If you plan to use an external transcription provider for research interviews, focus groups or other recorded material, your ethics application may need to explain how the files will be transferred, accessed, transcribed, retained and deleted.
This guide provides questions to answer and sample wording to adapt. It is not legal advice, and it does not replace your university’s ethics, information-governance, procurement or data-protection procedures. Your wording must describe the project and the transcription service actually commissioned.
What to confirm before writing your application
Confirm the practical arrangements before copying wording into an ethics application, data-management plan, data protection impact assessment or participant information sheet.
- What personal data will the recordings contain?
- Will participants remain identifiable?
- Will the material include special category or particularly sensitive data?
- Will transcription be completed by people, automated speech-to-text, or a combination?
- How will recordings and transcripts be transferred?
- Where will files be stored and processed?
- Who will be permitted to access them?
- What confidentiality arrangements will apply?
- Will names or other identifiers be removed or replaced?
- How long will source files and working copies be retained?
- How and when will files be deleted?
- Is a Data Processing Agreement or confidentiality agreement required?
- Does the supplier need to complete an information-security review?
- Does the description match the participant information and consent materials?
Use the examples below as starting points only. Replace every bracketed instruction and check that the final wording reflects your institution’s requirements. Do not describe a supplier as “approved” until the relevant approval process has been completed.
Suggested wording to copy and adapt
General wording for outsourced transcription
Audio or video recordings will be transferred to an [approved/external] transcription provider using an agreed secure transfer method. Access will be restricted to personnel involved in providing the transcription service. The provider will process the recordings only for the purpose of preparing the required transcripts and in accordance with the agreed contractual, confidentiality and data-protection arrangements. Retention and deletion periods will be agreed before files are supplied.
Replace “approved” with the term used by your institution, and use it only after the required supplier checks have been completed.
Wording for human transcription
The recordings will be transcribed by human transcribers. Automated speech-to-text will not be used where the commissioned service specifies a fully human workflow. Transcribers will follow the project’s instructions concerning speaker labels, timestamps, anonymisation, formatting and the treatment of unclear speech.
Include this only when a fully human workflow has been confirmed in the quotation or service specification. University Transcriptions provides human transcription, but project requirements should still be agreed before files are uploaded.
Wording for confidentiality and restricted access
The transcription provider will restrict access to the recordings and working documents to personnel who require access in order to provide the agreed service. Those personnel will be subject to applicable confidentiality and data-protection requirements. The provider will not use the material for any unrelated purpose.
If your institution requires a particular form of confidentiality undertaking, confirm that it is in place before transferring data. University Transcriptions can provide its confidentiality undertaking and NDA information or discuss an organisation’s own agreement.
Wording for secure transfer and storage
Recordings will be sent to the transcription provider through the agreed secure upload facility rather than as ordinary email attachments. The provider will store and return files using the arrangements agreed for the project. Any project-specific restrictions concerning storage location, access or delivery will be confirmed before transfer.
State the actual method that will be used. University Transcriptions provides secure file-upload options; contact the team before uploading if the project has additional technical or geographic restrictions.
Wording for removing or replacing identifiers
The transcription instructions will identify the information that must be removed or replaced. Names and other agreed identifiers will be replaced with consistent participant codes or placeholders. The research team will review the returned transcripts and remains responsible for deciding whether further anonymisation is required before analysis, sharing or publication.
Be precise about whether data will be anonymised or pseudonymised. If a code or separate key can reconnect a transcript to a participant, the information is generally still personal data. See the ICO’s introduction to anonymisation.
Wording for retention and deletion
The transcription provider will retain source recordings, working files and completed transcripts only for the period agreed with the research team. The files will then be deleted in accordance with the agreed process. The research team will retain its research data in accordance with the approved data-management plan.
Replace general phrases with the actual periods wherever possible. Distinguish between the provider’s short-term operational retention and the research team’s longer-term retention of approved research data.
Wording for a Data Processing Agreement
Before personal data is transferred, the university and transcription provider will put the required data-processing terms in place. These will define the subject matter and duration of the processing, its purpose, the types of personal data and data subjects involved, the provider’s instructions, security requirements, retention and deletion arrangements, and the responsibilities of each party.
University Transcriptions has a Data Processing Agreement template. Your institution should decide whether that document, its own agreement or another form of contract is appropriate.
