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Why NOT to localize GDPR implementation

Localization, Marketing

Suddenly your inbox is filling up with updated privacy policy notices from every company you have ever offered your name or email to. It’s worth taking a look at what they say — you’ll be surprised how obvious most of it sounds. You assumed your personal data was always treated with this level of respect. Sorry, it hasn’t been.

The General Data Protection Regulations (GDPR) were approved in the European Union in 2016 after four years or deliberation and edits, and enforcement commences May 25, 2018. Previous guidelines date back to 1990, five years before the oh-my-gosh-the-digital-era-is-upon-us classic THE NET. Clearly an update was overdue and while large multinationals have hired a small army of specialists to gracefully implement said rules, small businesses are scrambling to grasp the scope and find the time. Mostly because, sometime mid-April, they first heard of this and realized it applies to any company possessing the data of an EU citizen.

Our industry’s business is by default international, and it’s essential to understand these regulations apply to all EU citizens regardless where the data is processed. Companies in the United States, Japan or Zimbabwe must all comply when handling data of an EU citizen, but are not obligated to do so with data of non-EU citizens. Many language service providers (LSPs) consist of small teams with limited legal resources to implement GDPR, and if you’re freaking out right now that’s perfectly legit. Judging by Facebook’s decision to move 1.5 billion users from Ireland to California to avoid responsibility, most data-holders are.

Why not to localize GDPR

Always Localize?

Having a habit of localizing anything we can, it’s unsurprising we (MultiLingual) considered separating our EU clients from the rest in order to conform. Looking at the extent of our online database, that was going to be quite a task. It didn’t take long before we decided that applying the regulations to all data subjects, not just EU citizens, was going to be much easier. It’s actually more work to distinguish between the two and create separate policies, especially when you keep in mind odd cases like myself, who are permanent residents of the Unites States but hold EU citizenship. How will you be able to know this as a processor?

Another reason not to localize this effort — but instead apply it across the board — is that GDPR encourages trust. A fresh privacy policy and transparent opt-in choices are indicative of the kind integrity anyone hopes for. As a marketer, I like to think of opportunities rather than limitations. Sure, less people are going to opt in to receive direct mailers with sales pitches, but by distinguishing three categories of output instead of lumping them all into one, we’ll be able to customize delivery to our clients and prospects giving them a more appealing and personalized experience, hopefully resulting in a higher response rate. If you feel that GDPR offers timely basic respect and clarity, why not give all your customers the same peace of mind? Meanwhile, you are saving yourself some work and strengthening the tie with your clients.

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Marjolein realized early on that the Netherlands was too small for her. After traveling to 30+ countries over the span of 10 years she moved to the United States in 2014. She holds a degree in Communication from the University of Rotterdam and has long had an affinity for creative writing.


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Adobe announces a new, potentially horrifying level of personalization

Personalization and Design

“I was horrified.” That was reporter Eric Wood’s reaction to “unified profile” — the idea of collecting every online data point about a person into a single system. Modern consumers, says Adobe executive vice-president of marketing Brad Rencher, are “everywhere — they’re on mobile, social and they’re in your store. And they have multiple touchpoints including your loyalty programs, commerce systems, your support pages.” With that data spread out, it’s hard to personalize marketing across platforms. That’s why Rencher’s keynote at today’s Adobe Summit in Las Vegas focused on consolidating it into one profile tracking every data point about you.

Personalization began innocuously enough. Ideally, the approach helps both consumer and company. People get annoyed when they’re constantly presented with ads for stuff they’d never buy — no man, for example, wants a barrage of tampon ads. Audience precision clears out the junk. It also makes company operations more efficient: If businesses can get the right message to the right person and the right time, they’ll waste less time and make more money. In personalization, localization found an easy home: after all, what’s more personal than connecting in someone’s native language?

Adobe announces new personalization

But as I sit in the dark convention center listening to Rencher’s keynote, I have to ask: how personal is too personal? He starts talking about a woman who goes online to book a hotel, then hears the phone ring. Just as I would, she gets distracted, forgetting all about her en medias reservation. As someone who’s actually had this happen, and wound up paying double for the hotel as a result, I think, so far so good. Then Rencher begins to brag about how an ad for the hotel could follow her around — not just Google AdSense, the program that drops cookies in order to display bounceback ads on subsequent sites you visit, but Facebook display ads, texts — basically everything I use to communicate. Here, buy me, look at this, don’t you forget about me! Rencher sees a world with full integration of all your data everywhere — a single, unified profile where every data point about your life inevitably interacts. “How do we create a unified profile that enables you [the Adobe customer] to deliver a unified experience?” he asks.

It’s creepy.

And in Germany, it’s essentially illegal. The General Data Protection Regulation (EU/2016/679), more commonly known as GDPR, is a European regulation that shifts the definitions of personally identifiable information (PII) and what companies are allowed to do with it. Rencher calls GDPR the “four letters that will impact all of us.”

On July 5, 2017, Germany became first to adopt this standard. And just as your unified profile would follow you around, this European guidance is moving into other countries. US adoption begins May 25, 2018. Because translation companies are the ones personalizing websites, apps, and other data collection points, GDPR might come for localization next. The web, as we often say, is international, after all. You could be a New Zealand company translating into Ewe for a client in Brazil, but it doesn’t matter. As long as anyone in a GDPR-enforceable country can click on that translated site, this affects you.

A single, unified profile where every data point about your life inevitably interacts... Creepy. Click To Tweet

“How many of you in your organizations are able to recognize an inbound web hit is coming from Germany and be able to treat that data differently?” Rencher asks, “These are not easy challenges to solve if you’re dealing with and using legacy systems. Stitching all that data together can take months if not years.”

In addition to regulatory difficulties, Adobe also has a hard time dealing with the ethical implications of unified profile. In a post-keynote presser, reporters from NewsCorp, CMO Australia, IT Business, TechCrunch and others railed Adobe CEO Shantanu Narayen, chief technical officer Abhay Parasnis and Rencher, asking the same question about user privacy again and again.

After stressing that the onus of privacy protection falls on the user, Narayen said, “I think the rich number of questions around data and privacy really show that it’s front and center on people’s minds — on the enterprise’s mind.”

The ethics around data collection, whether people should opt in or out, and how well users truly understand the decision, are a topic for another day. But in the meantime, the localization industry should be thinking about how to prepare for a swingback. As more users turn off cookies and turn on ad blockers to keep AdSense et al from following, “personalization” could become a dirty word. And personalization is how we sell. If a swingback comes — if the broader public tires of ads or data collectors tracking them across platforms — will localization need a new message?

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Terena Bell is the senior director of communication for Lionbridge. She previously worked as an independent journalist who writes for The Atlantic, Washington Post, Fast Company and others. She is former CEO of In Every Language.


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