1. Privacy notice
1.1 Who are we?
This is the privacy notice of The Copyright Licensing Agency Limited (CLA).
We are committed to protecting your personal data. This privacy notice will inform you as to how we use and look after your personal data when you provide it to us via our website, or as part of our licence agreement with you, or personal data obtained in any other way, and tell you about your privacy rights.
We collect personal data through:
- Media Monitoring Organisations
- Data Collection Exercises
- Annual Data Returns (ADRs)
- The Department of Education
- Licensing bodies for which we act as agents, including NLA and PMLL
- Organisations that act as an agent for CLA, including IAPS and English UK
- Use of our technology platforms including Digital Content Store & Keylinks
- Website enquiries
- Contacts with Rights holders and other Collective Management Organisations
- Lists provided by commercial third parties
- Marketing activities
- Recruitment activities
Personal data may be provided to CLA:
a) by individuals, licensees, via data collection exercises, or web-based platforms (myCLA, DCS) and blogs. However, in some cases, contact information is obtained indirectly by CLA for the purpose of copyright licence sales and partnership with third party agents and suppliers. CLA is under a legal obligation to do this (see 'Our legal basis for processing personal data' below).
b) As part of recruitment activity when:
- you respond to an advert posted by us, whether via a job board, LinkedIn or other social networking site; or
- we download details uploaded by you onto a job board, LinkedIn or other social networking site in relation to a vacancy we are seeking to fill; or
- you contact us by phone, email or otherwise; or
- your information is provided to us by a recruitment agency
We are responsible for making sure the information we hold about you is kept secure and our processing of it complies with applicable legislation. If you have any questions about this privacy notice or how your personal data is used or to update your details please contact us using the details at the bottom of this notice.
CLA is a not for profit organisation which provides services to help customers legally access, copy and share the published content they need and ensure copyright owners are paid royalties for the use of their work. We provide rights and licences and services that simplify copyright and make it easier to access and manage content. e.g. Check Permissions search tool, Digital Content Store, Second Extract Service. To provide these services we need to collect personal data mainly for correspondence and communication purposes as part of the service provision. We are committed to ensuring that the information we collect and use is appropriate for this purpose. We will endeavor to keep your information accurate, relevant and up to date, and not keep it for longer than is necessary.
The types of personal data we would collect are:
Business contacts: name, telephone number, email address, usernames, job title, Business function, Business address, passwords, and photograph (for blog purposes with the consent of the subject),
Recruitment: Typically, this includes the applicant’s name, address, job title and contact details, and if you are being considered for a role, it will also include your CV as well as other details about your skills and experience, and the name and contact details of your referees.
Other: any other information you choose to provide to us.
The personal data we collect will be used for the following purposes:
- to register you and your organisation as a customer or licensee
- to provide you or your organisation with our service and fulfil our legal and contractual obligations to your business
- to provide news about CLA and its activities e.g. competitions, webinars, meetings etc.
- to manage our relationship with you, fulfil requests, and notify you of any changes to our services
- to administer, improve and protect our business and websites
- to verify that you hold a CLA licence or have the copyright owner’s permission to use copyright content in an authorized manner and so allow CLA to properly protect the interests of the copyright owners which CLA and its members represent
- for recruitment purposes (prospective applicants)
We will only use your personal data for the purposes for which we collected it, unless we reasonable consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose we will notify you.
Our legal basis for processing the personal data are:
- Where it is necessary to pursue what we believe to be the legitimate interests of our organisation, as a not for profit collective management organisation acting on behalf of rights holders and serving also their legitimate interests and those of other third parties
- Where we need to comply with a legal or regulatory obligation, such as the Collective Management of Copyright Regulations
- Where we need to do so to perform the contract with a data subject
- with your consent in some cases as set out below
We do not intend to collect any special categories of personal data about you.
We do not generally rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communication to you via email.
1.3 You may opt out of marketing communications or withdraw consent to specific activities at any time by updating your preference through the update preferences link provided in email communication or by contacting CLA, 5th Floor, Shackleton House, 4 Battlebridge Lane, London, SE1 2HX, or via firstname.lastname@example.org
1.4 If you fail to provide personal data
Where we need to collect personal data, for example under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you or other service we provide. We will notify you if this is the case.
1.5 Will CLA share my personal data with anyone else?
We may pass your personal data on to third-party service providers contracted to CLA in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the services they provide on our behalf and will dispose of the details when they are no longer needed to fulfil this service in accordance with our instructions.
In the event of a reorganisation, sale or takeover we may need to disclose personal information to the prospective buyer and any third party which may acquire the assets of CLA.
In addition, we may occasionally be required by law, a court order or governmental authority to disclose certain types of personal information e.g. to prevent fraud.
We will not otherwise pass on your personal data to third parties.
1.6 International transfers
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use providers based in the US, we would only transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection for personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
We have appropriate contractual provisions in place.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
1.7 Third Party Links
Our websites may include links to third party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy obligations. When you leave our website, we encourage you to read the privacy notice of every website you visit.
1.8 Retention period
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We are required to retain some information in accordance with the law and how long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
In the case of applications received for vacancies with us, we will retain the information you provide for 6 months. We will delete it after that time except where we need to keep any personal information to comply with our legal obligations, resolve disputes, or enforce our agreements.
1.9 Your rights as a data subject
It is important that the personal data we hold about you is accurate and correct. Please keep us informed if your personal details change during your relationship with us.
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you. On request, CLA will provide data subjects with copies of their personal data in a convenient format (via electronic means or otherwise). Where technically feasible, CLA will also meet any data subject’s request to transfer their data to a third party
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing
- Right of portability – you have the right to have the data we hold about you transferred to another organisation
- Right to object – you have the right to object to certain types of processing such as direct marketing
- Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling
If you wish to exercise any of the rights set out above please contact using the details below. We may require proof of identity to confirm who you say you are before we can respond.
We may update this privacy notice from time to time and will notify any changes as required by the law.
2. CLA contact details
If you have any questions about use of your data or would like to update your details please contact us using the details below:
Copyright Licensing Agency Limited
5th Floor, Shackleton House
4 Battlebridge Lane
If you wish to make a complaint about how your personal data is being processed by us (or third parties as described in 1.3 above), or how your complaint has been handled you can contact us on the addresses described above (2).
If you are unhappy with our response, you have the right to lodge a complaint directly with The Information Commissioners office at: www.ico.org.uk
We would appreciate the chance to deal with your concerns before you approach the ICO.
A cookie is a small file which is placed on your computer’s hard drive. This helps to analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
We also use a cookie to send information through our contact and application forms.
Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
If you'd like to know more about cookies and how to delete or control them, visit http://www.aboutcookies.org/
5. Change History Record
Initial issue: A Martin - 17 May 2018
Address update: R Owen - 29 January 2019