SILA Linguists® is a registered trade mark of NEXUS of SILA Limited.
This Privacy Policy explains how NEXUS of SILA Limited, trading as SILA Linguists® ('SILA', 'we', 'us' or 'our'), collects, uses, shares and protects personal data when you use our interpreting, translation, transcription, language analysis and related services, when you work with us as a linguist or apply for a role, when you use the SILA Linguists app (the 'App') and when you visit our website (the 'Website'). It also explains your rights and how to exercise them.
We comply with the UK General Data Protection Regulation ('UK GDPR'), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003 and, where we process personal data of people in the European Economic Area, the EU General Data Protection Regulation ('EU GDPR').
1. Who we are and how to contact us
NEXUS of SILA Limited is a company registered in Scotland (company number SC770122), with its registered office at 2/3, 48 West George Street, Glasgow G2 1BP, Scotland, United Kingdom. We are registered with the Information Commissioner's Office (ICO) under registration number ZC105121. In most cases, we are the controller of your personal data, which means that we decide how and why it is used. Section 3 explains when we act for a client as a processor instead.
For any question about this policy or about your personal data, please contact our data protection team at daptec@silalinguists.com or write to the Data Protection Team at the address above. Individuals in the European Union and the European Economic Area may contact us directly using these details.
2. The personal data we collect
Depending on how you deal with us, we may collect the following personal data.
- Contact and identity data: your name, job title, organisation, email address, telephone number, postal address and, for individual clients, information needed to confirm your identity.
- Booking data: details of the services you request, such as dates, times and locations of assignments, languages, the names of people attending, delivery requirements, booking references, timesheets and feedback.
- Assignment content: the documents, recordings and other material you give us to translate, transcribe, subtitle, localise, verify or analyse, and the information exchanged during interpreted sessions. This may include personal data about you and about other people, such as patients, service users, applicants or witnesses.
- Billing data: invoicing names and addresses, purchase order references, VAT numbers, and the details of bank transfers we receive, such as the name of the account holder, the account details shown on the transfer, the amount and the date. We do not accept card payments and we do not collect or store debit or credit card numbers.
- Communications: emails, letters, WhatsApp messages, messages sent through the App and notes of telephone calls with us.
- Linguist and recruitment data: if you work with us or apply to do so, your CV, qualifications, language skills, experience, references, right-to-work documents, results of vetting and security checks where required for the work (which may include criminal record checks), availability, assignment history, quality feedback, and bank and tax details needed to pay you.
- App data: your account details and login information, bookings and messages made through the App, and technical data such as device type, operating system and app version. If you grant permission on your device, the App may also use your camera, microphone or push notifications for the features that need them; you can change these permissions at any time in your device settings.
- Website data: technical information sent by your browser, such as your IP address, browser type and the pages requested, which our hosting provider records in server logs for security and operation; and, only if you consent, analytics data collected through Google Analytics and Microsoft Clarity, as explained in our Cookie Policy.
We collect most personal data directly from you. We may also receive personal data from the organisation that books a service involving you (for example a court, a health service or a solicitor), from referees and vetting bodies for linguists and applicants, and from publicly available sources such as professional registers.
3. When we act for our clients
When an organisation books an interpreter or sends us material to translate, transcribe or otherwise process, and that material contains personal data about other people, the organisation is normally the controller of that personal data and we process it as its processor, on its instructions and under a written contract. If your personal data reaches us in this way, please contact the organisation that holds it to exercise your rights. We will help that organisation to respond.
We act as an independent controller when we prepare expert reports, such as language analysis (LADO) and nationality assessment reports, because we must apply our own professional judgment and keep appropriate records; and when individuals book services for themselves.
