Last reviewed March 2022
This policy also explains your rights in relation to your personal data and how to contact us or supervisory authorities if we collect, use and are responsible for certain personal data about you. We are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to any services we offer to individuals and our wider operations in the European Economic Area (EEA).
It would be helpful to start by explaining some key terms used in this policy:
|We, us, our, SoA||The Society of Authors, a company incorporated and registered in England and Wales with company number 00019993 and its registered office at 24 Bedford Row, London, England, WC1R 4EH and its group companies, charities and associated trusts.|
|Our data protection officer||Peter Kennedy,|
Head of Member Services
020 3880 2230
|Personal data||Any information relating to an identified or identifiable living individual|
|Special category personal data||Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data (when processed to uniquely identify an individual) Data concerning health, sex life or sexual orientation|
|Data subject||The living individual who the personal data relates to|
The personal data collected about you depends on the particular services provided to you. The following personal data about you may be collected and used by us or by third parties acting on our behalf:
- your name and contact information e.g. your postal address, email address and telephone number (Contact Data)
- information to check and verify your identity e.g. your date of birth (Verification Data)
- your membership number or other unique reference numbers and identifiers (URNs)
- your payment information e.g. your membership fee, your payment history and your payment card information (Payment Data)
- information about your professional activities, interests and output e.g. contracts, details of your agent or publisher, details of your royalty entitlements, your LinkedIn profile (Professional Data)
- your correspondence, contact and activity history e.g. enquiries you have made, petitions you have signed, surveys you have completed, grants and prizes which you have received (Historical Data)
- Your voice and visual recordings e.g. CCTV in the Event Space, incoming telephone call recording and recordings of committee meetings (Voice/Image Data)
Your personal data is collected and used for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide the requested personal data, it may delay or prevent us from providing services to you.
Most of this personal data is collected directly from you—in person, by telephone, text or email and/or via our website. However, information may also be collected:
- from publicly accessible sources e.g. Companies House or LinkedIn;
- directly from a third party e.g. professional bodies such as the Authors’ Licensing and Collecting Society (ALCS); and
- from a third party with your consent e.g. your agent or publisher;
- from CCTV, video and audio recordings.
Under data protection law, your personal data can only be collected and used if there is a proper reason, e.g.:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering into a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when there is a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out a Legitimate Interests Assessment (LIA) when relying on legitimate interests, to balance our interests against your own.
The table below explains how your personal data is used, and why, by us or by third parties acting on our behalf.
|What we use your personal data for||Our reasons||Relevant categories of personal data processed|
|Providing membership services to you||To perform our contract with you or to take steps at your request before entering into a contract.||All data|
|Managing and improving our business and services||Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract; —for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to our members in furtherance of the SoA constitution and objects.||All data|
|Updating and enhancing information, systems and services relating to our business, e.g. researching and analysing demographics, researching and analysing contract information, digitising records and archives||Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract; —to comply with our legal and regulatory obligations; —for our legitimate interests, e.g. making sure that we maintain our records and archives; making sure we can keep in touch with our members about existing memberships and new services; and making sure we deliver the best service to our members in furtherance of the SoA constitution and objects.||All data|
|Connecting you with other professional bodies, e.g. the Authors’ Licensing and Collecting Society (ALCS) who offer of free membership to SoA members.||For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to our members in furtherance of the SoA constitution and objects.||Contact Data URNs Professional Data|
|Enabling you to participate in surveys and competitions, sign petitions and apply for benefits, grants and prizes.||Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract; —to comply with our legal and regulatory obligations; —for our legitimate interests, e.g. making sure that we can keep in touch with our members about existing memberships and new services, and to be as efficient as we can so we can deliver the best service to our members in furtherance of the SoA constitution and objects.||Contact Data URNs Professional Data Historical Data|
|Marketing our business and services to: —existing and former members; —third parties who have previously expressed an interest in our business and services; —certain third parties with whom we have had no previous dealings; via our newsletter and otherwise||For our legitimate interests, i.e. to promote our business and services to existing and former members and others.||Contact Data|
|Enforcing legal rights or defending or undertaking legal proceedings||Depending on the circumstances: —to comply with our legal and regulatory obligations; —in other cases, for our legitimate interests, i.e. to protect our business, interests and rights.||All data|
|Ensuring the confidentiality of commercially sensitive information||Depending on the circumstances: —for our legitimate interests, i.e. to protect trade secrets, membership information and other commercially valuable information; —to comply with our legal and regulatory obligations.||All data|
|Preventing and detecting fraud against you or us, e.g. conducting checks to verify your identity before processing a payment||For our legitimate interest, i.e. to minimise fraud that could be damaging for you and/or us.||Contact Data Verification Data URNs Payment Data|
|Preventing unauthorised access and modifications to systems||Depending on the circumstances: —for our legitimate interests, i.e. to prevent unauthorised access to our membership data which could be damaging for you and/or us; —to comply with our legal and regulatory obligations||Contact Data Verification Data URNs Payment Data|
|External audits and regulatory checks, e.g. for investors, regulators or for the audit of our accounts||Depending on the circumstances: —for our legitimate interests, i.e. to demonstrate to investors, regulators or auditors that we operate at the highest standards; —to comply with our legal and regulatory obligations.||All data|
|Paying royalties to the literary estate beneficiaries that we represent||—to perform our contract with the beneficiaries of the literary estates that we represent.||Contact Data Verification Data URNs Payment Data|
|Audio and visual recording of calls, meetings and events||Depending on the circumstances: — for our legitimate interests, i.e. to help with note taking. Ensuring that accurate records of calls and meetings are kept. — for our legitimate interests, i.e. for the safety of all participants at our physical and online meetings and events.||Voice data Image/likeness Data|
How and why we use your personal data—Special category personal data
Certain personal data collected by us or on our behalf is treated as a special category to which additional protections apply under data protection law:
- personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership;
- data concerning health, sex life or sexual orientation.
