Third Country Data Transfer Policy
Transfer of Personal Data to Third Countries
Robertson Languages International, which is part of the Wolfestone Holdings Group, is committed to providing quality language services.
The best people to provide these services are based in the countries where those languages are spoken, as full immersion means that they keep up with the changing way the language is being used and retain fluency. Moreover, we are more likely to have available linguists working in this language in these countries than in other countries.
Not all of these countries will be within the EU or on the list of countries deemed as adequate by the European Commission – China, India, Japan, UAE, for example, are not on the list.
Article 49 of the GDPR allows for data transfer outside of the EU under specific situations, and these are the clauses by which we operate as a language services provider if a document for translation contains personal data.
Our basis for this transfer would be one or more of the following clauses from Article 49:
- the transfer is necessary for the performance of a contract between the data subject and the controller or the implementation of pre-contractual measures taken at the data subject’s request;
- the transfer is necessary for the establishment, exercise or defence of legal claims;
(e.g. if you are a legal firm operating on behalf of your client)
- the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent;
(e.g. if the documents are to do with a social work to do with children or vulnerable adults)
Before we send any documents to linguists outside the EU, we will inform you, in accordance with clause a) that this is what we will be doing:
- the data subject has explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfers for the data subject due to the absence of an adequacy decision and appropriate safeguards;
If the files contain personal data, it is up to you to inform the data subject that their data may be transferred outside the EU and adequate countries in order for the contract to be fulfilled, and gain consent for that.
All of our linguists in all countries will be operating under a strict set of rules regarding data privacy and security, and all of our transfers will be carried out with protection measures in place (see here for our Information Security Policy)
If, for any reason, the data subject does not consent to us sending the data to linguists based in third countries, we will of course look into alternative suppliers based in the EU or adequate countries to carry out the work. This may affect turnaround timeframes.
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