4. How we use personal data and our lawful bases
We use personal data only where we have a lawful basis to do so. The table below sets out our main purposes and the lawful bases we rely on.
| Purpose | Lawful basis |
|---|---|
| Taking and managing bookings, providing our services and delivering the work | Performance of a contract with you; or our legitimate interests in providing services to the organisation you represent |
| Issuing invoices, receiving bank transfer payments, recovering debts and keeping accounting records | Performance of a contract; compliance with legal obligations (tax and company law); our legitimate interests in recovering amounts owed |
| Recruiting, vetting, engaging and paying linguists | Steps taken at your request before entering into a contract, and performance of that contract; compliance with legal obligations (such as right-to-work checks); our legitimate interests in ensuring that our linguists are qualified and suitable |
| Answering enquiries and communicating with you | Our legitimate interests in responding to you and running our business; performance of a contract where the enquiry relates to one |
| Quality assurance, handling complaints, training and improving our services | Our legitimate interests in maintaining and improving the quality of our services |
| Operating and securing the Website, the App and our IT systems, and preventing fraud | Our legitimate interests in keeping our systems and clients safe |
| Website analytics with Google Analytics and Microsoft Clarity | Your consent, which you can withdraw at any time through the 'Cookie settings' link on the Website |
| Sending news about our services to business contacts | Our legitimate interests, or your consent where the law requires it; you can opt out at any time |
| Complying with law, responding to courts, regulators and law enforcement, and establishing, exercising or defending legal claims | Compliance with legal obligations; our legitimate interests in protecting our rights |
Where we rely on legitimate interests, we have balanced those interests against your rights and freedoms. You can ask us for more information about this balance.
5. Special category and criminal offence data
Our work regularly involves sensitive information. Interpreting and translation for health, social care, legal and immigration matters, and language analysis reports, may involve information about health, racial or ethnic origin, religious or philosophical beliefs, political opinions, sex life or sexual orientation, and criminal allegations or convictions.
When we process this information as a processor, we do so only on our client's instructions; the client is responsible for having a lawful basis and condition for processing. When we process it as a controller, we rely on the conditions that apply, such as that the processing is necessary for the establishment, exercise or defence of legal claims or for courts acting in their judicial capacity, for reasons of substantial public interest under Schedule 1 to the Data Protection Act 2018, for health or social care purposes, or with your explicit consent. For criminal record checks on linguists, we rely on the conditions in Schedule 1 to the Data Protection Act 2018 relating to employment and the protection of the public. Where the law requires it, we maintain an appropriate policy document.
We protect sensitive information with additional safeguards: access only for people who need it, confidentiality agreements with all linguists, secure transfer methods, and deletion when it is no longer needed.
6. Who we share personal data with
We do not sell personal data. We share it only where necessary, with:
- our linguists: vetted interpreters, translators, transcribers, revisers and analysts, who receive only the information needed for the assignment and are bound by confidentiality obligations;
- sworn translators, notaries and similar professionals in other countries, where you ask us to arrange a sworn or officially recognised translation, legalisation or notarisation;
- the organisation that booked the service, where you are a person attending an interpreted session or the subject of a report, as needed to provide the service;
- IT and service providers who support our business, such as providers of email, cloud storage, booking and translation management systems, the App, website hosting and telecommunications, under contracts that require them to protect personal data and to use it only on our instructions;
- analytics providers, namely Google and Microsoft, only if you consent to analytics cookies on the Website;
- our bank, accountants, auditors, insurers and professional advisers, as needed for them to provide their services to us;
- courts, tribunals, regulators, law enforcement and other public authorities, where the law requires it or where it is necessary to establish, exercise or defend legal claims; and
- a buyer or successor of all or part of our business, under appropriate confidentiality terms.
If you contact us through WhatsApp, the message is also processed by WhatsApp under its own terms and privacy policy. Please do not send sensitive documents through WhatsApp unless we have agreed that this is appropriate.
7. International transfers
We are based in the United Kingdom and serve clients in the United Kingdom, Europe, North America, Australia and beyond. Some of our linguists and service providers are located outside the United Kingdom and the European Economic Area, for example a remote interpreter living in another country or a sworn translator recognised in the country where a document will be used.
When we transfer personal data outside the United Kingdom or the European Economic Area, we make sure that it is protected by one of the safeguards recognised by data protection law: a decision that the destination country provides adequate protection; the International Data Transfer Agreement or the UK Addendum to the European Commission's standard contractual clauses; the standard contractual clauses themselves; or, where appropriate, a recognised derogation, for example where the transfer is necessary to perform a contract with you or in your interest, such as arranging a sworn translation abroad at your request. You can ask us for more information about the safeguards we use.
