We are Access Language Services Inc. (“ALS”). Your privacy is important to us. The purpose of this Privacy Statement is to explain how we collect, use and disclose Personal Information, and to inform you of your rights with respect to such Personal Information.
We provide both translation and interpretation services for clients in Canada (together, the “Services”). We serve a wide array of clients ranging from Canadian government agencies to local and multinational companies, including large, institutional clients such as hospitals, health authorities and government departments (our “Clients”).
Classification of information
By the nature of our business, we have different relationships with the individuals whose Personal Information we handle or process.
- Institutional Clients: are organizations, health authorities, government agencies and companies for which we provide translation or interpretation services under contract. In those cases, our “client” is the institution (“Institutional Client”) and we refer to the individuals whose Personal Information we may handle on their behalf as “Institutional End Users”. When we collect, use or disclose Personal Information of Institutional End Users, we do so on behalf of the Institutional Client.
- Individual Clients: We sometimes provide translation and interpretation services directly to individuals. In this privacy statement, we refer to these individuals as “Individual Clients.”
- Contractors: To assist us in providing our services, we have a network of other translators and interpreters, who will we engage from time to time. In this privacy statement, contract translators/interpreters are referred to as “Contractors”.
- Translation Materials: When we provide translation and interpretation services, we inevitably come into contact with, handle or process the spoken or written words that are to be translated from one language to another. These are referred to as “Translation Materials”.
- Personal Information: This Statement relates to “Personal Information”, meaning information about an identifiable individual, whether that individual is our Institutional Client, Individual Client, Institutional End User, or a Contractor. Whether a person is “identifiable” means that they can be identified by the information itself or by that information combined with other information reasonably available.
You will note that the nature of the Personal Information varies depending on whether it relates to an Institutional Client, Individual Client, Institutional End User, or a Contractor, so each is specifically addressed in this Privacy Statement. The collection, use and disclosure of Institutional End User Personal Information would also be subject to the privacy practices of the relevant Client, so individuals should refer to them for additional information.
Collection and Use of Information
- From our Institutional Clients, we collect only information that is necessary to onboard and register them as Clients within our system, and to provide our Services. This information includes:
- Client name
- Contact information, including postal and email addresses
- Billing address
- Billing details (as necessary for our internal accounting purposes and for processing payments through our contracted processing service)
- Login information, such as usernames and encrypted passwords
- Information about how the Client uses our Services
- The use of our Services by Institutional End Users and Individual Clients may involve the collection of the following Personal Information, for the purpose of scheduling, client management, and general provision of Services:
- Name (Title and full name)
- Health card number
- Contact details
- Reason for requesting services
The collection of information of Institutional End Users is based on contracts with our Institutional Clients. As noted above, when we collect, use or disclose Personal Information of Institutional End Users, we only do so on behalf of the Institutional Client.
- We also collect and use Personal Information from our Contractors, in order to facilitate provision of our Services to our Clients. The information we collect may include:
- Contractor name (Title and full name)
- Contractor contact details
- Contractor credentials
- Payment instructions or other details
- Vulnerable sector check/Vaccinations
- Income tax required information
- Language testing
- Schedule availability
Contractors all follow strict protocol with respect to their own collection and use of Personal Information, and are required by Institutional Clients to adhere to confidentiality agreements and specific confidentiality procedures. Our Contractors also comply with our security policies and procedures.
On our website
Cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the website, pages visited, language preferences, and other web traffic data. We use the information for security purposes, to facilitate online navigation, to display information more effectively, to personalize your experience while using the website, and to otherwise analyze user activity. We can recognize your computer to assist your use of the website.
Pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with our website to, among other things, track the actions of users of the website and other means of communication with you (including e-mail recipients), measure the success of our marketing campaigns, and compile statistics about usage of the website and response rates.
You can learn about Google’s practices in connection with this information collection and how to opt out of it by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
Purposes for collection
Retention of information
We only retain Personal Information for as long as is required to achieve the purpose for which it was collected and where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements). Limited Personal Information of Institutional End Users and Individual Clients is retained in our database to facilitate provision of Services.
Disclosure of Personal Information
We will not disclose Personal Information to any third party other than with consent of the relevant client, or if we are lawfully obliged to disclose it. If we receive any legal process that would compel us to disclose any such Personal Information, we will make reasonable efforts to give the relevant client notice of the disclosure, provided we are lawfully able to do so.
There are circumstances where we do not control the disclosure of Personal Information that we handle. When we are providing interpretation services in a public courtroom, everything that is said and translated likely becomes a matter of public record. Translation Materials, and our translation work product, as well, may be disclosed by our Individual or Institutional Client, or Institutional End User.
If we were to be acquired by another company, the Personal Information necessary to operate ALS as a going concern would be transferred to the purchasing company. The purchasing company would be subject to this Privacy Statement with respect to the information that is transferred.
Safeguarding Personal Information
We are required by law to safeguard the Personal Information in our custody or control. We use industry standard measures to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. We protect Personal Information regardless of the format in which it is held.
Our methods of protection include (a) physical measures, such as restricted physical access to our information system; (b) organizational measures, including training and limiting access of employee and Contractors on a “need-to-know” basis; and (c) technological measures, including the use of passwords and encryption.
We use service providers, including data hosting providers, to facilitate providing the Services. We use contractual means to make sure that our service providers only deal with Personal Information on our behalf to provide the Services and not for any other purposes. We also undertake diligence to satisfy ourselves that our service providers will implement adequate safeguards to protect Personal Information.
If we have reason to believe that there has been a breach of security safeguards that has resulted in the inappropriate loss or disclosure of Personal Information, we will take reasonable measures to notify the affected Contractors and/or Clients promptly and with sufficient detail to enable them to evaluate the breach and understand the likely consequences.
Right of Access
Pursuant to applicable law, you may have a right to access and correct your Personal Information. If you are an Individual Client or Contractor and you have any questions about your Personal Information, please contact us at firstname.lastname@example.org. Institutional End Users may be directed to the relevant Institutional Client with respect to Personal Information we have collected and use on their behalf. In order to assist you with any access request, we may need you to provide additional information in order to confirm your identity.
We may use anonymized information, derived from Personal Information, for any purposes, including:
- Analytics to understand how users make use of our Services and our website;
- To improve our Services and to develop new capabilities; and
- For research purposes, either for ALS or for others.
We will take industry standard steps so that this anonymous information cannot be connected to any particular information.
If you have any questions or concerns about our privacy practices, or if you wish to access your Personal Information, please contact us.