Privacy Notice

We are PPL PRS Limited (‘PPL PRS’, ‘we’, ‘our’ and ‘us’). We are a joint venture between the UK’s two music licensing organisations – Phonographic Performance Limited (‘PPL’) and PRS for Music Limited (‘PRS For Music’) (operating on behalf of the Performing Right Society Limited (‘PRS’)).

We issue our customers with TheMusicLicence, which allows you to legally play or perform music in your business or organisation and covers virtually all commercially released music. For more information about us and TheMusicLicence, please click the link below.

We take data protection seriously and this privacy notice is intended to help you understand how we collect, use and/or share your personal information.

This is our main privacy notice. Additional terms or privacy notices may also apply to your personal data, as well as containing other important personal data about your dealings with us.

This privacy notice applies to the following groups:

  • Licensee (customer) – you are, or you represent (e.g. as an employee of), a potential, current or former licensee of PPL PRS Limited (licensing in its capacity as agent of PRS and PPL)
  • Visitor to our Website, including user of our online services – you use our website or any of our online services (e.g. webchat, payments or licence purchasing)
  • Copyright Infringement or Debt Enforcement – you are connected to an investigation about potential infringement of copyright, or you owe outstanding licence fees to us
  • Rightsholders – you hold rights in or relating to musical works and/or sound recordings that are vested in, or managed by, PRS or PPL or have performed a musical work of a PRS member
  • Marketing, Surveys, Competitions and Online Content – you: (i) receive our marketing, (ii) complete surveys, (iii) enter a competition (or a competition we have sponsored), or (iv) appear in our online content (including social media pages)
  • Events or Office Visitor – you visit our offices or attend events we organise or participate in
  • Third Party Relationship – you are, or you represent, one of our suppliers, business partners or any other organisations we engage with
Type of data subjectTypes of personal information may include
Licensees

As our licensees are businesses or organisations, much of the information that we collect, and use, is not personal information. However, some elements of the licensing process will require personal information, such as where we correspond or speak with an individual that represents your business or organisation, or where your business trades as a sole trader or partnership. This personal information may include:

  • your name and contact details
  • payment details (as appropriate)
  • licensing application information and music usage declarations
  • correspondence with us
  • recordings of communications with you (e.g. calls and transcriptions thereof (where available))
  • date of birth (sole trader licensees)
  • interactions with emails that we send to you (such as whether you open the email or select links within it)

We conduct website research, site visits and/or mystery shopping reports relating to venue music usage. These activities do not typically result in personal information being collected, but we have included these details here for completeness.

Visitor to our Website, including user of our online services
  • your name and contact details
  • recordings of communications with you (e.g. web chat)
  • information you may choose to provide in interactions with us (e.g. contact form, online payments)
  • if you are a registered website user, your login details
  • if you abort an online service, details of your abandoned transaction
  • information about your use of our website and website services, this may include:
    – access and usage information (e.g. IP address, log ins, access logs, search request activities)
    – details about how you interact with our webpages (e.g. time spent on content)
    – information collected by cookies, please see our cookie policy for further details about this
Copyright Infringement or Debt Enforcement
  • name and contact details
  • information about infringing actions or unpaid licence fees
  • repertoire details relating to musical works and/or sound recordings which may be infringed
Rightsholders
  • set lists, which may include details of musical works and/or sound recordings
  • name and details that confirm that rights in relation to repertoire are vested in, or managed by, PRS and/or PPL
Marketing, Surveys, Competitions and Online Content
  • your name and contact details
  • organisation(s) you are affiliated with
  • information provided as part of completing a survey or competition
  • information prepared for online content (e.g. social media pages)
  • images/video/sound recordings (where you submit content, tag us or otherwise give consent)
  • interactions with emails that we send to you (such as whether you open the email or select links within it)
Events or Office Visitor
  • your name and contact details
  • organisation(s) you are affiliated with
  • accessibility or dietary requirements (voluntary)
  • images/video/sound recordings (e.g. CCTV and event photography)
  • recordings of communications with you (e.g. calls)
Third Party Relationship
  • your name and contact details
  • organisation(s) you are affiliated with
  • any correspondence with us

We collect information about you either from you directly or from the following sources:

