Privacy Notice and Cookie information
Updated: August 2019
This privacy notice sets out how Publishers’ Licensing Services Limited (PLS) uses and protects any personal information that you provide when you use the PLS websites and services such as the PLS Account Manager, PLS Permissions service and Access to Research. 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 Data Protection legislation applicable in the UK: the General Data Protection Regulation 2016/679 (GDPR) and the Data Protection Act 2018 and any other applicable data protection legislation, including any UK laws amending, replacing or superseding the above.
In respect of personal information you provide to us by phone, email or when you use the websites and services above, we are the data controller of your personal data as defined in the Data Protection legislation and we have a legal duty to make sure the information we hold about you is kept secure, and is accurate, relevant and not excessive. You can find out more about Data Protection on the Information Commissioner’s Office (ICO) website, www.ico.org.uk.
Personal Information we collect
We process information about the types of third party individuals listed below:
Users of our Permissions 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
We may collect the following information, for example via the PLS websites, or when you use one of the PLS services such as PLS Account Manager, PLS Permissions Service, or Access to Research:
- 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.
- 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 information 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.
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.
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.
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 of the data subject 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 information 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 information we need to fulfil our contractual undertakings to your business, we may not to able to fulfil those obligations.
Sharing your information with third parties
Other than as set out below, we do not share your personal information with any third party.
ii) We may share your personal data with business partners, suppliers and sub-contractors within the EEA 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.
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 information.
We may occasionally be required by law, court order or governmental authority to disclose certain types of personal information, for example to protect the rights, property or safety of PLS or another party e.g. to prevent fraud.
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.
How long we hold your information
We will retain your personal information for as long as you remain a contact on the Publisher’s account on PLS Account Manager or any other PLS service such as PLS Permissions or Access to Research and for as long as is necessary for our legitimate business purposes and any legal requirements thereafter.
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 statement and you should look at the privacy statement applicable to the website in question.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information we collect online, covering both our internal processes and our external partners.
Communication with you
As described above, we may contact you from time to time to tell you about services we provide, or about PLS events. 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, as well as when we first collect your personal information.
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, 5th Floor Shackleton House, 4 Battle Bridge Lane, London SE1 2HX, or emailing us at email@example.com
You have the following rights in relation to your personal information:
- 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 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 legislation.
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 request details of personal information which we hold about you by writing to:
The Data Administrator, Account Services,
Publishers’ Licensing Services Ltd
5th Floor Shackleton House
4 Battle Bridge Lane
London, SE1 2HX
Or by email to: firstname.lastname@example.org
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 legislation.