Privacy
This privacy notice relates to:
- PRS and MCPS members or applicants for membership;
- authorised representatives of PRS and MCPS members or applicants;
- individual (or individuals within our) licensees and business partners; and
- users of this website and PRS applications including the PRS member portal, Search Works and Works Registration.
1. What is in this notice?
This notice tells you:
- who we are
- what information we might collect from you
- what information we might collect about you from other sources
- how we might use your information
- what information of yours we might share with others
- how long we might keep your information for
- your rights about the personal information you give us
- how you can contact us
2. Who are we?
We are PRS for Music (‘PRS', 'we', ‘our’ and 'us’). We are one of the world’s leading music collective management organisations. We represent the rights of songwriters, composers and music publishers in the UK and around the world. As a membership organisation, we work to ensure that creators are paid whenever their musical compositions and songs are streamed, downloaded, broadcast, performed and played in public.
PRS for Music is a ‘data controller’ as defined in the UK GDPR and Data Protection Act 2018.
3. What personal information do we collect about you?
The information we may collect about you will vary depending on how you interact and engage with us.
a. Members and Applicants for membership
We collect information from you, including:
- your contact details;
- repertoire records;
- application forms;
- voice recordings of telephone calls with you;
- correspondence with us; and
- documents which support your application (e.g. proof of identity).
We may also obtain information about you from third parties (see point 4 below) and when you use our Website (please see point c below).
b. Licensees
We collect information from you, including:
- your contact details;
- any correspondence that you send to us; and
- licensing application forms and information which you provide to us for calculating whether a licence is required or the size of licence fee payable (for example, usage statistics or revenue information).
We may also obtain information about you from third parties (see point 4 below) and when you use our Website (please see point c below).
c. Website Users
We collect the information you provide on the PRS for Music website when you create an online account, submit membership application forms, apply for or take out a music licence, pay an invoice, sign-up to receive our newsletters and publications, accept our terms and conditions, enter a competition or survey and when you report a problem to us.
The information you give us may include:
- your name;
- address;
- email address;
- phone number; and
- financial and credit card information (collected via a secure payment processor).
We may also collect information about how you interact with our website (such as how long you spend on each page), whether certain cookies are stored on your device, as well as technical information such as the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. Please see our cookie policy for further details about this, including how we use this information.
d. Sensitive information
We will only collect sensitive personal information (also known as ‘special category personal data’) from you if you provide us with it. Sensitive personal information includes information about your racial or ethnic origin, religious or philosophical beliefs or sexual orientation.
For example, you may submit sensitive information such as your ethnicity or your sexual orientation if you choose to participate in one of our diversity surveys.
We will always explain what the information will be used for and, where required, obtain your consent to process it. Please see section 5.a for more information about information we use based on your consent and what rights you have.
4. What information do we collect about you from other sources?
We receive information from third parties where it is relevant to the services we provide to you, or where it is relevant to our compliance and enforcement activities. For example, we receive information from:
- your authorised representatives regarding your membership, licence application or in relation to any enquiries that your authorised representatives raise on your behalf;
- other collecting societies and agencies regarding the use of your repertoire, licences outside the UK or other compliance purposes;
- credit reference agencies, background check providers and your bank when we conduct a credit/background check prior to approval of your application for membership or a licence, for credit control purposes and prior to commencing an audit;
- other collecting societies for compliance and enforcement purposes, or where you have a licence in place with such societies covering territories outside of the UK;
- from industry stakeholders regarding the frequency of use of your materials (for example, radio play lists); and
- business partners and subcontractors who assist us in delivering our services to you (such as those in technical payment and delivery services) who may share your information with us (such as your contact and payment details).
We may also generate our own data about you on your historical or predicted earnings based on information we hold about you such as your royalty payment history (which is based on usage of your works) and information we receive from third parties (such as radio play lists). We use this information to make sure we are providing you with enough support in the course of providing the services.
5. How do we use your information?
We have to have a valid reason to use your personal information. This is called a “lawful basis for processing”. We process personal information under the following legal bases:
a. We use your personal information where you have given us your consent, such as:
- for diversity monitoring;
- to send you direct marketing by email in relation to our services, news and events or other products and services provided by us, our affiliates and carefully selected partner organisations (although these messages will always come from us);
- for the use of cookies and similar technologies in accordance with our Cookies Policy and the information provided to you when those technologies are used.
If you are a member:
- we will make your contact details available to the PRS Members’ Fund and the PRS Foundation. At your request they can contact you directly about the work they do, opportunities available to support them and services that may be of interest to you;
- we will share your email address with candidates for the Performing Right Society Directors’ Ballot in advance of the AGM each year so that the candidates can contact you directly by email with canvassing materials (NB. Voting and Principal Voting members are eligible to vote in the Ballot). Note that candidates may contact you with canvassing materials by post without your consent.
