as accountants, for legitimate operational or administrative needs.  We’ll share your details if we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings or prospective legal proceedings.

We keep this Privacy Policy under regular review and update it from time to time.
This policy was last updated in May 2018. Please review this policy periodically for any changes.

You have the right to modify, or have your data removed from our database, at any time by updating your Data Preferences.
You can access and browse our website without disclosing your personal data.
We ask our linguists and specialist consultants to keep the content of texts to be translated and any other related information confidential, as well as any details we receive from our clients and require all parties involved not to disclose them to anyone else.

Where you give us Personal Data on behalf of someone else, you confirm that you have provided them with the information set out in this Privacy Policy and that they have not objected to such use of their Personal Data.

Who this policy applies to
We provide language services (“our services”) to a range of clients throughout the world. Details of our services can be found elsewhere on our website and our LinkedIn page. This policy applies to you whether you are a candidate for an assignment for one of our clients, an individual we are assessing for future engagement, an existing or prospective client, or whether you are a source or a referee in respect of a linguist or other specialist.

Additionally, this policy will apply to you if you attend one of our events or have subscribed to receive information about our services or any of our marketing materials.

For the purposes of this policy:
candidate(s) means an individual who is a candidate, applicant, potential candidate for a work assignment;

linguist(s) and other professional(s) means any translator or interpreter, as well as any specialist professional (medical doctor, banker, architect, journalist and so on) with whom we interact for the execution and completion of an assignment.
 
client(s) means any business, firm, organisation, government body or individual that mandates us to perform any of our services;

a referee is a person who provides a personal or work reference in respect of a candidate; and

a source is a person or organisation who provides us with information or intelligence about a candidate or a client (Companies House, Chamber of Commerce, industry associations).

Gathering information
Our clients expect that we identify the best professionals to carry out a task. So, we need to research systems, online databases and other information sources, and talk to individuals, including referees and sources to help inform our decision-making process.
The nature of our work means we are required to process personal data quickly, confidentially and often without reference to the data subject. Accordingly, we process such data in accordance with the Data Protection Laws, regularly using our legitimate interest where it is not possible or feasible to speak directly with the data subject. Beyond this, we will seek consent in the circumstances explained later in this policy document.
We collect information from candidates directly when we receive a CV or resume. We also collect information from clients when we receive content and instructions.

Your personal data

The internet
Please remember that communications over the internet, such as emails and webmails (messages sent through a website), are not secure unless they have been encrypted. Your communications may go through a number of countries before they are delivered – this is the nature of the internet. We cannot accept responsibility for any unauthorised access or loss of Personal Data that is beyond our control.

Clients as private individuals
We may occasionally email you about our services, send newsletters, ad-hoc communications, seasonal greetings. When you first give us Personal Data through our Website or by e-mail, we will normally give you the opportunity to say whether you ‘opt in’ to be further contacted by us, whether by email, phone or chats. You can also always send us an email at the address set out below at any time if you change your mind.

The data we hold might include some or all of the following: your contact details, scanned images of your passport and identity documents, academic achievements, work history, skills, nationality, languages, working rights, criminal records, medical records, bank details, age and gender, all provided voluntarily to us as subject matter of assignments, as content to be translated, and/or as legitimate information for accounting purposes. Additionally, we keep a record of our contact history with you including price and progress on any translation or language consultancy you requested from us.
We retain any data you voluntarily provide to us to prepare a cost estimate or assign us a translation or language consultancy, for a limited time; such time is specified in our offer or, in any case for no longer than 2 years from completion of the assignment, unless needed for accounting/legal reasons.
When we interact with you we are committed to giving you a personalised service that meets your needs in a way that also protects your privacy.

Linguists and other professionals
We collect the personal data that you volunteer to us when offering to collaborate with us and proposing your services, and/or you apply to jobs/roles online. We may also collect information from public sources such as translators’ and professional  associations, LinkedIn or internet searches. We might also contact referees that you indicated to us, to get better knowledge of your work experience. We use this data to identify you when we have assignment opportunities that might be relevant to you.

