ALS (Capita) ignored my request to remove my personal data and now ignore my letter of complaint
Applied Language Solutions not only ignored my request that they remove my data from their database, but they still have not acknowleged or replied to my letter of complaint dated 23/4/2012 sent by Recorded Signed For... are these the actions of an organisation of sufficient standing and repute to operate a national framework for interpreting services in the justice sector and to create and maintain a national register of legal interpreters ???
21 Hartington Road
Mr. Gavin Wheeldon
Applied Language Solutions
Information Commissioner's Office, firstname.lastname@example.org
Ministry of Justice Interpretation Project Team, email@example.com
01 June 2012
Dear Mr Wheeldon,
I am writing to complain about misuse of my personal data by Applied Language Solutions (ALS).
I did four medical interpreting assignments for ALS at the beginning of June 2009 and after I had received payment for these I wrote to your member of staff, Lucy Robinson, saying that I no longer wished to work with your company because "I feel that ALS treats interpreters as a commodity, not as valued professionals".
I explicitly asked Lucy Robinson to remove my data from your database, in these words: "Please can you remove my name and details from your database, so that I do not get any more calls for interpreting jobs from you."
How much clearer does a person need to be for your company to comply with such a request? Which part of that did your staff not understand? It is all in clear English!
I know that my communication was received by your company, so why did ALS not comply with my request? Was it because ALS staff routinely ignore such requests from interpreters and your company does not adhere to the principles of the Data Protection Act and only makes attempts to change procedures after being publicly challenged and embarrassed?
I am aware that many colleagues from the National Register of Public Service Interpreters have been contacted repeatedly by ALS staff despite not having registered with ALS and despite making it clear to your staff that they will not work for ALS. I myself was not contacted by ALS at all and I made no contact whatsoever with ALS. However, while I was assisting a colleague in drafting a complaint about your misuse of her data, she persuaded me to input my email address to your TalkBase web portal to check whether ALS was holding my data.
To my surprise a few days later I received an email with a user name of "disabled" and a password. I logged on and found that you had kept my complete record in spite of my having requested that you delete my details from your database.
My telephone number and email address are publicly available on the NRPSI website and I make my address available on my own website, however the other details in your record are not publicly available. I object to you having kept my data for well over 2 ½ years - way beyond the period when you might have had any reasonable need for it. In particular, I have major objections to you keeping my bank details accessible on a database that, as I understand it, has been available to a data processing site outside the European Union, in India.
For the avoidance of any doubt, I request yet again, pursuant to section 10 of the Data Protection Act 1988, that you delete my personal data from your database of linguists immediately and stop processing my personal data.
I would like written confirmation that you have stopped processing my data, an explanation of ALS's behaviour and a written apology for processing my data contrary to my express instructions.
Furthermore, I would like a written assurance that I have not been included in the number of interpreters ALS has reported as available for work under the Framework Agreement (FWA) with the Ministry of Justice (MOJ). I understand implementation of the FWA was delayed repeatedly until ALS was able to give the MOJ sufficient reassurance about the number of interpreters available to work for ALS on this contract. ALS or Capita Group plc has also released widely varying figures to the press relating to the number of interpreters it has available to work on the contract.
If however the numbers you provided to the MOJ and the press were based on figures derived from the number of interpreters on TalkBase and hence, or for any other reason, I was included, I would like a written apology from you for including me in the total numbers given to the MOJ and press, despite my clear and public opposition to this FWA (c.f. my article in the ITI Bulletin Sep-Oct 2011 issue and my inclusion on the public "Say No" list of Registered Public Service Interpreters refusing to work under the FWA).
I am copying this letter to the Information Commissioner's Office, to add to the other complaints already submitted by interpreters regarding this matter, and also to the MOJ Interpretation Project Team, who should have the ability to verify the interpreter numbers provided by ALS and Capita Group plc.
I await confirmation that you have deleted my data and your apology for processing my data, as well as clarification, accompanied by an apology, if appropriate, regarding my inclusion or otherwise in your total figures of interpreters available to work for you under the FWA.