By its nature translation work knows no borders: the specialist in the target language is often in another country. This means that a document goes abroad, and in files that contain personal data it requires a separate arrangement. Cloud services raise the same question silently.
Definition of transfer
Sending the document to a person or a system abroad is a transfer. No physical carriage is needed. The definition is broad.
The specialist's location
The specialist in the target language may be in another country. This is the ordinary structure of the sector. The situation is explained transparently.
The position of cloud services
The server location of the systems used raises the question of transfer. The location is asked. The information is recorded.
The risk of silent transfer
Uploading a file to the cloud can be a transfer that goes unnoticed. An inventory of tools is drawn up. The risk is made visible.
Inventory of tools
Which tools are used and where they are hosted is listed. The list can be shared with the client. Transparency is ensured.
Regulating in advance
The conditions of transfer are written before the job starts. A transfer noticed afterwards causes problems. The article is included from the outset.
Client approval
Some contracts make transfer subject to approval. The condition is written down. Practice follows it.
Giving country information
The countries to which transfer may be made are stated. The list can be limited. The scope is defined.
List of restricted countries
The client may keep certain countries out of scope. The restriction affects the choice of resources. The situation is known in advance.
The domestic-only condition
In some jobs no transfer is wanted at all. This condition narrows the pool of resources. The effect is explained.
Effect on capacity
A domestic restriction lowers capacity in some language directions. The truth is told at the outset. The expectation is set.
Security measures
The transfer channel is encrypted and controlled. An open e-mail attachment is not preferred. The channel is defined.
Access instead of transfer
Instead of sending the file, access can be given in a controlled environment. Copies do not multiply. The method is preferred.
Tracking copies
How many copies of the file exist and where is tracked. At the end of the job the copies are deleted. A record is kept.
Deletion after the job
Copies held by the team abroad are deleted at the end of the job. The deletion is confirmed. The record is retained.
Subcontractor undertakings
The same obligations are set up with specialists abroad. The chain does not weaken. The undertaking is in writing.
Limits for special category personal data
For documents that contain health and judicial records, transfer is assessed more strictly. If necessary it is not made. The decision is cautious.
Keeping records
Which document was transferred where is recorded. The record may be requested in an audit. Order is established.
Transparency is decisive
The greatest risk here is not the transfer itself but the client being unaware of it; a transfer learned of afterwards turns into a problem of trust even if it was made in accordance with procedure. The information is shared at the outset. Approval is obtained in writing.
Limits of legal information
What is described here is for information purposes and does not replace a legal opinion. The data protection assessment belongs to the authorised persons. The limit is stated.