The data we hold might include some or all of the following: your contact details, academic achievements, work history, skills, nationality, languages, working rights, age and gender, all provided voluntarily to us in order to be accredited among our linguists or other suppliers, and/or as legitimate information for accounting purposes. We will also hold information on your fees and bank and/or means of payment details if you have provided to us, as well as notes we take during our collaboration. Additionally, we keep a record of our contact history with you including progress on any assignments you have applied for or been selected for.
We retain the documents that you have provided to us such as your most recent CV, work related records, introductory letters, samples of written work and so on. We routinely delete obsolete CVs that you might have provided to us in the past.

If you register your interest with us directly or through a job application portal, please do keep your details up to date, and notify us of any changes to your personal data. You can do this by updating your profile, or by contacting us using the details below.

Use and processing of your personal data
SPUK is the Data Controller for your personal data. SPUK processes your personal data on the lawful basis of legitimate interest as a specialised language service provider.

Data is stored on a secure, proprietary and confidential database which is only accessible by members of SPUK for operational, administrative, accounting and legal purposes.

Clients as private individuals
As a Client, by providing SPUK with your personal data, you are giving your consent for SPUK to identify you and contact you about developments in our business practice, send you newsletters, general updates, invites to events, and seasonal greetings.
You can unsubscribe from our electronic messages by following the “unsubscribe” instructions included in our communications.
From time to time, we may contact you with updates on our services, terms of business or simply to ensure that the data we hold is current, relevant and up to date.

SPUK may aggregate and anonymise personal data for industry or marketing reports or for statistical purposes.

If you provide false or inaccurate information to us and we suspect fraud, we will record this and may share it with other people and organisations. We, or other credit and insurance organisations, may also use technology to detect and prevent fraud.


 

Linguists, specialists and other suppliers

As a linguist or specialist, by providing SPUK with your personal data, you are giving your consent for SPUK to identify you and contact you about work opportunities that may be relevant to you. Please note that no automated decisions, such as computerised candidate profiling, are made on the basis of the information we collect. You also give your consent for SPUK to identify you and contact you about developments in our business practice, send you newsletters, general updates, industry news, and seasonal greetings. You can unsubscribe from our electronic messages by following the “unsubscribe” instructions included in our communications. SPUK may aggregate and anonymise personal data for industry or marketing reports or for statistical purposes. If you provide false or inaccurate information to us and we suspect fraud, we will record this and may share it with other people and organisations. We, or other credit and insurance organisations, may also use technology to detect and prevent fraud.

Your rights
You have the right to obtain access to your data record, to challenge the data that we hold about you and have the data erased, rectified or amended. Upon written request, we will provide you with a readable copy of your data record although, according to our security procedures, we may require proof of your identity before we disclose personal information to you, and require a minimum of 10 working days to provide the data. There may be a nominal charge of £12 incl. 20% VAT to cover administrative costs.
You have the right to modify or have your data deleted at any time by updating your Data Preferences or contacting us at any time by email at GDPR@smartplanninguk.com.
We aim to keep the Personal Data we hold about you accurate and up to date. If you tell us that we are holding any inaccurate Personal Data about you, we will delete it or correct it promptly. Please email us at GDPR@smartplanninguk.com or write to us at the registered address above to update your Personal Data.

Keeping your data records
We keep your personal data for as long as required to provide our services, and in accordance with legal, tax and accounting requirements. Where your personal data is no longer required, we will ensure it is disposed of in a secure manner.

Deleting your data record
As a Client, when you request that your data is deleted, SPUK will hold a record of such request and will not process your data, nor will we contact you with information on our business developments, or with marketing materials.
Please allow ten working days for your data to be deleted. A record of your deletion request will be kept by our data administrator.
Only records needed for legal/accounting reason will be kept.
You can contact SPUK at any time and communicate your data by writing to GDPR@smartplanninguk.com providing your consent for us to process your data.
Once your data is deleted, we cannot guarantee that we will not contact you again in the future through public data sources such as LinkedIn or internet searches.

