The General Data Protection Regulation (GDPR), implemented in 2018, governs how organisations within the EU—or dealing with EU citizens’ data—collect, store, and process personal information. For translation agencies, this regulation is particularly relevant due to the sensitive nature of client content and the international scope of operations.
Translation agencies routinely handle documents containing personal data, such as legal contracts, medical reports, financial statements, and employment records. Any information that identifies a natural person—names, addresses, identification numbers, or even IP addresses—falls under the GDPR. When translating such content, agencies become either data processors or data controllers, depending on their relationship with the client.
A Language Services Vendor is typically a data processor, acting on behalf of the client (the data controller). However, in some cases—such as when offering Machine Translation with data retention or managing client platforms directly—it may assume the role of data controller. This distinction determines specific legal responsibilities under the GDPR.
Language Services Vendors must ensure there is a lawful basis for processing personal data. This usually includes contract fulfilment (e.g., translating a client’s document) or consent (when handling particularly sensitive information). It's essential that clients provide assurances that data subjects have been informed and that appropriate consent has been obtained, if necessary.
If a translation project involves subcontractors or external platforms (e.g., CAT tools with cloud storage), agencies are responsible for ensuring these third parties are also GDPR-compliant. Data Processing Agreements (DPAs) should be in place with all external vendors.
Data Retention and Deletion Policies
Language Solution VendorsTranslation agencies should establish clear data retention policies—keeping personal data only as long as necessary for the project or as required by law. Clients should be informed about these policies and have the option to request data deletion in line with their rights under the GDPR.From a linguist’s perspective, GDPR compliance adds an additional—but essential—layer of responsibility. We’re not just converting content from one language to another; we’re often entrusted with sensitive, personal, or confidential information. It’s critical that linguists understand their role in safeguarding data, follow secure file handling practices, and respect confidentiality agreements. A good habit could be to delete project files immediately after delivery unless instructed otherwise, and to confirm that used platforms are secure. Data protection is as much about trust as it is about law.
GDPR compliance is not optional—it is a legal and ethical obligation. By understanding the regulation’s implications and applying rigorous data protection standards, translation agencies can safeguard client trust and operate responsibly in an increasingly data-conscious marketplace.
|
Risk Category |
Description |
Example in context of Translation |
|
Legal Sanctions |
Fines up to €20 million or 4% of annual global turnover, whichever is higher. |
Translating personal medical data without proper consent. |
|
Contractual Breach |
Violation of NDAs or service agreements may lead to lawsuits or termination. |
Sharing a confidential legal document with an unauthorized third party. |
|
Reputational Damage |
Loss of trust from clients, agencies, or collaborators. |
Client finds out their data was stored insecurely or shared without notice. |
|
Loss of Business |
Clients may choose GDPR-compliant competitors. |
Agencies stop assigning projects due to non-compliance concerns. |
|
Data Breach Liability |
Responsibility for exposing sensitive or personal data. |
Storing client documents on unencrypted personal devices. |
|
Third-Party Mismanagement |
Use of non-compliant subcontractors or tools. |
Working with a freelance translator who doesn’t follow data protection rules. |
|
Improper Data Retention |
Keeping personal data longer than necessary or after project completion. |
Failing to delete files after delivery, against GDPR or client policy. |
|
Unsecured Communication |
Using unsafe channels to send or receive data. |
Sending translation files with personal data via unencrypted email. |
|
Lack of Transparency |
Not informing clients about how their data is handled. |
No clear data protection policy on your website or in your communication. |
|
Ignorance of Data Subject Rights |
Failing to respect rights such as access, correction, or deletion. |
Refusing or ignoring a request to erase translated data with personal info. |