How I process your personal data
Who is the data controller?
For the purposes of the General Data Protection Regulation (GDPR), the data controller is me, Martin Naylor (“I”, “me”), operating as a sole trader with the business name Översättningsfirma M N Naylor (M N Naylor Translations) (“my business”).
Address: Betgatan 11, 754 49 Uppsala, Sweden.
Phone: +46 18 256649. Email: email@example.com
What personal data do I process?
I process the following types of personal data:
- Contact information – name, postal address, email address and/or telephone number – and any other information you yourself provide when you contact me, e.g. to make an enquiry about a translation, language editing/proofreading work or interpreting, or when you order such a service from me.
- Any personal data that may be included in the text you wish to have translated/edited/proofread, in preparatory material for an interpreting assignment, or in any other text or information material which you make available to me and which is needed to provide the service in question.
No personal data is collected via this website, using cookies or by any other means.
You can read about how I process your personal data in the text below.
What are the purposes for which your personal data is processed?
I process your personal data for the following purposes:
- to be able to deal with email and other communications from you and assess whether further processing of your personal data is necessary and, if so, for what purposes and on what legal bases,
- to be able to respond to enquiries from you about my services,
- to be able, at your request, to give you a quotation and inform you about delivery dates etc.,
- to be able to enter into and administer a contract with you for my services,
- to be able to provide you with the agreed services,
- to be able to update your contact information, where necessary,
- to be able to follow up services you have ordered (e.g. deal with any complaints),
- to be able to invoice services provided and retain the invoice and other material forming part of my business’s accounting records (this only applies to contact information – usually, your name and postal address or telephone number – and a brief description of the service provided).
Your personal data is not used for marketing or for automated decision-making (including “profiling”).
What is the legal basis for processing the data?
As regards purpose 1 above, the legal basis for processing your personal data is that it is necessary for the purposes of my legitimate interests – more specifically, my need to be able to deal with incoming communications – and those interests are not overridden by your right to protection of the data.
As regards purposes 2–7 above, the legal basis for processing your data is that it is necessary to enable me to perform the contract for services which you enter into with me, or to enable me to take steps at your request prior to entering into such a contract (e.g. to give a quotation).
As regards purpose 7 above, a further legal basis for processing your data is my legal obligation under the Swedish Legal, Financial and Administrative Services Agency’s regulations to retain documentation of translations that I have produced.
As regards purpose 8 above, the legal basis for processing your data is my legal obligation under the Swedish Accounting Act to retain accounting records for a certain period of time.
If you order a translation or language editing/proofreading of a text that contains sensitive personal data about you (e.g. data about your health or revealing your ethnic origin), I need to have your consent to that data being processed for the intended purpose. The same applies if, prior to an interpreting assignment, you provide me with preparatory material containing sensitive personal data. The legal basis for processing such data is that you have given your consent. You may withdraw your consent at any time. For the processing of other, non-sensitive personal data as part of the service provided, the legal basis is that the processing is necessary to enable me to perform the contract which you enter into with me.
How is your personal data processed and how long do I keep it?
The data you provide in your contacts with me, e.g. in emails, is stored electronically or by other means to enable me to provide you with information you have requested and confirm any order for services.
If in my assessment of an incoming communication I conclude that further processing of your data is not necessary, the data will be erased as soon as that assessment has been made.
If you have received a quotation but do not order any service from me, your personal data will be erased no later than 3 months from when it becomes clear that you will not be placing an order.
If you order a translation or language editing/proofreading, the original text will be stored electronically or by other means, together with your contact information and any other text or information material which you make available and which is needed to provide the service. The text is then language-edited/proofread or used as the basis for a translation. The finished text is stored electronically, printed out and sent to you in the manner we have agreed.
The translation or the language-edited/proofread text and in certain cases the original text are then normally kept, together with your contact information, for no more than 3 years after the service has been provided. This is to enable me, for example, to provide you with additional copies of the text, answer any questions you may have or deal with any complaints. If at the end of this 3-year period you are still a customer of my business, the earlier texts may be kept for longer, if they are needed in connection with later orders from you – but not for more than 1 year from when you cease to be a customer of my business.
If you order interpreting work, any preparatory material for the assignment which you provide will be stored electronically and/or printed out. Such material will be erased or destroyed no later than 1 month after the assignment.
The personal data included in the invoice you receive from me (normally, your name and postal address or telephone number, and a brief description of the service provided), or which you make available when paying for a service provided, will be kept as part of my business’s accounting records for 7 years from the end of the calendar year in which the service is provided. This is to comply with the provisions of the Swedish Accounting Act.
Will your personal data be disclosed to anyone else?
All personal data which you provide to me is dealt with confidentially. As an authorised translator and legal interpreter I am subject to a statutory duty of confidentiality. This means, among other things, that I must not, without lawful authority, disclose anything which has come to my knowledge in the course of a translation or interpreting assignment concerning the personal circumstances of a private individual, a trade secret or a business relationship.
Only when the law or the decision of a public authority so requires can certain personal data be disclosed to the proper authority (e.g. the police or a court). Your personal data will not be disclosed under any other circumstances, unless you expressly ask me to disclose them to a specific person or organisation.
Nor will your personal data be transferred to a third country or international organisation.
You have a right of access to the personal data about you which I hold, as well as to information about the purposes for which it is being processed, how long it will be kept, and your other rights arising from processing of the data.
In addition, you have the right to
- have inaccurate data about you rectified and incomplete data completed,
- have data about you erased if it is no longer necessary for the purposes for which it has been processed, if it has not been processed in accordance with the law, if erasure is required to comply with a legal obligation, if processing is based solely on your consent and you withdraw that consent, or if you object to the processing and there are no overriding legitimate grounds for it,
- have the processing of data about you restricted,
- object to the processing of data about you.
If you have given consent to the processing of your personal data, you have the right to withdraw your consent at any time.
As regards personal data about you which is processed by automated means and which you yourself have provided to me, you have the right to receive the data in a structured, commonly used and machine-readable format, for the purpose of transmitting the data to another data controller (”data portability”). This applies when your data is being processed on the basis of your consent or a contract you have entered into with me. You do not have the right to data portability if your data is being processed on the basis of a legal obligation, or if it would adversely affect the rights and freedoms of others.
If you feel that I have not complied with the rules in processing your personal data, please inform me as soon as possible so that I can look into what has happened and if necessary rectify matters. You also have the right to lodge a complaint with a supervisory authority. In Sweden, the supervisory authority is the Swedish Data Protection Authority (Datainspektionen).
To be able to provide you with services, I need to process certain personal data about you in the ways and to the extent described above. You are not obliged to provide me with your personal data, but if you choose not to do so it may mean that I will not be able to provide you with the services you require.
More information about the General Data Protection Regulation can be found on the Swedish Data Protection Authority website (mainly in Swedish).