Providing a client’s name upon confirmation of a booking – is it a GDPR breach?

By NUBSLI | Published on 18 June 2019

Last updated on May 26th, 2023 at 10:51 pm

Related: agencies LanguageLine Solutions

Members across the UK have brought to our attention that LanguageLine Solutions has recently taken the decision to withhold client names from the booked interpreter. NUBSLI do not endorse this practice and have written to LLS to express our concerns; a copy of the letter is below.

The National Union of British Sign Language Interpreters (NUBSLI) represents BSL/English interpreters and translators working across the UK.  Two matters have recently been brought to our attention by several of our members and they have asked us to contact you on their behalf to address these.

The first issue is that LanguageLine Solutions has recently taken the decision to withhold client names when confirming bookings with freelance interpreters, citing GDPR compliance as the reason.  Whilst we appreciate your concerns, we would advise that the provision of client names is not in breach of this legislation, but that it is essential for the interpreter whose services have been contracted to know this information in advance.

Interpreters accept or decline assignments based on a number of factors and knowing who the client is a crucial one.  The information can allow them to identify in advance reasons why it might not be suitable for them to accept the assignment, e.g., conflict of interest, known language discrepancy, previous/ongoing professional relationship from other assignments, etc.  Whilst you are suggesting that, should a reason be identified, the interpreter has the right to withdraw at the of assignment, we would suggest this is too late and leaves the client without vital communication support.

GDPR clearly explains that data sharing should be handled on a “need to know” basis and sharing data with those who need to know is not a breach of the regulations.  We cannot envisage anything an interpreter may do with the name of a client that would constitute mishandling of personal data.  If you could explain exactly which part of the GDPR regulation you are concerned about, we can be more specific in terms of finding a resolution.

The second issue members are concerned about is your policy on interacting with clients, or rather not interacting with them.

NUBSLI has seen advice issued by NHS England specifically relating to spoken language interpreters working with victims of trafficking, and it appears that this is now being issued as a blanket policy by yourselves.  We would suggest that this is unnecessary, as well as ill-advised.

Sign language interpreters work with clients with a wide range of communication needs, often with idiosyncratic use of language and limited language proficiency.  It is therefore vital that we are able to engage with clients prior to interpreting sessions to determine their needs and preferences, to ensure there is a language match, and that an appropriate service can be provided.  Indeed, our Code of Conduct and Best Practice Guidelines state that this is what the ethical practitioner must do.

Your new policy places sign language interpreters in direct conflict with their codes of conduct and makes it impossible for them to work.

As the advice from NHS England was in relation to spoken language interpreters working with victims of trafficking, we would ask you to retract this for sign language interpreters.

We look forward to receiving a response at your earliest convenience.

NUBSLI will continue to correspond with LanguageLine Solutions and will provide an update when the matter has been resolved.