DATA PROTECTION POLICY
Welcome to IMD Legal Translation and Interpreting Ltd Data Protection Policy.
IMD Legal Translation and Interpreting Ltd is committed to protecting and respecting your personal information. This Data Protection Policy aims to provide a comprehensive overview and explain how we collect and use any personal information and data we may obtain from you and about you.
Purpose of this Data Protection Policy
This Data Protection Policy aims to give you information on how IMD Legal Translation and Interpreting Ltd collects and processes your personal data through your use of our website, any data you may provide when you purchase a product or service or any data you provide to us during our business relationship.
This Data Protection Policy also supplements our Privacy Notice which specifically applies to our employees or self-employed contractors. You can ask for a copy of this Privacy Notice. If you provide your personal data for the recruitment purposes or otherwise in joining us as an employee or contractor, we ask that you refer to our Privacy Notice.
We may update our Data Protection Policy from time to time. If we do so, we will communicate any changes to you and will publish the updated Data Protection Policy on our website. We do encourage you to visit our website regularly to stay informed of any changes.
Who we are
IMD Legal Translation and Interpreting Ltd is the controller and is responsible for your personal data (collectively referred to as "we", "us" , "our" or “the firm” in this Data Protection Policy).
Our registered office and principal address is located at Suite 1N-C, Trafford House Chester Road Manchester M32 0RS however this Data Protection Policy also applies to all of our satellite offices.
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Data Protection Policy. If you have any questions about this Data Protection Policy including any requests to exercise your legal rights please contact the DPO using the details below:
Mr Marcin DurlakIMD Legal Translation and Interpreting Ltd Suite 1N-C, Trafford House,Chester Road,Manchester,M32 0RSe-mail address: ku.oc.noitalsnartdmi%40opdtelephone number: (0044) 330 912 1530
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We collect and process a variety of personal information which we have grouped together as follows:
Identity information which includes your current full name, any previous names, title, date of birth, gender, marital status and copies of any identity documents that we obtained as proof of your identity;
Contact information which includes your current postal address, any previous addresses, your e-mail address and your telephone number and copies of any documents we have obtained as proof of your address;
Financial information which includes your bank account details, credit and / or debit card details, copies of your financial statements, results of any credit referencing enquiries, details about your assets and liabilities and details about your current and previous financial circumstances;
Education and employment information which includes your current and previous education and employment details.
Video and / or photographic images which includes copies of your identity documents or any other photographs together with any CCTV images that we may hold;
Service information which includes information about which services we provide you with and services you have previously inquired with us about;
Marketing and communications information which includes your preferences in receiving marketing from us and your communication preferences;
Technical information and usage information which includes your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, website navigation, metadata associated with sending information through our website and interaction with our website and our posts on various social media and other platforms;
Any other personal information that you chose to disclose to us.
We obtain, collect and process a variety of categories of personal information at the start, throughout and after your contractual or other relationship with us. Whilst we may hold a variety of information about you, we do try to limit the collection and processing of information to what is necessary to achieve one or more of the legitimate purposes as is explained further in this notice.
We may also process special certain categories of information for specific and limited purposes, such as prevention of fraud and crime or where this information is critical to the service that we provide you with. We will only process these special categories of information where we have your explicit consent, are lawfully permitted to do so or are obligated to do so by law.
The special information that we collect and process may include:
Information about your physical and mental health together with copies of your medical records and medical reports;
Information about your criminal record or previous convictions;
Information about racial or ethnic origin;
Information about your political, religious or philosophical beliefs;
Information about your sexual orientation;
Information about your membership of any trade unions;
Any other special information that you chose to disclose to us that would fall within the special information category.
In most cases we will hold this information because it is necessary for us to do so in order to provide you with our service.
We also collect and use what is known as aggregated data for any purpose. Aggregated data may be derived from your personal information however it does not reveal your personal information either directly or indirectly. For example, we may use aggregated data to calculate a percentage of our customers using a particular service or website.
How is your personal data collected?
We obtain your personal information in a variety of ways including:
Information that you give us whether it is whilst contacting us or throughout our contractual relationship;
Information we receive from third parties including any of our partners (where permitted by law) or associates or credit referencing or fraud prevention or government agencies;
Information we learn about you through our contractual relationship as we are carrying out the service in accordance with our contractual relationship;
Information that we gather from publically available sources such as various public registers, online search engines and associated websites and any virtual or physical media;
Information that we gather from technology about how you access our services and your interactions with our various media posts such as via Google analytics and Facebook analytics as well as your Technical information and usage information.
Your personal information may also be provided to us by our current or prospective client. In most such cases this personal information will be provided to us in a legal matter and will therefore be protected by litigation privilege and / or legal privilege and will therefore not be subject to rights in accordance with this privacy notice.
How we use your personal data
We will only use and share your information where it is necessary for us to carry out our services and in connection with our lawful activities. So that you can fully understand how your personal information we be used we have detailed the purposes for which your information may be used below.