- where you are a Principal Voting member, we will use your name where you stand for election to the Members’ Council and your email address to the extent you support the nomination of another Principal Voting member.
When we process personal information based on your consent, you have the right to withdraw consent at any time.
b. We may process your personal information when we need to fulfil a contract with you, such as:
- processing your application for membership or a licence;
- undertaking bank checks on prospective licensees who are individuals;
- providing our services to you (such as distributing royalty payments and administering licences); and
- communicating with you in the course of fulfilling our contract.
c. We process your personal information when we have a legitimate interest to do so (provided that our interests are not overridden by your data protection rights).
Our legitimate interests include where we use your personal information to:
- verify your identity for identity verification and fraud prevention purposes (including by carrying out checks on your identity using third party registers, databases and credit/background providers);
- provide certain services you request (including membership services);
- verify music usage under the terms of a licence, or to establish whether a licence is required;
- carry out market research;
- inform strategic development/business intelligence purposes;
- personalise our website, products or services for you;
- maintain and administer licensee and membership records;
- investigate and respond to comments, complaints, enquiries or requests you or others may send us;
- send you important information about PRS for Music Limited or your account;
- exercise our contractual rights (such as those established under the Membership Agreement and licence agreements);
- personalise, monitor, improve and protect our products, content, services and websites, both online and offline;
- conduct marketing using social media third-party websites. Note that this includes sharing hashed data with third party websites and/or social networks so that PRS related posts and advertisements are displayed to you (known as 'custom audience'). The third party website will only see the data if it is already used for an account on their site. If you don’t want your data to be matched with the social media websites you use, let us know by contacting the Membership team. You should also be able to change your settings directly on the social media website;
- administer our business in accordance with our Code of Conduct and Constitution (for example, running general meetings, running appointments to the board); and
- deal with legal claims and compliance, regulatory and investigative issues (for example, debt recovery) as necessary (including disclosure of such information in connection with legal process or litigation).
d. We may process your personal information to comply with our legal and regulatory obligations. For example:
- preventing, investigating and detecting crime, fraud or anti-social behaviour and complying with information requests from law enforcement agencies;
- to comply with legally binding requests for information by government or law enforcement authorities; and
- to comply with legally binding requests received under the Companies Act 2006, including, for example requests to disclose member names and postal addresses to candidates for the Performing Right Society Directors’ Ballot in advance of the AGM each year so that the candidates can contact members directly by post with canvassing materials.
6. Who do we share your personal information with?
“Affiliates” means International Copyright Enterprise Services Limited; ICE Operations AB; the Network of Music Partners A/S; ICE International Copyright Enterprise Germany GmbH and PPL PRS Limited.
a. Affiliates
We may share your personal information in connection with the administration of your membership or licence with the Performing Right Society Limited, the Mechanical-Copyright Protection Society Limited and Affiliates.
b. Collecting societies
We may share your personal information with other collecting societies in order to enable them to administer licences outside the UK, when needed to deal with queries or to enable them to pursue legal action on behalf of PRS.
c. PRS for Music related organisations
We make the personal information of members available to the PRS Members’ Fund, where you have contacted the PRS Members’ Fund and provided them with permission, they will be able to check details of and access information about your membership.
With your consent, we may also share member contact details with the PRS Members’ Fund and the PRS Foundation for marketing purposes.
d. Other members or licensees
The information contained in the PRS Search Works database is made available to other members and licensees. Please refer to the terms of use for PRS Search Works for further information.
We share personal information of members relating to work registrations with licensees in order to (a) improve the accuracy of their usage reporting; and (b) enable them to attribute authorship of works to end-users.
We also share information relating to licensing status with library members where requested for synchronisation licensing purposes.
e. Agents or representatives of members
We may share the personal information of members with agents or representatives authorised to deal with us on a members' behalf.
f. Licensee agents or industry bodies
We may share the personal information of licensees with agents or industry bodies who carry out licensing operations for us (e.g. the Centre for Education & Finance Management ‘CEFM’).
g. Government authorities and/or law enforcement
We may share information with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if we have a legitimate interest in doing so in order to comply with applicable laws.
h. Performing Right Society Director candidates
We may share personal information relating to members with candidates for the Performing Right Society Directors’ Ballot for canvassing purposes.
i. Parties connected with an acquisition of the business
In the event that the business is sold or integrated with another business, we may share personal information with our advisers, any prospective purchaser’s advisers, and the new owners of the business.
j. Credit/Background check providers
We may share limited information with credit/background providers in order for these organisations to carry out identity checks on our behalf for identity verification and fraud prevention purposes.
k. Other third parties
We may share personal information with selected other third parties not listed for the purposes identified above. Such third parties include professional advisors, website hosting and maintenance providers, event booking platform providers, credit reference agencies, banks (where we have contacted them to ask for verification that you are able to make licence fee payments), marketing software providers and marketing agencies, internal systems providers and system integrators (such as in relation to our client relationship management system, finance systems and communication systems), third party websites and/or social networks, Ofcom, credit/background check providers, event organisers, e-voting platforms (to assist in internal election processes), music usage monitoring providers, and parties connected in litigation or legal processes.