We may process special category personal data for the purposes of: understanding inclusion, diversity, and representation in our organisation and in our profession; and producing and monitoring equal opportunities statistics on an anonymised basis.
You are not required to provide any/all special category personal data that may be requested and, should you choose not to provide it, your application for SoA membership and/or your ability to avail of our services will not be affected. Where we do process special category personal data, we will ensure we are permitted to do so under data protection laws by obtaining your explicit consent in writing in advance.
How and why we use your personal data—sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
We will use your personal data to send you updates (by email, text message, telephone or post) about our business and services, including surveys, competitions, petitions, grants, prizes and other activities, events and opportunities.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
- contacting us (see ‘How to contact us’ below); or
- using the ‘unsubscribe’ link in emails.
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell it to other organisations for marketing purposes.
We do not track individual your behaviour on our website or elsewhere. We do not use AI or algorithms to make decisions that affect you.
We may share personal data with:
- companies, trusts and charities within the SoA group;
- third parties we use to help operate our business and deliver our services, e.g. payment service providers;
- third parties approved by you, e.g. other professional bodies, e.g. the Authors’ Licensing and Collecting Society (ALCS);
- Researchers and archives
We only allow those organisations to handle your personal data if we are satisfied that they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above occasionally also share personal data with:
- our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations; and
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations.
Who we share your personal data with—in more detail
More details about who we share your personal data with and why are set out in the table below.
|Recipient||Processing operation (use) by recipient and purpose||Relevant categories of personal data transferred to recipient|
|APT Solutions (up to 2022) Compucorp (2022 onwards)||Provision of our membership database||All data|
|SharePoint facility hosted by Microsoft||Our digital member files are securely stored on the SharePoint facility hosted by Microsoft||All data|
|Kentico platform hosted by Smart Impact||Parts of our website are built on the Kentico platform which is hosted and supported by Smart Impact||Contact Data URNs Payment Data|
|WordPress platform hosted by Cloudways||Parts of our website, including event bookings, purchase of guides and insurance, are built on the WordPress platform, hosted by Cloudways||Contact Data URNs Payment Data|
|MailChimp||Our mailing lists are hosted by MailChimp||Contact Data|
|Stripe||Credit card payments made to us, whether online or by phone, are processed by Stripe.||Contact Data Payment Data|
|Zoom and Vimeo||Our online events are hosted and run using a range of platforms including Zoom and Vimeo.||Contact Data|
|The Authors’ Licensing and Collecting Society (ALCS)||The ALCS offer free membership to SoA members||Contact Data URNs Professional Data|
|Civica||The SoA operates a democratic constitution, which includes the nomination, selection and election of members to our Management Committee. All full members are entitled to vote in this process, which is managed securely by Civica.||Contact Data Verification Data URNs|
|Bradbury Phillips royalty accounting software||The Literary Estates team use Bradbury Philips royalty accounting software to administer the accounts of the estates that the SoA represents.||Contact Data URNs Payment Data|
|BrightHR||Employee data is stored securely on the Bright HR platform||All data|
|IMPROVE||Employee data is stored securely on the IMPROVE online learning platform||Contact Data|
|SAGE accounting and payroll software||Employee data is stored securely on the SAGE accounting software for payroll and also to make payments for expenses.||Contact Data Payment Data Verification Data|
|The Royal London Mutual Insurance Society Limited||Employee pension data is transferred via a secure portal covered by the legal requirement for processing pension contributions.||Contact Data Payment Data Verification Data|
|The British Library, Reading University and other libraries and archives||To provide storage and archive services.||Contact Data Professional Data|
|External IT consultants||To provide support and development services in relation to our systems and databases.||All data|
|Legal and other advisors, trade union and regulatory authorities, courts and government agencies||To enforce our legal rights, or to protect the rights, property or safety of our workers or members, or where disclosure is permitted or required by law||All data|
Who we share your personal data with—further information
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.
