NEWS/BLOG

Introduction

At Clear Voice we are committed to protecting your privacy and being transparent about how we use your data. We will only use the information we collect about you lawfully in accordance with UK Data Protection Law which includes the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA). This, together with our website terms and conditions, tells you about what we collect and how we use and store your personal information. For the purposes of this notice, Clear Voice acts as a data controller.

If you have any queries about our privacy statement, please contact us on info@clearvoice.org.uk

Clear Voice is the trading name of Migrant Help Trading Limited which for the purposes of the law is the Data Controller. All profits go back into its parent charity Migrant Help. Where Clear Voice provides its services to clients it may act as a data processor in accordance with the UK GDPR article 28 clauses. These clauses can be found in the terms and conditions and the purposes for processing the personal data in Annex A of those terms.

Clear Voice’s expertise offers:

• Comprehensive range of languages
• Fast and easy to use service
• Culturally sensitive approach
• Professional, reliable and experienced linguists
• Ethical choice – all profits go back into the Migrant Help charity

How we collect information from you

Clear Voice provides the following core services:

• Face to face interpreting
• In-app telephone interpreting
• Instant telephone interpreting
• Remote video interpreting
• Transcription services
• Translation services

Services can be accessed and/or booked via telephone, app, email and website portal.

Some of the information you give to us will be held on central systems and accessed by authorised staff only.

We may also process personal data of our contractors and those that apply to work for us and staff members.

Transferring data outside the UK

Where data is transferred from the UK to an adequate Country or to a third country, in accordance with the UK adequacy regulations (details of which can be found here), we will ensure such transfers are protected by suitable and appropriate safeguards such as the UK International Data Transfer Agreement. This may be subject to a Transfer Risk Assessment. Any changes to these requirements in the UK will be reflected in updated versions of this notice so please revisit this site to ensure you are informed of any amendments we may make.

What personal data we collect and how we use it

Any information we collect about you will:

• Be obtained and processed fairly and lawfully and shall not be processed unless certain conditions are met
• Be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with that purpose
• Be adequate, relevant and not excessive for those purposes
• Be accurate and kept up to date
• Not be kept for longer than is necessary for that purpose
• Be processed in accordance with the data subject’s rights
• Be kept safe from unauthorised access, accidental loss or destruction
• Not be transferred to a country outside the European Economic Area, unless that country has equivalent levels of protection for personal data or where suitable safeguards exist.

The type and quantity of information we collect and how we use it depends on why you are providing it.

Customers and organisations

Customers and organisations requiring an interpreting/translation service from Clear Voice must complete an Account Registration form or in some cases sign a contract.

If you receive a quote, book, use or purchase a service with Clear Voice, we will collect and store this onto our secure database.

Data and documentation will be retained for a period of seven years beyond the last date of entry on the records. Any paper documentation is disposed of by secure shredding. Electronic files will be deleted securely by the IT Department.

Suppliers

New suppliers will complete a Contract of Supply. The Contract, application forms, references, contact details and bank details are kept electronically. Suppliers will act as a data processor to Migrant Help Trading Limited acting as the data controller.

Once the contract is complete, documentation will be retained for a period of seven years beyond the last date of entry on the records. Some information may be kept for a different period of time. Any paper documentation is disposed of by secure shredding. Electronic files will be deleted securely by the IT Department.

Making a Complaint

Clear Voice has a complaints procedure for their services. Complaints must be reported in writing either via an email or using the contact us form which can be found on the website.

You may also complain to the Information Commissioner’s Office (ICO) who regulate information rights in the UK. For further details about this, please visit their website: https://ico.org.uk/make-a-complaint/

If you reside outside of the UK, you will need to consult your local regulator.

How we keep your data safe and who has access

Clear Voice ensures that there are appropriate technical controls in place to protect your personal details. For example, our online forms are always encrypted, and our network is protected and routinely monitored.

We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained personnel.

We may use external companies to collect or process personal data on our behalf. We do comprehensive checks on these companies before we work with them and put a contract in place that sets out our expectations and requirements, especially regarding how they manage the personal data they collect or have access to.

If you have any queries about this statement, please contact us at Clear Voice, 128 City Road, London, EC1V 2NX or email info@clearvoice.org.uk

Retention of personal data

We are required to retain records of our business activities, and this may include personal data. The retention of personal data is likely to be governed by a statutory obligation. Where this is not the case, we may retain the information in accordance with our records of processing activity and internal procedures. For example, where we engage a contractor, we will retain the information for up to seven years according to our contractual obligations. Information that may identify a client who uses our services may be retained for 12 months after the service has been provided. Other retention periods may apply. If you would like further details about this, please contact us at info@clearvoice.org.uk.

Your right to know what data we keep, how to make changes or ask us to stop using your data

Customers have the right to access any personal data that is being kept about them by Clear Voice.

• Any private client who wishes to exercise this right should contact the Director in writing using info@clearvoice.org.uk
• The organisation aims to comply with requests for access to personal information as quickly as possible but will ensure that it is provided within one month as per the UK GDPR guidelines. This can be extended where requests are complex or numerous, but the individual must be notified within one month of the receipt of the request and given an explanation why the extension is needed.

Other important information rights include:

• The right to erasure. This right enables you to request us to delete your records. Some exclusions may apply. 
• The right to be informed. You have the right to know what data we are processing and why.
• The right to question automated decision made about you. We do not currently make such decisions.
• The right to have inaccuracies concerning your personal data rectified. If you believe any of the information, we hold about you is inaccurate please get in touch with us at info@clearvoice.org.uk
• The right to object. You have the right to object to our handling of your personal data. Again, I you have any concerns please get in touch.

Lawful Basis

Under the DPA we process data under the “conditions for processing”. Under the UK GDPR, this is our “lawful basis” for processing personal data. This policy documents our lawful basis. The lawful basis for processing data can include:

a. Consent of the data subject
b. Processing is necessary for compliance with a legal obligation
c. Processing is necessary to protect the vital interests of a data subject or another person
d. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
e. Processing is necessary for purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject.

The conditions for special categories of data, formerly known as sensitive data are:
a. Explicit consent of the data subject, unless reliance on consent is prohibited by UK data protection law
b. Processing is necessary for carrying out obligations under employment, social security, social protection law or a collective agreement
c. Processing necessary to protect the vital interests of a data subject where the subject is incapable of giving consent
d. Processing is necessary for the establishment, exercise or defence of legal claims
e. Processing is necessary for reasons of substantial public interest
f. Processing is necessary for the assessing the working capacity of the employee
g. Processing is necessary for reasons of public interest in the area of public health

Legal basis for processing

We rely on the following lawful basis for processing personal data where we act as a data controller:

• Providing some services to customers – Contractual obligation/Legitimate interest.
• Evaluate service delivery – Legitimate interest.
• Market to potential customers – Legitimate interest or Consent.

In regard to special categories, we will seek consent to collect, store and process their data unless we rely upon schedule 1 or 2 of the Data Protection Act 2018. Where required an appropriate policy document may be in force.

Where we act as a data processor and on behalf of our customer acting as the data controller, we will rely upon the lawful basis we are instructed to use to process the personal data.

In addition, in regard to special categories, processing is necessary for the establishment exercise or defence of legal claims.

Wherever we may use our Legitimate Interest to process personal data, you may object to such processing. If you wish to object, please contact us at info@clearvoice.org.uk

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