7. How long do we keep your information for?
The length of time we keep your information will vary depending on the purposes for which we hold it for.
To determine the period we store personal information for, we apply the following principles:
- we will only keep your information for as long as we need to, and
- we think about what type of information it is, the amount collected, how sensitive or intrusive it might be and any legal requirements.
The table below sets out in more detail the periods for which we hold certain types of personal information.
Type of personal information | How long we keep it for |
---|---|
Personal information that we hold in the context of a membership | Generally, up to 6 years after you cease to be a member or licensee We may retain information relating to royalty distributions for longer than 6 years where necessary For information from identity verification checks undertaken on application for membership, up 3 months after the check or up to 6 years after a membership application is refused based on this information |
Personal information that we hold in the context of a licence | Up to 6 years after you cease to be a licensee |
Personal information in connection with performing another type of contract (such as providing you with access to an event) | Up to 6 years after your last interaction with us |
Where we process personal information for website security purposes (e.g. log-in credentials and IP addresses) | 26 months |
Once the purpose for which we hold your data has been fulfilled, we will securely delete or anonymise your information (so that we, or anyone else, can no longer tell that data relates to you) unless we are required to retain the data for legal, tax or accounting reasons.
8. International Transfers of Personal Information
Your information may be sent outside the United Kingdom ('UK'). For example:
- Information about members and licensees will be sent to other collecting societies (which are located worldwide);
- Information about members' repertoires is shared with other members and licensees (who can be located worldwide);
- Information about website users, members and licensees may be shared with third party service providers (who can be located worldwide).
Where your information is transferred to a country that is not deemed to adequately protect personal data under applicable data protection law, we take steps to ensure your information is protected, for example by using approved model clauses. For further information on international transfers, please submit a request using the contact details set out below.
9. Children and Personal Data
PRS understands the importance of safeguarding the personal data of children, which we consider to be individuals under the age of 13 or the equivalent age as specified by law in your jurisdiction. We do not knowingly collect information relating to children unless a membership application has been submitted on behalf of a child. In this case, an individual with parental responsibility for the child needs to complete the application form on the child’s behalf.
10. Use of cookies
We use cookies and other tracking technologies on our website and in some of our emails. Please see our Cookie policy for more details on the cookies and tracking technologies which we use, and the purposes for which we use them.
11. Registered users
Certain sections of this website are only open to registered users and give those registered users the ability to review and modify personal information previously provided to us. 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. Please notify us in the event that such information is revealed to, or accessed by, anyone else or if you become aware of a breach of confidentiality or any unauthorised use of this website.
12. Other websites
Our website may contain links to other websites which are run by other companies. The companies will have their own privacy notices and are therefore not covered by this notice. We have no control over the content or privacy practices of those other companies. We encourage you to read the privacy notices on the other websites you visit.
13. Your rights in relation to how we use your personal information
You have the right to ask us for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement).
You have the right to object to and opt-out of marketing. If you opt-out of receiving marketing emails you will still receive non-marketing emails from PRS for Music which contain essential information about your membership or licence including updates regarding royalty distributions, AGMs and any fundamental changes to how we operate as a society.
You also have the right to withdraw consent wherever we rely on your consent to use your data. See section 5 for more information on when we rely on consent.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.
Please note you may be asked to supply us with proof of identity and other additional information before we will be able to provide you with a response to your request. We aim to respond within one month of receiving your request or identifying information (if required), and we will let you know if we anticipate your request taking any longer.
If you wish to submit a request in relation to any of the rights above, please see section 14 below
14. Contact Us and Complaints
If you have any concerns, we would like you to give us an opportunity to help resolve them. To submit a query or complaint, please email dataprotection@prsformusic.com or write to us at:
Data Protection Queries
Legal Department
PRS for Music Limited
Goldings House
2 Hays Lane
London SE1 2HB
If you do not think we are handling your personal information adequately or you have unresolved concerns, you have the right to lodge a complaint with an EU data protection authority where you live, work or where you believe a breach may have occurred.
In the UK, the privacy regulator is the Information Commissioner’s Office (‘ICO’). For further information, including contact details, please visit www.ico.org.uk.
15. Changes to this privacy notice
This Privacy Notice will be amended from time to time if we make any changes in the way we collect, store and use personal information. Where these changes are significant or we think you need to be aware of them, we will take steps to notify you of the changes.