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Privacy Notice and Cookie information

Updated: October 2023

This privacy notice sets out how Publishers’ Licensing Services Limited (PLS) uses and protects any personal data that you provide when you use the PLS websites and services such as PLS Account Manager, PLSclear and Access to Research or you sign-up to and/or attend our in-person or online events. If you provide any information to PLS by which you can be identified, it will only be used in accordance with this privacy notice. 

PLS is committed to ensuring that your privacy is protected and we endorse and adhere to the principles of data protection, as set out in the legislation applicable in the UK:  the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and any other applicable data protection legislation, including any UK laws amending, replacing or superseding the above (Data Protection Law). 

In respect of personal data you provide to us by phone, email or when you use the websites and services above, or which are provided to us in respect of our events, we are the data controller of your personal data as defined in UK GDPR and we have a legal duty to make sure the personal data we hold about you is kept secure, and is accurate, relevant and not excessive. You can find out more about Data Protection Law on the Information Commissioner’s Office (ICO) website, www.ico.org.uk. 

We may occasionally change our privacy policy by updating this page and will notify of any changes as required by Data Protection Law.


Personal Data we collect

We process personal data about the types of third-party individuals listed below:

  • Publisher contacts
  • Users of our PLSclear service: both rights holders and permission requestors
  • Contacts at libraries and local authorities in relation to our Access to Research Service
  • Other publishing industry contacts
  • Business contact details of suppliers
  • Individuals who may contact us with a query
  • Attendees at our in-person or online events  

We may collect the following personal data, for example via the PLS websites, or when you use one of the PLS services such as PLS Account Manager,  PLSclear, or Access to Research or when you sign-up to and/or attend our events:

  • Name, job title and organisation you work for.
  • Contact information including postal and email address and telephone number.
  • If you are signed up to any PLS services: information relevant to maintaining and updating that account, including financial information.
  • If you sign-up to and/or attend our events your diet and accessibility information.

We may also collect data from observing your use of PLS Account Manager or PLSclear and any data derived from this use. 

We collect only the data that is necessary for us to carry out the activities described below.


What do we do with this personal information, and the lawful basis on which we do it

We require and use this personal data for the following purposes:

i)       To provide you or your organisation with our services and fulfil our legal and contractual obligations to your business.
ii)      To fulfil requests you make.
iii)     To subscribe you to our electronic and print publications, giving you information on our service provision and performance of our contract(s) with you.
iv)     To update you on relevant news, events and publications related to our services and performance of our contract(s) with you.
v)      To contact you from time to time for research purposes. We may contact you by email, phone or mail.
vi)     To improve our websites.
vii)    To host our in-person or online events.
and for internal record keeping.

You are able to opt out of our e-bulletins ((iii) and (iv) above) by altering your communication preferences via your account if you do not wish to continue to be contacted in this way unless we are required by law to provide you with information in this way.

The legal bases of such processing are:

a)       our legal obligation to comply with the Collective Management of Copyright Regulations 2016 and related legislation.
b)       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 publishers and other rights holders and serving also their legitimate interests, to understand their business needs, to improve our services to them, and to respond to their requests. Before using your personal data for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you to ensure that your interests and fundamental rights and freedoms do not override those interests.
c)       to provide you with our services, and performance of our contractual obligations to your business under the PLS General Terms and Conditions and any other related agreements if you are an individual or a sole trader.
d)       in some cases consent in which case we will clearly seek your specific agreement to processing.  You may withdraw such consent at any time by contacting us via the contact details given below.

If you do not provide the personal data we need to comply with our legal requirements under the Collective Management of Copyright Regulations, we may not be able to pay your business the correct share of the revenue we collect. Similarly, if you do not provide the personal data we need to fulfil our contractual undertakings to your business or to provide you with services, we may not be able to fulfil those obligations.

 

Sharing your personal data with third parties

Other than as set out below, we do not share your personal data with any third party.

i)                   If you use our PLSclear service to request permission for republication the Publisher of the work will have access to your personal data, and the information you provide as part of the request, to enable provision of the services.  We are the data controller of any such personal data to the extent that we process such personal data.  The Publisher is the data controller of any such personal data to the extent that it processes such personal data. Under the PLSclear Licensing Services Agreement with PLS the Publisher agrees that it will not access, use or otherwise process any personal data obtained during the use of the PLSclear service for any purpose other than use of the services except on a lawful basis as notified to you, and in accordance with Data Protection Law.  Any such further use of your personal data by the Publisher will be governed by and subject to their privacy policy.
ii)                   We may share your personal data with business partners, suppliers and sub-contractors if necessary for the performance of any contract we may enter into with them or you.  For example, development, hosting and maintenance of our IT services are provided by third party service providers which host our data in accordance with our agreements with them. We continue to be the data controller of any personal data processed by these third parties.
iii)                 We may share your personal data with marketing platforms such as Dot Digital to process email communications for us.  We continue to be the data Controller of any personal data processed by these third parties. 
iv)                 If you log into third party sites such as Eventbrite in connection with an event we are organizing they may also become a data controller of your personal data in accordance with their own privacy notice.