You have the right to withhold your personal information (subject to this not misleading us) or in some cases request that this information is not used as detailed below however unfortunately in most cases if you fail to provide or agree to us processing the personal information that we require we are unlikely to be able to provide you with our services. In addition we may still be obliged to disclose the information we hold in accordance with our legal obligations.
1. Contractual necessity in order to provide you with our services
Where we have entered or about to enter into a contract with you it will be necessary of us to process your personal information in order to perform our obligations under the contract. This may include processing your personal information in the following ways:
Communicating with you about the service that you have received from us;
Managing and maintaining our relationship with you and providing on-going customer service;
Providing services and carrying out your instructions throughout our contractual relationship including preparing documentation and correspondence for you and on your behalf, executing your instructions, transferring funds on your behalf, contacting various third parties on your behalf and resolving any queries;
Disclosing your personal information to third parties such as: legal services providers, accountants, tax advisors, external translators, external interpreters, external transcribers.
Assessing your requirements and proposing a translating or interpreting or other service in line with your requirements;Confirming your identity.
2. Legal obligations that are placed on us by various authorities
Were you have contacted us about our services or where you have entered into a contractual agreement with us, we are required by law to collect and process certain personal information about you. This may include processing your personal information in the following ways:
Investigating and resolving complaints;
Conducting investigations into potential breaches of conduct and policies by our employees;
Managing contentious regulatory matters;
Notifying our insurers in cases of incidents or emergencies on our premises or in cases of regulatory or contractual breaches;
Notifying you of any changes to our policies or terms and conditions and complying with your requests where you have exercised your rights as detailed in this privacy notice;
Confirming your identity using the information and documents that you have provided;
Performing checks against various external databases such as sanctions lists and lists of politically exposed persons;
Sharing information with law enforcement agencies and other authorities and regulators, including reporting suspicious activities, where we have a legal obligation to do so;
Sharing information with third parties where we have been ordered to so by the court or it is required by any statutory or legal instrument.
3. Legitimate interest of the firm.
We may also process your information where it is in our legitimate interest to do so as a firm. We will do this without prejudicing your fundamental rights and freedoms. This may include processing your personal information in the following ways:
Ensuring that we are providing you with the service your require;
Identifying any other services that we believe will be of interest to you and sending you marketing information in respect of these services;
Identifying translating or interpreting services that may be of your interest and sending you newsletters in respect of these services;
Developing our relationship with you;
Understanding your needs, actions, preferences and expectations in order to improve our service and to develop new services;
Assessing the quality of service that we have provided and analysing any complaints that you have made in order to improve our service and to address any staff training needs;
Compensating you for loss as a result of any regulatory or service level failures;
Monitoring and processing your information in order to monitor and improve our business processes and information solutions to ensure business continuity and continuing information security;
Performing financial, regulatory and general accounting and reporting;
Performing risk reporting and risk management;
Protecting our rights and interests by carrying out debt tracing and recovery.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Sharing your personal information with third parties
We will not share your personal information with anyone outside the firm except:
Where we have your express permission to do so; or
Sharing your personal information is contractually necessary for us to provide you with our services; or
We are legally obliged to share your personal information; or
Sharing your personal information falls within the legitimate interests of the firm, such as for the purposes of debt tracing and debt recovery.
In addition, as we operate a paperless office, we will share your information with the provider of our management system software who will retain your information for our exclusive use and access. Our management system software provider will only store your information and will not use it for any reason other than to hold the information on our behalf.
We will not usually transfer your personal data outside the UK unless doing so is necessary in order to carry out our contract with you unless you are based outside the UK.
In the event that we must transfer your personal information outside the UK, we will only do so if one of the following conditions is met:
You have provided your express consent;
The relevant country has been deemed to provide an adequate level of protection for personal information by the UK;
Where we use a service provider, we have entered into a contract on the terms approved by the UK which gives personal information the same level of protection as it has in the UK.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at ku.oc.noitalsnartdmi%40opd
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us at: ku.oc.noitalsnartdmi%40opd
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Unless you have told us that you do not want to hear from us in relation to services that we consider are of interest to you, we will send you relevant marketing information by mail, phone, email and other forms of electronic communication.
If no longer want us to contact you with marketing information, please contact our DPO with your request and we immediately stop processing your information in this manner.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
We use both session and persistent cookies on our website. The names of the cookies that we use on our website are:
Google Analytics (ga, gat, uta, utmt);
Most browsers allow you to refuse to accept cookies; for example:
in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
in Firefox (version 44) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
in Chrome (version 48), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.
Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you may not be able to use all the features on our website. You can delete cookies already stored on your computer; for example:
in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);
in Firefox (version 44), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking "Remove All Cookies"; and
in Chrome (version 48), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug -in data ”before clicking“ Clear browsing data.
Deleting cookies will have a negative impact on the usability of many websites.