As a Linguist, when you request that your data is deleted, SPUK will hold a record of such request and will not process your data, nor will we contact you with information on our business developments, information on current or future work opportunities or marketing materials.
As your data at SPUK is deleted, you will also become excluded from any current or future roles and work opportunities.
Please allow ten working days for your data to be deleted. A record of your deletion request will be kept by our data administrator.
Only records needed for legal/accounting reason will be kept.
You can contact SPUK at any time and communicate your data by writing to GDPR@smartplanninguk.com providing your consent for us to process your data.
Once your data is deleted, we cannot guarantee that we will not contact you again in the future through public data sources such as LinkedIn or internet searches.

Data security and integrity
We store your personal data on our secure, highly confidential database, which can only be accessed by SPUK members and consultants. All those who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of your personal data.
We have implemented security policies, rules and technical measures to protect the personal data that we have under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.
A copy of your data (in full or in part) may be stored at a back-up Cloud, currently OneDrive and Carbonite. We ensure that your personal data will not be disclosed to institutions and authorities except if required by law or other regulation.
We may sometimes be required to disclose information about you to law enforcement bodies, agencies or third parties, under a legal requirement or court order. We will act responsibly and take account, where possible, of your interests when responding to these requests.

Information about others
If you provide us with information about other individuals, like details of a referee or personal contact, you must ensure they have agreed to this. We would advise you to keep a record of their agreement and provide them with a copy of, or link to, this Privacy Policy.

Our website smartplanninguk.com
All information and copyright incorporated within our website smartplanninguk.com is the property of Smart Planning UK and any unauthorised reproduction is prohibited.
We use reasonable care in compiling the information found on this website. However, it can change without notice and you should seek guidance before relying on it. We make no representation or warranty regarding the completeness or accuracy of this information and disclaim all and any liability arising from its use. By using this site, you accept that the information it contains may be incomplete or inaccurate. You irrevocably agree that the courts of England shall have exclusive jurisdiction to hear and decide any suit, action or proceedings, and/or to settle any disputes, which may arise out of or in connection with this website and for these purposes each party irrevocably submits to the jurisdiction of the competent court in London (England under English Law).
Our website does not enable our visitors to communicate with other visitors or to post information to be accessed by others.

Analytics
We use analytics tools and cookies on our website to help deliver our online services, identify any service issues, improve our services, provide content tailored to users' personal preferences, and to monitor site traffic and usage.

These tools may be provided by third-party service providers and may include the collection and tracking of certain data and information regarding the characteristics and activities of visitors to our website. We may disclose data, including personal data, to certain third-party services providers in order to obtain such services.

One of these providers is Google Analytics. More information about the ways in which they collect and process your personal data can be found here: www.google.com/policies/privacy/partners.   You can opt-out of Google Analytics here: tools.google.com/dlpage/gaoptout

Cookies
Cookies are small computer files which are downloaded onto your device when you browse the web. They collect information about the way in which you navigate and use a website and the wider web. This information may allow us to identify you or your approximate location. Cookies also help us provide you with a more personal experience, like a local version of the website in a local language. Information from cookies also allows us to make improvements to our services.

We might only collect "session" cookies, which are not usually stored after your browsing session has ended. These are used to establish your approximate location and to serve up the website in an appropriate language.

You may delete and block all cookies, or just certain types of cookies, via your browser settings. However, if you choose to block or delete cookies, this may affect the functionality of the website.

Third party websites
This Policy only applies to this website. If you land on our site from other websites or move to other ones from our website, you should read their separate privacy policies.

Complaints procedure
If you have a complaint about how we have handled your personal data, contact us using the details below, and we will investigate your complaint. Please use the same contact details to instruct us to cease processing your personal data.

Contacting us
If you have any questions about this Privacy Policy, or would like to exercise your rights with respect to your personal data, please contact us at GDPR@smartplanninguk.com, or write to:  Smart Planning UK with registered office at 51 Cranleigh Road, Merton Park, London SW19 3LX

Changes to our Data Protection and Privacy Policy
SPUK reserves the right to modify or amend the Data Protection and Privacy Policy at any time and for any reason so long as permitted by applicable law.
Last Updated: 22 May 2018

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