So first of all think about the privacy issues for the people who use our software.
In line with privacy-by-design, our Translation Software minimizes the data held on users and gives them control over what is held, for example by letting them choose a user name that doesn't identify them without reference to information held elsewhere (essentially a pseudonym).
The more complex issues surround how any personal data in materials to be translated is treated.
Where there is personal data, the most straightforward and reliable way to apply privacy by design is as follows:
- Pseudonymize content during file preparation: In other words, have a project manager (or equivalent role) replace the personal data in the source content file with pseudonymous strings before passing the file to a translator, service provider, or any other user.
- Delete the key once the pseudonymization is reversed: Once the translated content has been finalized and approved with the pseudonyms in place, the project manager reverses the process so that the final deliverable includes the personal data as required. The project manager can then safely delete the pseudonymization key.
Lastly, remember the Data Controller - the person that exposes our software or translators to the content, is responsible for the data within that content and GDPR compliance. This is beyond the means of our software or Data Processors to govern, but we can help you become GDPR compliant with a few simple practices.