We may disclose depersonalised, anonymous data (such as aggregated statistics) about the users of our service in order to describe our traffic patterns and other service information to prospective partners, advertisers, investors and other reputable third parties and for other lawful purposes, but these statistics will include no personal data.

We may occasionally be required by law, court order or governmental authority or in emergency/urgent circumstances to disclose certain types of personal data, for example to protect the rights, property or safety of PLS or another party e.g. to prevent fraud or if a serious issue arises at an event.

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 PLS.

 

Transferring your personal data internationally

Some countries outside of the UK and the EEA do not have laws that protect personal data in the same way as the UK and countries in the EEA. Therefore, in accordance with Data Protection Law, if we do transfer your personal data outside of the UK and the EEA, we ensure that your personal data is afforded a similar level of protection by ensuring such transfers are to countries which are recognised as providing an adequate level of legal protection by the UK and/or the European Commission or where one of the specific safeguards approved by the Information Commissioner’s Office (ICO) in the UK and/or the European Commission is in place. You can find further information about these safeguards at  International transfers | ICO and https://ec.europa.eu/info/law/law-topic/data-protection_en.  In the event that there is any change in the law such that one or all of the safeguards are no longer valid or applicable, we will ensure that we are satisfied that alternative arrangements / safeguards are in place to protect your privacy rights as required by the Data Protection Law.

 

How long we hold your personal data

We will retain your personal data for as long as necessary to fulfil the purposes we collected it for and to the extent necessary for legal or regulatory requirements and other legitimate interests taking into account that purpose as well as the amount, nature, and sensitivity of the personal data and the potential risk of harm from unauthorised use or disclosure. For example, you remain a contact on the Publisher’s account on PLS Account Manager or any other PLS service such as PLSclear or Access to Research for as long as is necessary to provide services to you or there is a legitimate need to communicate with you and for any legal requirements thereafter but diet and accessibility information provided for your attendance at an event will not usually be retained beyond the event.    

 

Links to external websites

Our website or communication with you may contain links to other websites such as Eventbrite and GoToWebinar. Once you have used these links to leave our site, we cannot be responsible for the privacy and security of any information which you provide to the site you are visiting which is outside the scope of our services to you. Such activities are not governed by this privacy notice and you should look at the privacy notice applicable to the website in question.



Security

We are committed to ensuring that your personal data is processed securely. In order to prevent unauthorised access or disclosure, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the personal data which we process and service providers who we share your personal data with are required to take appropriate security measures to protect your personal data. 



Communication with you

As described above, we may contact you from time to time to tell you about our contracts with you, the services we provide, or about PLS events. Unless we are required by law to provide you with information in this way, you have the right to ask us not to contact you in this way and we will provide a clear method for you to opt out of receiving this information in each communication that we send to you.
You may change your mind at any time or update your information by changing preferences in your account settings or writing to:

The Data Administrator, Account Services, Publishers’ Licensing Services Ltd, 1 St Katharine's Way, London, E1W 1UN, or emailing us at pls@pls.org.uk



Your Rights

You have the following rights in relation to your personal data:

  • the right of access to a copy of the information we hold;
  • the right to require us to correct the information we hold (and to help us, please inform us any of changes or corrections as soon as you can);
  • the right to request us to erase the information we hold in certain circumstances (but please note that we may not be able to provide services to you if you make this request);
  • the right to object to our processing or require us to restrict processing in certain circumstances;
  • the right in certain circumstances to request that we supply a copy of the data we hold about you to you in a digital form or transfer it in that form to another person or business; and
  • the right to lodge a complaint about our processing of your data with the Information Commissioner’s Office.

If you contact us in relation to use of your personal data, we will do our best to deal with your request as soon as we can, and in any event within the timescales required by the Data Protection Law. 

If you are unhappy with our response, unsure about your rights, or are concerned about how your personal data may be processed you should contact the ICO:   https://ico.org.uk/global/contact-us/

You may exercise your rights above including requesting access and/or details of personal data which we hold about you by writing to:

The Data Administrator, Account Services

Publishers’ Licensing Services Ltd

1 St Katharine's Way

London, E1W 1UN

Or by email to: pls@pls.org.uk 

We will endeavour to send you this information as soon as we can, and in any event within the time limits set out in the Data Protection Law.