  • our authorised licensing agents regarding the licence that has been issued to you (for example certain trade bodies may issue licences under an agency arrangement with us)
  • where applicable, your authorised representative regarding your licence or in relation to any enquiries that your authorised representative raises on your behalf
  • PPL, PRS for Music and PRS in order to provide our services to you, as well as for licence analysis and development purposes, management and distribution of licence fee monies and for investigation of copyright infringement
  • publicly available information (e.g. press articles, websites, social media, site visits, mystery shopping reports), and submissions from third parties (such as using the reporting tool on our website), in relation to identifying the requirement for the licence or the extent of music usage, as well as for infringement investigations
  • publicly available information (e.g. Companies House, Land Registry, Charity Commission), business databases and credit reference databases, in order to verify, maintain and update our records, obtain contact details (e.g. to contact individuals who may require a licence), as well as for identity verification or credit control purposes
  • business partners and subcontractors who assist us in delivering our services to you (e.g. payment and delivery services)

We will only process your personal information where we have a valid reason under data protection law, called a lawful basis for processing. We have set out below and throughout this privacy notice the main purposes we process personal information for and the legal bases we use when processing your personal information. Depending on how you engage with us, more than one section may apply to you. Please take time to read all sections which are relevant to how you engage with us.

  1. Licensee
PurposeLawful Basis
To process your licence applicationLegitimate interests: to assess that your application is appropriate and to issue your licence accordingly, including collection of the royalties due
To verify your identityLegitimate interests: to verify your identity and prevent fraud
To maintain and administer our licence with you

Contract: to comply with contractual obligations under TheMusicLicence terms and conditions

Legitimate interests: to manage the licence arrangement, and protect and administer the rights of PRS and PPL members

To communicate about licences required to use musical repertoire that we representLegitimate interests: to communicate about a licence required to use the repertoire that we represent, based on our understanding of your use of the music
To communicate with you as the representative (e.g. employee) of a licensee regarding the administration of the licenceLegitimate interests: to communicate and work with you to manage the licence in place with the organisation you represent

To collect your feedback on our service (e.g. through our external feedback partner, Feefo)

(You will not be identifiable if your feedback is given anonymously)

Legitimate interests: to improve our services and/or for our promotional purposes
To carry out business insights reporting, which is shared with PRS for Music, PRS and PPLLegitimate interests: to inform strategic development, business intelligence, licence analysis and development and distribution of licence fee monies
To review accounts and call recordings for quality assurance and enablement purposesLegitimate interests: for staff training and performance management
To investigate and respond to comments, complaints, enquiries or requests you or others may send usLegitimate interest: to respond appropriately to your request

To comply with relevant legal obligations, such as:

  •  
  • requests or warrants from law enforcement agencies or government agencies
  • statutory obligations under copyright law, company law, health and safety law, data protection law or any other relevant law
  • the direction or order of any court or tribunal
Legal obligation: as described
To verify that your music usage declarations remain accurate and completeContract: to uphold our contractual rights under TheMusicLicence terms and conditions
To test, monitor and analyse data, products, content, functionality, services and websiteLegitimate interests: to run appropriate testing of potential and existing activities using information we hold, to understand engagement with us, to improve and assess our activities and to analyse information to inform business improvements, plans and activities

 

2. Visitor to our Website, including user of our online services

PurposeLawful Basis
To test, monitor and analyse data, products, content, functionality, services and websiteLegitimate interests: to run appropriate testing of potential and existing activities using information we hold, to understand engagement with us, to improve and assess our activities and to analyse information to inform business improvements, plans and activities
To manage and monitor access and use of our online servicesLegitimate interests: to protect the security and integrity of our systems and manage access

Use information from cookies and similar technologies

We use cookies (and similar technologies) on our website to assist the functioning of our website and understand how our website is being used. In particular, we use Google Analytics, this provides de-identified information about how the site is being used. Google Analytics does this by placing cookies on your device or reading cookies that are already there. For more information, please visit  Google’s Privacy & Terms site

You can control cookies through the preferences on your browser, and by dedicated browser extensions or add-ons. Please see our Cookie policy [link: https://pplprs.co.uk/cookie-policy/] for more details on the cookies and tracking technologies we use and the purposes for which we use them

Consent: given by the cookie consent mechanism where we ask for consent to place cookies

Legitimate interests: to understand our relationship with you and improve future communications and our services

 

3. Copyright Infringement or Debt Enforcement

PurposeLawful Basis

To prevent, investigate and detect infringement of copyright and take appropriate (including legal) action

This includes collecting evidence about unauthorised music usage and identifying the legal entity and/or persons responsible