8. How long we keep personal data
We keep personal data only as long as necessary for the purposes for which we collected it, including to meet legal, accounting and reporting requirements and to deal with complaints and claims. In particular:
- invoices, payment and accounting records are kept for six (6) years after the end of the financial year to which they relate, as required by tax and company law;
- client and booking records are kept for the duration of our relationship and for up to six (6) years afterwards, so that we can deal with queries and claims;
- assignment content, such as source documents and recordings, is kept only as long as needed to provide the service and deal with corrections and queries, unless the client instructs otherwise or the law requires a longer period, and is then securely deleted or returned;
- language analysis and other expert reports, and the material on which they are based, are kept for as long as they may be needed in legal proceedings, including appeals, in line with our professional obligations;
- linguist records are kept while the linguist works with us and for up to six (6) years afterwards; unsuccessful applicants' data is kept for no longer than twelve (12) months after the recruitment process ends, unless they ask us to keep it longer; and
- website analytics data is kept for the periods set in the analytics tools, which we keep to the minimum needed.
When personal data is no longer needed, we securely delete it or anonymise it.
9. How we protect personal data
We use appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing, accidental loss, destruction or damage. These include access controls based on need to know, secure passwords and multi-factor authentication, encrypted transfer of files, confidentiality agreements with staff and linguists, training, and procedures for dealing with suspected data breaches. No method of transmission over the internet is completely secure, but we work to protect your personal data and we will notify you and the regulator of a breach where the law requires.
10. Your rights
Under data protection law, you have the right to:
- ask for a copy of the personal data we hold about you (access);
- ask us to correct personal data that is inaccurate or incomplete (rectification);
- ask us to delete your personal data in certain circumstances (erasure);
- ask us to restrict the use of your personal data in certain circumstances (restriction);
- receive personal data you provided to us in a structured, commonly used and machine-readable format, and have it transmitted to another organisation, where the processing is based on consent or contract and is carried out by automated means (portability);
- object to our use of your personal data where we rely on legitimate interests, and at any time to direct marketing (objection); and
- withdraw your consent at any time, where we rely on consent. This does not affect the lawfulness of processing before you withdraw it.
We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects.
To exercise your rights, contact us at daptec@silalinguists.com. We may need to confirm your identity before responding. We will respond within one month, which may be extended by up to two further months for complex or numerous requests, in which case we will tell you why. We do not normally charge a fee. Some rights are subject to exemptions, for example where the information is protected by legal professional privilege or where providing it would reveal personal data about someone else.
Where we process your personal data as a processor for one of our clients (see section 3), please send your request to that client. If you send it to us, we will pass it on to them promptly.
11. How to complain
If you have a concern about how we use your personal data, please contact us first at daptec@silalinguists.com, so that we can try to resolve it. We will acknowledge your complaint and respond without undue delay.
You also have the right to complain to the supervisory authority. In the United Kingdom, this is the Information Commissioner's Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, telephone 0303 123 1113. If you live or work in the European Economic Area, or the issue arose there, you may complain to the data protection supervisory authority in your country.
12. Cookies
Our Website uses storage that is strictly necessary to remember your cookie choice, and analytics cookies from Google Analytics and Microsoft Clarity only if you consent. Videos on the Website are loaded from YouTube only when you click play. Full details, and how to change your choice, are in our Cookie Policy.
13. Children
Our Website and App are not intended for children, and we do not knowingly collect personal data from children through them. Our services may, however, involve personal data about children, for example when we interpret for a family or prepare a language analysis report concerning a young person. In those cases, we process the data on the instructions of the organisation responsible or on another lawful basis, with particular care for the child's interests.
14. Third-party services
Our Website and App may contain links to social media and app store pages. Those services are operated by third parties under their own privacy policies, and we are not responsible for how they use personal data.
15. Changes to this policy
We may update this Privacy Policy from time to time, for example when we change our services or the law changes. The date at the top of this page shows when it was last updated. If we make significant changes, we will take reasonable steps to tell you.
16. Contact us
Data Protection Team
NEXUS of SILA Limited, trading as SILA Linguists®
2/3, 48 West George Street
Glasgow G2 1BP
Scotland
Email: daptec@silalinguists.com