CLA Privacy Policy

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1.1 Who are we?

The Copyright Licensing Agency Limited (CLA) is a company registered in England and Wales with company registration number 01690026 and registered office address at c/o Berg Kaprow Lewis LLP, 35 Ballards Lane, London, England, N3 1XW (referred to in this policy as “CLA”, “we” or “us” in this policy.

Our website address is https://cla.co.uk.

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.

Data Sources:

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 media access (NLA)
Organisations that act as an agent for CLA, including IAPS and English UK
Use of our technology platforms including my CLA Digital Content Store (DCS), Keylinks and Education Platform (EP)
Website enquiries
Contact with rights holders and other Collective Management Organisations
Data lists provided by commercial third parties
Marketing activities
Recruitment activities

Personal data may be provided to CLA:

by individuals, licensees, via data collection exercises, or web-based platforms (myCLA, DCS, EP) and blogs. In some cases, contact information is obtained indirectly by CLA for the purpose of copyright licence sales and partnerships with third-party agents and suppliers.
As part of recruitment activity when:

you respond to an advert posted by us, whether via a job board, LinkedIn or another social networking site; or
we download details uploaded by you onto a job board, LinkedIn or another 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 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, Education Platform, Second Extract Permissions 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 endeavour 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.

Website Visitor

When any user visits our website, cookies are used 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 also use cookies to send information through our contact and application forms. For more information on the cookies we use and the purposes for which we use them please see our Cookie Policy here.

Use of Personal Data

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 administer a prize draw or competition being run by CLA which you have entered
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 authorised manner and so allow CLA to properly protect the interests of the copyright owners which CLA and its members represent
for recruitment purposes (e.g. prospective applicants)

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 we need to use your personal data for an unrelated purpose we will notify you.

Our legal basis for processing personal data is:

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.

1.2 Consent

We rely on consent where we have obtained your active agreement to use your personal data for a specified purpose, e.g. if you subscribe to a newsletter provided by CLA.

When you enter a prize draw or competition organised by CLA you consent to our collection and processing of the information you provide to us for the purposes of administering the prize draw or competition.

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, c/o Berg Kaprow Lewis LLP, 35 Ballards Lane, London N3 1XW, or via email gdpr@cla.co.uk

1.3 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 services we provide. We will notify you if this is the case.

1.4 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 will be obliged to keep your details securely, and to use them only to fulfil the services they provide on our behalf and to 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.

1.5 International transfers

A few of our external third parties may be 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.

the country of transfer has been deemed to provide an adequate level of protection for personal data via government adequacy regulations
We have undertaken a risk assessment and appropriate contractual provisions, such as an International Data Transfer Agreement (IDTA) are in place.
Exceptionally, we may rely on an exception under the GDPR e.g. if it is in our compelling legitimate interest to do so.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

1.6 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.

1.7 Retention period

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including 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.

1.8 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 us 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.

CLA Contact Details

If you have any questions about the use of your data or would like to update your details please contact us using the details below:

gdpr@cla.co.uk

Complaints

If you wish to make a complaint about how your personal data is being processed by us by third parties as described in 1.5 above, or how your complaint has been handled you can contact us on the addresses listed above.

If you are unhappy with our response, you have the right to lodge a complaint directly with The Information Commissioners’ Office.

We would appreciate the chance to deal with your concerns before you approach the ICO.

Policy last updated: June 2024