Wording for a participant information sheet
Your audio or video recording may be securely transferred to an external transcription provider acting on behalf of the research team. The provider will use the recording only to prepare the transcript under agreed confidentiality and data-protection arrangements. [Explain what identifying information will be removed or replaced.] [State when the provider’s copy of the recording and transcript will be deleted.]
Use language that participants can readily understand. It must be consistent with the ethics application and with the lawful basis and transparency information approved by your institution.
How to tailor the wording to your research
A short, accurate explanation is more useful than a long generic assurance. Add detail where the nature of the project requires it.
Interviews and focus groups
Explain how speakers will be labelled and whether the transcription provider will be given participant names. With focus groups, make clear that participants may identify one another during the discussion and that removing names from a transcript cannot undo disclosure within the group itself.
Health, clinical or other sensitive research
Identify any enhanced supplier checks, access controls or contractual requirements imposed by the university, research sponsor, NHS organisation or other relevant body. Do not assume that a general security statement is enough for the project.
Research involving children or vulnerable people
Describe the safeguards approved for the study and confirm whether the project requires personnel screening or restricted handling. Any project-specific vetting requirement should be raised with the transcription provider before commissioning.
Multilingual recordings
Specify whether you need a transcript in the original language, an English translation, or both. Explain whether identifiers are to be removed during transcription, translation or a later review by the research team.
Projects excluding automated transcription
If the ethics approval depends on a fully human workflow, state this expressly in the service specification as well as the application. Do not rely on a general description of the provider’s service when commissioning the work.
Common wording problems to avoid
- Calling a supplier “approved” too early: approval may depend on ethics, procurement, information-security and contractual checks.
- Using “GDPR compliant” as the whole explanation: describe the actual transfer, access, processing, retention and deletion arrangements.
- Calling pseudonymised data anonymous: data that can be reconnected to a participant remains personal data.
- Promising complete anonymisation without a specification: list the identifiers to be removed and who will check the completed transcript.
- Leaving retention open-ended: state the period or the event that will trigger deletion.
- Allowing documents to conflict: the ethics application, data-management plan, participant information and supplier instructions should describe the same process.
- Assuming the provider decides the lawful basis: the university or research organisation must determine the lawful basis and other governance requirements for its project.
Documents University Transcriptions can provide
University Transcriptions is operated by TP Transcription Limited. Before work begins, the team can provide information to assist with:
- research ethics applications and data-management plans;
- supplier questionnaires and information-security reviews;
- Data Processing Agreements;
- confidentiality agreements;
- retention and deletion instructions;
- project-specific transcription specifications; and
- current information about relevant security arrangements and certifications.
Supporting documents and policy links are available on the company policies and templates page. The university or research organisation remains responsible for deciding whether the proposed arrangements meet its legal, ethical, procurement and information-governance requirements.
Frequently asked questions
Can I copy the sample wording directly into my ethics application?
Use it as a starting point, then adapt it to your project and university requirements. Confirm the actual service, security, access, retention and deletion arrangements before submitting the application.
Does research consent always provide the lawful basis for transcription?
Not necessarily. Ethical consent to participate and the data-protection lawful basis are related but distinct questions. Your institution should determine and document the appropriate lawful basis and any additional condition required for special category data.
What is the difference between anonymisation and pseudonymisation?
Anonymised information can no longer identify a person by means reasonably likely to be used. Pseudonymised information replaces identifiers but can still be connected to a person using additional information, such as a participant-code key. Pseudonymised information remains personal data.
Do we need a Data Processing Agreement?
A written contract is normally required where a provider processes personal data on an organisation’s behalf. Your university should determine the appropriate contractual document and approve it before personal data is transferred.
Must the transcription provider be named in the ethics application?
This depends on the institution and project. Some applications require the supplier to be named; others require a description of the type of processor and the safeguards. Follow your university’s form and guidance.
Can University Transcriptions complete a supplier questionnaire?
The team can provide information about its service and security arrangements for supplier and information-security reviews. Send the questionnaire before uploading sensitive material so that the requirements can be considered.
Further guidance
The Information Commissioner’s Office explains the UK data-protection provisions applying to research and the need for appropriate safeguards in its guidance on the research provisions. Researchers should also consult their own institution’s current ethics, data-protection and information-security guidance.
Request project information or a quotation
If you need information for an ethics application, Data Processing Agreement, security review or transcription specification, contact University Transcriptions before uploading sensitive recordings.