Introduction and purpose
As a dedicated provider of professional translation services, INNORWEGIAN AS handles sensitive, confidential, and high-value materials for diverse clients. We recognize the rapid evolution of artificial intelligence (“AI”) technologies and maintain a clear, cautious, and transparent approach to their adoption.
This public policy (the “Policy”) sets out our institutional commitments, data handling practices, and safeguards regarding AI. It serves to inform our clients and prospective clients of how we protect their materials, ensure absolute confidentiality, and maintain the highest standards of linguistic quality.
Principles on AI usage
We apply a strict segregation between internal operational assistance and the actual processing of client source materials.
We do not input, upload, or transmit any client documents, source texts, personal data, or confidential client records into generative AI tools or large language models. All translation, editing, and proofreading services performed for client deliverables are executed by qualified human linguists. Where dedicated translation tools are used in a project, these are, in the vast majority of cases, provided or specified by the client and applied in accordance with the client's instructions.
We permit the use of AI tools exclusively for internal, non-client-specific administrative and exploratory purposes, including:
High-level subject-matter research and conceptual brainstorming;
General terminology compilation, generic vocabulary verification, and public glossary structuring; and
Internal administrative, organisational, and operational workflows.
Where a client specifically provides AI-generated source text or machine translation output to us for review, post-editing, revision, or translation, we process and handle such material strictly in accordance with that client's specific instructions and agreed scope of work.
Confidentiality and professional secrecy
We treat all client materials, source texts, reference documents, and business communications as strictly confidential.
Our professional secrecy and non-disclosure obligations apply unconditionally across all translation engagements. These duties are never altered, degraded, or compromised by technological tools. Because client materials are never submitted to third-party AI platforms, our clients' trade secrets, legal privileges, and proprietary information remain fully protected.
Data protection and GDPR compliance
We process all personal data in full compliance with the Norwegian Personal Data Act (personopplysningsloven) and the General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”).
In delivering translation services, we frequently act as a data processor pursuant to GDPR Article 28, processing personal data solely on documented instructions from our clients, who act as data controllers.
This Policy addresses our use of AI specifically. Further details on how we collect, use, store, and protect personal data are set out in our Privacy Policy, available on our website at innorwegian.com/privacy.
In alignment with GDPR Articles 5, 25, and 32, we enforce strict principles of data minimisation, privacy by design, and integrity:
Personal data contained in client documents is never transferred, exposed, or disclosed to public AI systems;
Client data and source materials are never used, retained, or repurposed to train, fine-tune, or develop public or third-party AI models; and
All electronic processing and storage of client personal data is maintained strictly within the European Union (EU) and European Economic Area (EEA).
Human oversight and quality assurance
Every translation and linguistic deliverable delivered by us is produced, managed, and reviewed by qualified human translators and linguists.
We maintain uncompromising human accountability for the accuracy, contextual nuance, terminology, tone, and cultural appropriateness of all deliverables. Automated systems are never substituted for human professional judgment, linguistic competence, or editorial oversight.
Transparency and contractual alignment
We are fully transparent regarding our operational methods and technology usage.
We strictly adhere to any client-specific contractual requirements, framework agreements, or guidelines concerning artificial intelligence, machine translation, or automated processing tools.
Client preferences and tailored accommodations
We recognize that individual clients maintain varying policies regarding AI and automated tools. We readily accommodate client instructions requesting a complete, absolute exclusion of AI across all stages of project support, terminology preparation, and administrative handling.
Upon request, we enter into standard or custom Data Processing Agreements (“DPAs”) pursuant to GDPR Article 28, detailing technical safeguards and formal processor commitments tailored to client compliance requirements.
Information security
We implement and maintain appropriate technical and organisational security measures pursuant to GDPR Article 32 to protect client files, personal data, and confidential materials against unauthorised access, disclosure, alteration, loss, or unlawful processing.
Access to client materials is restricted strictly to authorised personnel and vetted human linguists bound by confidentiality undertakings who require access to perform assigned linguistic duties.
Contact information
Clients, prospective clients, and data subjects with questions regarding this Policy, our data protection measures, or our AI practices are invited to contact us at:
Policy review and maintenance
We review this Policy on a periodic basis to ensure continued alignment with technological developments, legal requirements, and industry best practices.
Any updates to this Policy will be published directly on our company website with a revised effective date.
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