Blog post dated Apr 1, 2019

GDPR—Marking Personal Data in crossTank

The alarm caused by the GDPR has cooled down a bit, but many fellow translators still feel quite unsure about it. Since personal data are also bound to end up in translation memories such as crossTank, do old crossTank entries have to be deleted right away?

The GDPR applies to "the processing of personal data wholly or partly by automatic means, and to the processing otherwise than by automatic means of personal data which form part of a filing system or are intended to form part of a filing system". (Art. 2 (1) GDPR)

But how do I delete all those entries without damaging or, even worse, destroying my entire crossTank?

An Article by

Andreas Rodemann
Trainer Across Translator Edition

Learn how you can make your work easier and reliably delete personal data from crossTank.

When Do crossTank Entries with Personal Data Have to Be Deleted?

According to Art. 17 GDPR, personal data have to be deleted if they are no longer needed, the data subject withdraws consent to the processing or objects to the processing, the personal data have been unlawfully processed, the personal data have to be deleted to comply with a legal obligation in the European Union or Member State law, or the data subjects request that the data be deleted.

When Must crossTank Entries with Personal Data Not Be Deleted?

They must not be deleted if there are legal obligations that would make the continued storage necessary. One of the most prominent obligations, for instance, is a guarantee or warranty, meaning that no data should be deleted as long as a guarantee or warranty is in force. In addition, data must not be deleted if the retention period of six, 10, or 30 years (there may be other periods in other countries) has not yet expired or the data need to be retained indefinitely. This period starts at the beginning of the year that follows the year in which the services were performed.

No personal data should be deleted as long as a guarantee or warranty is in force.

How Do I Solve This Dilemma?

It would be best if personal data did not end up in crossTank at all. This can be achieved if the source text paragraph only contains personal data without any additional text that would have to be translated. In this case, do not enter anything in the Target Editor and directly set the paragraph to the "translated" state. In the window that opens up, click "Keep source". This way, this paragraph will not be stored as a crossTank entry.

On the other hand, if you have to store a paragraph in crossTank because it contains text that has to be translated, you can easily mark crossTank entries that contain personal data with system attributes after some preliminary work. But after that, you can delete all relevant entries almost automatically.

Create two system attributes under Tools System SettingsSystem Attributes. For example, you could name one of the system attributes "GDPR_Year" and the other one "GDPR_DataSubject". What you name these attributes does not really matter as long as you remember what they stand for.

If you have to store a paragraph in crossTank because it contains text that has to be translated, you can mark the entries that contain personal data with system attributes.

Then add the attribute values "2019", "2020", etc. to the attribute "GDPR_Year". Also check the "Default " box for the attribute value "2019".

In 2020, remove the checkmark from "Default" and check the box for "2020" and so on. The attribute values for "GDPR_DataSubject" will be added while you are working. Here, you can e.g. enter the name of the respective data subject.

Accustom yourself to a certain pattern and allow for name duplicates. You can change attribute values without closing crossDesk.

After translating a paragraph in crossDesk that contains personal data and saving it to crossTank, click the button at the bottom right in the Search Center to "Edit" the crossTank entry.

Click "Add attribute" in the window that opens up and add the two attributes to the entry together with the applicable values.

What Happens to Old Personal Data?

Have you already been working with Across for several years, and have you already collected quite an amount of personal data in crossTank? You can of course go and open up all old projects and tasks one by one and mark the entries as described above. But it will be a lot easier to use the crossTank Manager.

However, this is still a tedious job because you have to find the data in crossTank. To do so, open the crossTank Manager by clicking the respective dashlet on the dashboard.

On the left-hand side, you will see the Search Bar:

Accustom yourself to a certain pattern and allow for name duplicates. You can change attribute values without closing crossDesk.

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First of all, set the language pair for which you would like to search for entries. The language to the left will be the language in which the search term is. Below that, enter the search term. This may be a name, a date, an address, or any other personal data that could possibly identify a person.

In most cases, the Concordance Search will do the job nicely. You may search for several search terms with the Concordance Search. If you do so, only the that contain all search terms will be displayed. The search terms do not have be next to each other in the crossTank entry.

The Advanced Search allows you to use the wildcard character "*" (= "no character" or "any number of characters") as well as the Boolean operators ("AND", "OR", and "NOT").

Click the filter icon next to the search mode to activate the filter settings. For example, you can set a filter on "Date" to limit the search to a certain period of time, or on "Subject", "Relation", "Project", or "User-defined system attributes" to limit the search accordingly.

Using the respective icon in the icon bar below, you can now mark the entries as described above. You can also select several entries and mark them all at once.

Using the respective icon in the icon bar at the top of the hit list, you can delete the translation unit(s) from your crossTank that are ready to be deleted.

From now on, you can search or filter for entries with these attributes in the crossTank Manager as described above, or you can use the crossTank Maintenance function at the request of the data subject or upon expiry of the legal retention period in order to delete the entries in one go.

When using the Maintenance function, simply click the respective fields to determine your filtering conditions. Take a look at the Preview before deleting the entries in order to make sure that only the entries that you actually want to delete have been selected.

If necessary, adjust the filtering conditions or use the Concordance Search or the Advanced Search in the crossTank Manager. After clicking "Continue", you will be asked for confirmation. If you confirm this message, all selected entries will be deleted.

Important: Be sure to back up your data before editing your entries on a grand scale so that you can restore them in case you have mis-edited your data on a grand scale.

This article only focuses on the data in your Across Translator Edition or rather crossTank. Quite possibly, the same data may exist in your documents or backups on your hard disk. Obviously, you will have to take care of these separately.

About the Author

Andreas Rodemann is a graduated translator with Chinese and English as working languages. He has been working as freelance translator with Across since 2009. Besides this, Andreas Rodemann has been moderator for many years and since 2014 owner of the “Übersetzer- und Dolmetscher-Lounge” (Translators and Interpreters Lounge) at XING where he is assisting fellow translators and interpreters with words and deeds far beyond Across topics.

Website: AR-Übersetzungen