On Saturday 22 November 2019 the project for Common European GDPR guidelines for the translation and interpreting sector was officially launched from the podium of the old German Parliament at the BDÜ Conference in Bonn.
Our presentation team consisted of John O’Shea, representing FIT Europe, and Stefanie Bogaerts, representing the Association of Translators of the Lublin Region LST and FreeLING Foundation (Fundacja Freeling) from Poland.
The presentation at the BDÜ Conference was the official kick-off of the project. We launched the first step: a survey for freelance translators and interpreters and one for translation and interpreting associations.
The main goal of the surveys is to assess the state of awareness amongst translators and interpreters and their representative associations.
If you are a freelance translator or interpreter we ask that you follow this link and fill out the survey.
The survey for associations will be sent out directly to associations that are members of FIT Europe.
In the near future there will also be a survey aimed at language service providers in order to assess the situation among these actors in the translation and interpreting sector. Combining the data from the three surveys will give us a much clearer picture of the current state of play.
In the meanwhile, we are also building a team of experts who are willing to support the project. Want to join our team? If you have a strong interest in GDPR issues for the translation and interpreting sector and want to help your colleagues comply with #GDPR, please don’t hesitate to contact us at FIT Europe – privacy@fit-europe-rc.org or Fundacja FreeLING –
info@freeling.pl.
If all goes well, the next step will be a conference and panel of experts in the form of a Translating Europe Workshop. This will be organised in cooperation with the Polish Field Office of the Directorate-General for Translation. Many thanks to Mr. Krzysztof Nalepa for his support!
The Workshop will allow us to develop and present our position on issues that the translation and interpreting professions find problematic with GDPR. This will give us a solid basis to prepare and publish a set of uniform guidelines for the translation and interpretation sector.
But you might ask why we have initiated this project?
Since May 2018 data protection has become an important issue for the translation sector. GDPR has introduced rules intended to bring order to the data processing arena, but lack of uniform interpretation of these rules across Europe causes a lot of confusion for the translation and interpreting professions.
Over the past months many sets of instructions, guidelines and model documents have been published and a mass of information on #GDPR is freely available on the internet. However, most of the proposed solutions and documents are general in nature and do not take into account the specific needs of translators and LSPs.
There is a strong need for specific guidelines for the translation industry that will help all actors to fully implement the GDPR requirements. The European Commission’s “Taking Stock” report on GPDR published one year after the Regulation entered into force also acknowledges the need for industry-specific guidance to promote greater compliance.
These guidelines should answer major questions about the procedures and formalities connected with data processing in our sector and present best practices. They should encompass the whole translation process and every link in the supply chain, from the end client over LSP’s to the freelance translator and interpreter.
As translators very often work cross-border and guidelines for data protection differ significantly from country to country, it is advisable that common guidelines be drafted on a European level. This will allow translators and LSPs to apply uniform standards, fully protecting not only the rights and freedoms of the data subject, but also the interests of all actors in the translation sector.
These uniform standards should address problematic issues such as:
- When are translators and LSPs data processors and data controllers?
- How long can and should we retain personal data?
- What to do with translation memories and personal data collected before May 25 2018?
- Are pseudonymisation and anonymisation good solutions for translators?
- How to draft standard clauses for data processing agreements in order to protect the interests of the data subject, client, LSP and translator/interpreter?
If you want to contribute to the project, please fill out the survey, add your comments and share information about the project. Thanks to your support we will be able to answer questions like these and many more, and prepare uniform guidelines that will help all translation and interpreting professionals.