• providing translation and/or interpretation services to clients (or quotes therefor);
• producing (and procuring the production of) translations and/or interpretations for clients;
• in the case of KLGF, the offer and sale of franchises and in support of Keylingo Franchisees;
in the case of Keylingo, identifying, engaging and communicating with linguists, project managers and other language professionals;
• complying with governmental regulations, including primarily the offer and sale of franchises and export of content being translated and/or interpreted;
• identifying and communicating with individuals interested in receiving information about the translation and/or interpretation services
• offered by Keylingo Family Members, and other marketing purposes;
• hiring and employment purposes (including for independent contractors);
• training; and
• operating the Keylingo Translations website.
Keylingo Family Members generally use such personal information to carry on their respective businesses and serve their respective clients as described above. If a Keylingo Family Member collects personal information for a purpose not identified above, the purpose for collecting the personal information shall be identified at or before collection. Keylingo Family Members do not sell, loan or otherwise make available personal information to any third party, unless required by law or a regulatory or financial audit (such as U.S. franchise regulations requiring disclosure of personal information of current and former franchisees, in the case of KLGF). Nor do Keylingo Family Members track personal information of individuals who visit the keylingo.com website (though all emails send to a keylingo.com email address to pass through the United States, regardless of final destination). All of Keylingo’s independently contracted linguists and project managers (and all Keylingo Franchisees) have signed confidentiality agreements regarding client information.
The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except as provided by law. A Keylingo Family Member will not (as a condition for providing or procuring translation and/or interpretation services for example) require an individual to consent to the collection, use or disclosure of personal information beyond what is necessary for the purposes of collection. If a Keylingo Family Member acts as a service provider to another organization with respect to the collection, use or disclosure of personal information, the Keylingo Family Member shall obtain and adhere to any form of consent previously obtained by such organization. The adequacy of any form of consent depends upon the circumstances, the type of information that is being collected and the reasonable expectations of the individual. Generally speaking, the more sensitive the information (such as heath records or employment evaluations), the consent must be more explicit or manifest Consent shall not be obtained through deception. If a client includes personal information within content to be translated, Keylingo Family Members will assume that the client has obtained consent for Keylingo Family Members (and subcontracted linguists and language professionals) to have access to and use of such personal information for such purposes. An individual may withdraw a consent at any time, subject to legal or contractual restrictions and reasonable notice. The individual shall be informed of the implications of such withdrawal. In Canada, exceptions to the consent requirement are specified in the PIPEDA.
A Keylingo Family Member shall limit collection of personal information to that which is necessary for the purposes identified above or for any identified special purpose. The information shall be collected by fair and lawful means. Personal information shall not be collected indiscriminately. Both the amount and the type of information collected shall be limited to that which is necessary to fulfill the purposes identified.
Personal information maintained by a Keylingo Family Member shall be accurate, complete and up-to-date, to the knowledge of the respective Keylingo Family Member and as necessary for the purposes for which the information is used. The extent to which the personal information shall be accurate, complete and up-to-date will depend upon the use of the information, taking into account the interests of the individual. For example, this is particularly important where the information is being used to make some evaluation or judgment about the individual.
A Keylingo Family Member will implement safeguards to protect the personal information maintained by such Keylingo Family Member, appropriate to the sensitivity of the information. Each Keylingo Family Member’s security safeguards shall protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. The nature of the safeguards will vary according to the sensitivity of the information. At the moment the principle means of safeguarding shall be to limit access to the data bases used in common by Keylingo Family Members. Most personnel of Keylingo Family Members work in a variety of locations and access these programs and data from laptops. If an individual wishes his or her data in such common data bases to be unavailable to other Keylingo Family Members, except for the purposes identified above, then he or she may inform his or her Keylingo Family Member. Each Keylingo Family Member’s Privacy Manager shall periodically make its personnel aware of the importance of maintaining the security of personal information.
• how the individual may contact the respective Privacy Manager;
• advice that the individual can gain access to personal information by writing to the Privacy Manager with verification of identity and a request for information;
• a description of the type of personal information held by the Keylingo Family Member, including a general account of its use;
• information that explains the Keylingo Family Member’s protocols; and
• what personal information is generally made available to related organizations.
A Keylingo Family Member shall inform an individual upon request of the existence, use and disclosure of his or her personal information. The individual shall be given access to that information and an opportunity to challenge the accuracy and completeness thereof (and to have it amended as appropriate). Before granting an individual access to the personal information, a Keylingo Family Member must consult the respective Privacy Manager. In Canada, for example, there are restrictions on the grant of access in PIPEDA where it would reveal personal information about a third party that cannot be severed from the information about the individual making the request (and in certain other circumstances there needs to be prior notification of governmental institutions). Access may also be refused where the information is protected by attorney- or solicitor-client privilege; where revealing the information would also reveal confidential commercial information; where revealing the information could reasonably be expected to threaten the life or security of another individual; if the information was collected during an investigation of a breach of an agreement or a contravention of the laws of the U.S., Canada or a state/province on the expectation that the knowledge or consent or consent of the individual would compromise the availability or accuracy of the information; or where the information was generated in the course of a formal dispute resolution process. Upon such a request, the Privacy Manager of the applicable Keylingo Family Member shall inform an individual whether or not the Keylingo Family Member holds personal information about the individual. When disclosure is made to the individual, the organization shall provide an account of the use that has been made or is being made of the information and an account of the third parties to which the information has been disclosed. Where the request for access is with respect to personal information collected, used or disclosed in the course of serving a customer or other third party, the customer or other third party shall immediately be provided with a copy of the request. Each Keylingo Family Member shall endeavor to respond to an individual’s request within 30 days and at minimal or no cost to the individual. When an individual successfully demonstrates the inaccuracy or incompleteness of personal information, the Keylingo Family Member will amend the information as required. Depending upon the nature of the information challenged, amendment could involve the correction, deletion or addition of information. Where appropriate, the amended information shall be transmitted to third parties having access to the information in question.