Privacy Policy Certified Spanish Language(CSL) is committed to protecting your privacy in a variety of ways, including using industry-accepted security measures to protect against the loss, misuse, and altercation of data contained in our system. This Privacy Policy applies to all of the interpretation and translation services offered by CSL. Our policy is designed to ensure the safety and accuracy of our CSL clients and their customers’ personal information. Any information revealed to us will never be sold, rented, traded, or leased. CSL adheres to all HIPAA Administrative Simplification Regulations found at 45 CFR 160, 162, and 164. All CSL employees and independent contractors are required to complete the requisite training courses upon hire and annually thereafter. CSL holds certification that it is in full compliance with the EU–U.S. Privacy Shield Framework and the Swiss– U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information from European Union member countries and Switzerland to the United States, respectively. CSL adheres to the Privacy Shield privacy principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Privacy Shield program, please visit the Privacy Shield website, which includes the Privacy Shield privacy principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. CSL’s EU–U.S. Privacy Shield and Swiss– U.S. Privacy Shield certifications can be found here. For complaints and disputes that cannot be resolved between CSL and the complainant, CSL has agreed to participate in the dispute resolution procedures of the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information (Swiss FDPIC) to resolve disputes pursuant to the Privacy Shield privacy principles. Individual DPAs may be contacted directly via the information provided on the Privacy Shield website. If your complaint is not resolved, you may have the ability to invoke binding arbitration. Please see the Privacy Shield website if you have questions on this topic. Confidentiality Precautions Each and every person who works with CSL, either as a direct employee in the central offices or as a contract interpreter, receives training in the compliance with confidentiality and nondisclosure laws. This training takes place prior to the employee or contractor ever working with the customer in any form. Further, questions pertaining to their understanding of this information are incorporated into our testing program. Periodic review of this information takes place via quarterly training updates. As part of our employee initiation program, every employee is required to read, understand, and sign our proprietary employee manual, which includes all documentation that supports confidentiality, HIPAA, and Privacy Shield requirements. CSL is constantly aware of the necessity to keep all documentation and recordings regarding our customers and their CSL clients in strict confidentiality. We have implemented the following procedures to ensure that our practice of protecting private information is followed. These practices are consistently reviewed and updated and include:
Strict guidelines require that Customer confidential information never leave our secure office.
We have contacts within the Centers for Medicare and Medicaid Services (CMS) and the U.S. Office for Civil Rights (OCR), both of which specialize in HIPAA compliance. These contacts evaluate our practices and advise us, ensuring our practices are HIPAA compliant.
No confidential information is available on the web. All data is stored securely in-house.
Our premises are not open to the public; the doors are locked and solely accessible via regulated key cards.
1 Every employee has a strict
confidentiality agreement with emphasis on HIPAA and Privacy Shield compliance.
Interpreters are bound by signed confidentiality and HIPAA compliance agreements. In order to provide our services, we may collect the following types of information: Information you provide – When you sign up for services with CSL, we ask you for personal information (such as your name, email address, phone number, other account information, and an account password). For certain accounts, we accept credit card or other payment account information that we maintain in encrypted form on secure servers. User communications – When you send email or other communications to CSL, we may retain those communications in order to process your inquiries, respond to your requests, and improve our services. Personal Information When you sign up for our interpreter services, the only confidential information that is necessarily exchanged is the information that the interpreter is relaying between the two parties. CSL does record some telephone interpreting calls with permission from our customers. These recordings are made strictly for internal quality assurance purposes and are securely retained for 90 days, at which point they are destroyed.
Call recordings are encrypted with an encryption level of at least 256AES. Access to call recordings are limited to authorized staff.
Recordings are kept securely on the premise only. CSL customizes our services to meet the needs of our customers. We will gather any information that you require for billing purposes and this information will appear on the invoices. We will not collect or use sensitive information for purposes other than those described in this Privacy Policy and/or in the supplementary service privacy notices. Upon request, CSL will provide you with information on whether we hold, or process on behalf of a third party, your personal information. To request this information, please contact us via email. When notified by email or mail, CSL will make reasonable effort to correct, amend, or delete such Personal Data if such data is demonstrated to be inaccurate or incomplete. Information Sharing CSL only shares personal information with other companies or individuals outside of CSL in the following limited circumstances: We have your consent. We require opt-in consent for the sharing of any sensitive personal information. We have a good faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process, or enforceable governmental request; (b) enforce applicable Terms of Service, including investigation of potential violations thereof; (c) detect, prevent, or otherwise address fraud, security, or technical issues; or (d) protect against imminent harm to the rights, property, or safety of CSL, its users, or the public as required or permitted by law. If CSL becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice before personal information is transferred and becomes subject to a different privacy policy. Information Security We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. These include internal reviews of our data collection, storage, and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data. We restrict access to personal information to CSL employees, contractors, and agents who need to know that information in order to operate, develop, or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. Additionally, CSL maintains current certification for compliance with PCI data
security standards. Data Integrity CSL processes personal information only for the purposes for which it was collected and in accordance with this Privacy Policy or any applicable service-specific privacy notice. We regularly review our data collection, storage, and processing practices to ensure that we only collect, store, and process the personal information needed to provide or improve our services. Enforcement CSL is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. CSL complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield Framework, CSL is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, CSL may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. CSL regularly reviews its compliance with this Privacy Policy to ensure it meets both HIPAA and Privacy Shield standards. When we receive formal written complaints, it is CSL’s policy to promptly contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between CSL and an individual. Changes to this Privacy Policy Please note that this Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent, and we expect most such changes will be minor. Regardless, we will post any Privacy Policy changes on our website and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification) of Privacy Policy changes. If you have any additional questions or concerns about this Privacy Policy, please feel free to contact us via email or write to us at: Confidentiality Matters c/o Certified Spanish Language 11843 Sutter Gate Loop, Suite A, Hudson, FL 34667 USA.