Purpose of this Privacy Notice
In order for Directors UK to fulfil our function as a Collective Management Organisation (CMO), we process personal data which relates to our members, as well as non-member authors, other stakeholders and contacts. Directors UK is committed to maintaining the appropriate confidentiality, integrity and security of personal data that we process by complying with our legal obligations in respect of data protection and privacy. This policy sets out the principles Directors UK adheres to when processing personal data, how we process personal data and the operational aspects of our various data processing activities.
Full name of legal entity: Directors UK Limited
Email address: email@example.com
You have the right to make a complaint about the processing of your data at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the Privacy Notice and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current.
In order to help Directors UK keep your information up to date members may be asked at regular intervals to provide details of any changes to their information.
If any of the information that you have provided to Directors UK changes – for example, if you change your name, contact details or payment information, or if you wish to cancel your membership – please login to the website or contact firstname.lastname@example.org.
For changes to payment information please contact email@example.com.
Alternatively, you can write to us at our office address at the end of this policy.
Please keep us informed if your personal data changes during your relationship with us.
The Directors UK website may include links to third-party websites, plug-ins 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 statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. We may from time to time display advertisements from third parties on our site. In particular, unless expressly stated, we are not agents for these sites or advertisers nor are we authorised to make representations on their behalf.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you (member, non-member or website visitor) which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, pseudonyms, username or similar identifier, marital status, title, date of birth and gender.
- Sensitive Personal Data such as race/ethnicity.
- Contact Data includes postal address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Works Information: details of series and episode information for audiovisual works, such as TV programmes and films.
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, transactions with you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes correspondence with us, your preferences in receiving marketing from us and third parties, and your communication preferences.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply to become a member;
- subscribe to a service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- Indirect interactions. Where we may collect personal data about you from various sources.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy for further details.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party), namely to fulfil our function as a CMO in accordance with applicable law and regulations and to conduct and manage our relationship with specific individuals. Where we use your personal data for Directors UK legitimate interests, we make sure that we take into account any potential impact that such use may have on you and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
As a CMO, Directors UK is bound by the terms of The Collective Management of Copyright (EU Directive) Regulations 2016. These regulations legally require CMOs to take the necessary steps to identify, locate and pay fees due to non-member rights holders as well as member rights holders.
Generally we do not rely on consent as a legal basis for processing your personal data but where we do (as in the case of the sensitive personal data of members), you have the right to withdraw consent at any time by contacting us.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest or for official purposes.
Purposes for which we use your personal data
We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
- For the provision of our services to you in accordance with our mandate;
- To administer and maintain our records;
- To enable the exercise of your governance rights, providing notices and regarding company meetings and elections;
- To ensure that our services continue to be the most appropriate for your needs;
- To verify your identity;
- To respond to any query that you may raise with us;
- To update our systems to provide an enhanced service to you;
- To notify you about changes to our services;
- For the purpose of research and statistical analysis;
- For disclosure to law enforcement agencies;
- For disclosure to comply with our legal obligations;
- For our internal service monitoring; and
- To provide news and information about Directors UK and our activities.
Prior to introducing new systems or technologies relevant to the processing of personal data, Directors UK will undertake the necessary Privacy Impact Assessments (PIA) with a particular focus on any associated risks.
How we use particularly sensitive personal information
‘Special categories’ of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
We may process special categories of personal information in the following circumstances:
- In limited circumstances, with your explicit written consent.
- Where it is needed in the public interest, such as for equal opportunities monitoring.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
We may also process such information about members or former members in the course of legitimate business activities with the appropriate safeguards.
Marketing, news and information
Contact details of members are used to provide news and information about Directors UK and our activities. You can opt-out of receiving these notifications or change your preferences at any time using the ‘unsubscribe’ link provided in our emails or by contacting us at firstname.lastname@example.org.
From time to time we may run competitions on our website. As part of any such competition, we may use your Identity or Contact Data in relation to such competitions.
You can ask us or third parties working on our behalf to stop sending you marketing messages by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of being a member.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data for the purposes set out above with companies and organisations with whom we have agreements or who are otherwise contractually obliged to report to us to help supply, maintain or facilitate our member and distribution services. These third parties include our sister collecting societies, broadcasters and providers of payment or banking services.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not sell personal information to third parties.
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. For example, the information that we collect from you may be transferred to, and stored at, a destination outside the EEA. It may also be processed by staff operating outside the EEA who work for us or for one of our sister collection societies who we have reciprocal agreements with. Such staff may be engaged in, among other things, the administration of a contract between us, the processing of your payment details and the provision of support services. By you submitting your personal data to us, you agree to this transfer, storing or processing.
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.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
The Members’ Area of the Directors UK website requires entering a username/email address and password which is encrypted and known only to the member. The data that members provide online to Directors UK is also encrypted, protected by Secure Sockets Layer (SSL) encryption technology. We ask that you do not share usernames, passwords or any other secure access information with anyone – you are responsible for keeping this information confidential and secure. You must notify us in the event that such information is revealed to, or accessed by, anyone else or where you become aware of a breach of confidentiality or any unauthorised use of this website.
Although Directors UK strives to protect your personal data online, including through use of encryption and other measures, we cannot guarantee the security of any internet communication or transmission.
Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.
In the event of any breach of Directors UK’s systems impacting on the security of a member’s or any other individual’s personal data, Directors UK will inform the affected member(s) or individuals at the earliest opportunity describing the nature of the breach, the possible consequences and the measures being taken to remedy the situation in accordance with our procedures and applicable law.
Data retention – For how long will we use your personal data?
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 may keep our members data indefinitely during the lifetime of their membership unless a member has requested us to delete their information. Please see below for further information.
We may keep the following information indefinitely for processing purposes, so that we are able to continue to provide those aspects of the member or non-member services which continue beyond the term of your membership or association with us (for example, if we are required in the future to contact you in respect of royalties):
- Contact details
- Credits information and relevant documents relating to credits
By law we have to keep basic information about our members (including Contact, Identity, Financial and Transaction Data) for six years after they cease being members for tax purposes.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on these grounds as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us by writing to Directors UK, 3rd and 4th Floor, 22 Stukeley Street, London WC2B 5LR, or by email to email@example.com.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Please direct any comments or enquires relating to this policy to: The Chief Executive Officer, Directors UK, 3rd and 4th Floor, 22 Stukeley Street, London WC2B 5LR or via email to firstname.lastname@example.org.