We will not keep your personal data for longer than we need it for the purpose for which it is used. For example, e.g.:
- Verification Data, URNs, Payment Data and any other data used for the purposes of providing membership services to you and/or managing and improving our business and services will be kept for as long as you are a member of the SoA, and may be kept for at least six (6) years after you cease to be a member of the SoA (in line with the Statute of Limitations) after which period your data may be deleted or anonymised;
- Contact Data, URNs, Payment Data and Historical Data used for the purpose of enforcing legal rights or defending or undertaking legal proceedings, preventing and detecting fraud against you or us, preventing unauthorised access and modifications to systems and/or external audits and regulatory checks (e.g. for investors, regulators or for the audit of our accounts) will be kept for as long as you are a member of the SoA, and may be kept for at least six (6) years after you cease to be a member of the SoA (in line with the Statue of Limitations) after which period your data may be deleted or anonymised;
- Contact Data used for the purpose of marketing our business and services to existing and former members, third parties who have previously expressed an interest in our business and services, and certain third parties with whom we have had no previous dealings (via our newsletter and otherwise), may be kept indefinitely unless/until you ask use to remove your Contact Data from our database; and
- Contact Data and parts of your Professional Data and Historical Data used for the purpose of updating and enhancing information, systems and services relating to our business (e.g. analysing demographics, analysing contract information, digitising records and archives) may be kept indefinitely unless/until you ask use to delete or anonymise your data from/in our database.
- Audio Data will be recorded from all incoming calls for training purposes and to aid with processing complaints. Audio Data will be kept for seven days.
- Visual Data will be recorded in the Event Space for safety purposes and to aid with processing complaints. Visual Data will be deleted after seven days.
- Audio and Visual Data will be recorded at meetings to aid note taking. Audio and Visual Data will be kept until the minutes have been signed off as accurate at the next meeting or after 12 months, whichever is sooner.
Different retention periods may apply for different types of personal data from time to time. You can find out more about our retention periods by contacting us (see ‘How to contact us’ below).
The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
- in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here.
- in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here.
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
- a specific exception applies under relevant data protection law.
Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) on the basis of legally approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) on the basis of legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.
Transferring your personal data out of the UK and EEA—further information
If you would like further information about data transferred outside the UK/EEA, please contact us (see ‘How to contact us’ below).
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal data|
|Rectification||The right to require us to correct any mistakes in your personal data|
|Erasure (also known as the right to be forgotten)||The right to require us to delete your personal data—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data|
|Data portability||The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|To object||The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims|
|Not to be subject to automated individual decision making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
|The right to withdraw consents||If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by [insert details as relevant depending on consents] Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn|
For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:
- contact us (see ‘How to contact us’ below);
- provide enough information to identify yourself (e.g. your full name, address and any URNs applicable to use) and any additional identity information we may reasonably request from you;
- let us know what right you want to exercise and the information to which your request relates.
We have appropriate organisational, security and technical measures in place to prevent personal data from being accidentally lost, or used or accessed unlawfully, e.g.:
- We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner after GDPR training and are subject to a duty of confidentiality.
- If you interact with us online (e.g. via our website, on social media, to make an online payment to us, in surveys or event booking system) those interactions will be conducted in environments protected by SSL encryption technology.
- If you engage in an email exchange with us, whilst we cannot guarantee the security of email communications, your email correspondence will be stored securely on our email and, if appropriate, member filing systems.
- If you make a payment to us online, we will never retain a copy of your credit or debit card details. Our third-party payment processors will securely retain and process the information they need to process your transaction.
- If you apply for membership, a grant, or a prize using a paper application, it will be scanned into electronic format and stored in a password and firewall protected facility, and the paper copy will be shredded.
- Data files shared by us with any third parties will be password protected.
- Before introducing any new systems or technologies relevant to the processing of your personal data, we will where necessary and appropriate undertake and complete a data protection impact assessment (DPIA) identifying any associated risks.
- When processing any special category personal data, we will anonymise or pseudonymise that data (e.g. by removing identifiers such as names and address and using URNs only) to minimise the damage that may be caused by a data breach.
- We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
- We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:
- the Information Commissioner in the UK; and
- any relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA.
The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
For a list of EEA data protection supervisory authorities and their contact details see here.
This privacy notice was published on 15 February 2022 and last updated on 15 February 2022.
We may change this privacy notice from time to time—when we do, we will inform you via our website or by email.
Our contact details are shown below: