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.