Appropriate Policy Document

ISL-LEG-F-H — the policy document required by DPA 2018 Schedule 1 Part 4 for processing special category and criminal offence data. Names the Schedule 1 conditions relied on (para 8 equality, para 18 safeguarding, para 1 employment), how each principle is met, and the retention schedule. Closes ROPA item CR-04.

England & Wales

Appropriate Policy Document

InSignLanguage Ltd · Document code ISL-LEG-F-H · Required by the Data Protection Act 2018, Schedule 1, Part 4 · ICO registration ZC163713

Version 0.1 — DRAFT for external data-protection counsel review. Review: annually, or on material change.

1. Purpose and scope

This document explains how InSignLanguage complies with the data protection principles when processing special category data and criminal offence data, and how long we keep it. It is the policy document required by Schedule 1, Part 4 of the Data Protection Act 2018.

It covers criminal offence data — DBS, PVG and AccessNI certificate information and self-declarations from interpreters and staff — and special category data: data revealing disability, which is inherent to providing services to Deaf people, and health, religious belief, sexual orientation or racial or ethnic origin where a booking's context reveals it.

2. Why we process this data

Interpreter vetting. Interpreters we assign to work with children or adults at risk must hold current enhanced clearance. We verify it, record the outcome and expiry date, and monitor renewal. This protects the people we serve and evidences our ISO 18841:2018 obligation to satisfy ourselves of the competence and suitability of the interpreters we supply.

Service delivery. A booking tells us a person is Deaf and what communication support they need. That is disability data, and we cannot deliver the service without it. Booking context sometimes reveals more — a mental health assessment, a police interview, a safeguarding conference.

Safeguarding. Where a concern arises during an assignment, acting on it may involve processing health, disability or criminal offence data.

3. Our lawful bases and conditions

Data	Article 6 basis	Article 9 / 10 condition
Disability and communication needs of the people we serve	Contract; legitimate interests	Schedule 1, Part 2, paragraph 8 — equality of opportunity or treatment. Where we act as processor, the client's condition applies.
Health, religion, sexual orientation or ethnicity revealed by booking context	Contract; legitimate interests	Processed only so far as necessary to deliver the assignment, under the same condition; minimised at intake
Interpreter DBS / PVG / AccessNI data	Legitimate interests — verifying suitability for regulated work	Schedule 1, Part 2, paragraph 18 — safeguarding of children and of individuals at risk
Safeguarding concerns raised during an assignment	Legitimate interests; vital interests where a person is at risk	Schedule 1, Part 2, paragraph 18
Interpreter engagement records generally	Contract	Schedule 1, Part 1, paragraph 1 — employment, social security and social protection, so far as it applies to engaging suppliers

Each of these conditions requires this policy document to be in place. Where we process on a client's behalf, the client is responsible for its own condition; ours applies to the processing we control.

4. How we comply with the principles

Lawfulness, fairness and transparency. Conditions are identified before processing begins and recorded in our Record of Processing Activities. Interpreters are told at application what vetting we require, why, who sees it and how long we keep it. Service users are covered by our Privacy Notice, and by the transparency statement on booking forms where the booker is not the data subject.

Purpose limitation. Vetting data is used to decide whether an interpreter may take a category of assignment. It is not used for marketing, profiling, performance assessment or any decision unrelated to suitability.

Data minimisation. We record the outcome, certificate number, issue date and renewal date — not the underlying detail of any disclosure. Booking forms ask for the information the interpreter needs and instruct bookers not to enter account numbers or sensitive personal detail. Interpreters receive the minimum briefing necessary.

Accuracy. Vetting records are checked against the certificate at onboarding and re-verified at renewal. Registration status is re-checked against the professional register on a monthly cycle. Where a record is found wrong, it is corrected the same day.

Integrity and confidentiality. Criminal offence data is held in access-controlled records visible only to named compliance and bookings roles, under multi-factor authentication and least-privilege assignment, with auditing on access. It is never held in shared mailboxes, spreadsheets or messaging threads, and never leaves the UK-region environment. Everyone with access is trained and bound by confidentiality.

Accountability. Processing is recorded in the ROPA; access is reviewed periodically; this policy is reviewed annually and after any material change.

5. Retention and erasure

Record	Retained	Then
DBS / PVG / AccessNI outcome, number, issue and renewal date	While the interpreter is engaged, plus 6 months	Securely deleted
Underlying certificate copy or image	Not retained beyond verification	Deleted on verification
Vetting records where a concern was raised and acted on	6 years from resolution, to defend a claim	Securely deleted
Safeguarding records	Per the Safeguarding Policy's statutory period	As set out there
Booking data revealing disability	Duration of the engagement plus the audit period	Securely deleted; only aggregated MI retained
Session recordings, where enabled	6 months (quality assurance) unless a complaint or safeguarding matter extends it	Securely deleted
This policy	While the processing continues, plus 6 months after it ends	Retained as required by Schedule 1, Part 4

Erasure is by deletion from the live system and from backups on the normal backup cycle. Deletions are logged.

6. Individual rights

The people whose criminal offence data we hold are our interpreters, and they may exercise the full range of rights: access, rectification, erasure where the retention period has passed, restriction, objection and portability. Requests go to support@insignlanguage.co.uk and are handled under our Data Subject Rights procedure within one month.

We do not use vetting data for automated decision-making. The decision to allocate an interpreter to a category of assignment is made by a person — the Head of Interpreting Services — and recorded as an explicit approval. Our systems support that decision; they do not make it.

7. Responsibility

The Data Protection Lead (John Hood, john@insignlanguage.co.uk) owns this policy and the Record of Processing Activities. The Head of Interpreting Services owns the vetting process and the suitability decisions it supports. Compliance and Bookings hold day-to-day access.

Anyone who believes special category or criminal offence data has been mishandled should tell the Data Protection Lead immediately. You may also complain to the Information Commissioner's Office at ico.org.uk.

8. Review

Reviewed annually, and whenever the vetting process, the systems holding the data, or the relevant law changes. Each review is dated and recorded, and the previous version retained.

InSignLanguage Ltd · 26 Domum Road, Portsmouth PO2 0QZ · Company number 10943637 · ICO registration ZC163713