Legitimate interests: to investigate potential infringement of copyright and take appropriate (including legal) action against such activities
To prevent and investigate unpaid licence fees that are due under your licence, and take appropriate (including debt collection or legal) actionContract: to uphold our contractual rights under TheMusicLicence terms and conditions

4. Rightsholders

PurposeLawful Basis
To facilitate the accurate distribution of royalties by PRS and/or PPL, by collecting set lists from licensees and submitting these to PRS and/or PPL for distribution purposesLegitimate interests: to support the distribution of accurate royalties to rightsholders
To take appropriate (including legal) action in respect of infringement of copyright by confirming that the relevant rights being infringed upon are vested in, or managed by, PRS and/or PPL

Legitimate interests: to take appropriate (including legal) action against infringement of copyright

Legal obligation: where required by the court or relevant procedure rules

 

5. Marketing, Surveys, Competitions and Online Content

PurposeLawful Basis
Marketing

Consent: to send you marketing communications according to your preferences

Legitimate interests: to send postal communications about matters we think will be of interest, relevance or importance and where we consider there is a legitimate interest

Legitimate interests:
to send you marketing communications that we think will be of interest to you as part of our business-to-business relationship

Competitions

Contract: to uphold the terms and conditions of the competition

Legitimate interests: to facilitate and manage a competition you have entered

SurveysLegitimate interests: to ensure we can obtain feedback from you to assist with improving our services, products, industry research or discussions and our business activities

 

6. Events or Office Visitor

PurposeLawful Basis
To ensure the security, safety and accessibility of our premises and events (including by use of CCTV, access records and facilitating attendance requirements)Legitimate interests: to facilitate access and ensure the safety, security and accessibility of our premises and events for all persons that work with us and visit us
Images/videos/sound recordings at events

Legitimate interests: to use photos and videos from our events for promotional and publicity purposes

Please contact the events organiser if you do not wish for us to use your image, video or sound recording

To accommodate accessibility or dietary requirements

Consent: voluntary disclosure by you

Vital interests: in a health emergency

 

7. Third Party Relationship

PurposeLawful Basis
To maintain and administer our relationship with you

Contract: to uphold the relevant contract that is in place between us

Legitimate interests: to manage our relationship with you, including any pre-contract negotiations

To correspond with you as the representative (e.g. employee) of a third party we work withLegitimate interests: to communicate and work with you on behalf of the organisation providing services to us

 

We do not sell your personal information. However, we do share your personal information with the following categories of recipients.

Categories of Recipients

Overview of Data Sharing

PRS for Music, PRS, PPL and their affiliates where appropriate (such as MCPS and VPL)

We share personal information in connection with your licence, in particular for licence administration, licence analysis and development, management and distribution of licence fee monies, and enforcement purposes.

These organisations may also directly contact you in connection with the above matters and/or in respect of other products/licences that they consider should be in place.

For more detail about how PRS for Music, PRS and the Mechanical-Copyright Protection Society Limited (MCPS) may use your information, please visit https://www.prsformusic.com/privacy.

For more detail about how PPL and VPL may use your Information, please visit https://www.ppluk.com/privacy-policy

Agents or representatives of licensees

We share personal information with agents or representatives authorised to deal with us on your behalf, to the extent necessary to discuss, arrange, administer or manage your licensing arrangements.

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, to the extent necessary to discuss, arrange, administer or manage your licensing arrangements.

Government authorities, law enforcement, law advisers, regulators and the Dispute Resolution Ombudsman

We may share personal information where we are under a legal or regulatory obligation or where there is a legitimate interest in doing so, for example for the purposes of a dispute we are engaged in or a complaints process being managed.

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 to allow the business to continue to utilise music.

Copyright infringement and data enforcement  

We may share personal information with relevant third parties in order to investigate, prevent, or take action regarding suspected copyright infringement or unpaid royalties that are due under your licence (such as lawyers, debt collection agencies, field operatives and enquiry agents).

Feefo customer feedback platform

We work with an external feedback provider, Feefo, to request feedback on our services from our licensees by email. We share your name, email address, and basic details of TheMusicLicence that was purchased (as obtained during the licensing process) with Feefo (such as the date of your purchase and the applicable tariff). Feefo will send you an email directly, inviting you to provide feedback on your experience with PPL PRS. Providing feedback is optional and, should you choose to do so, you will be providing that data to Feefo directly and therefore Feefo will process your personal information as a data controller. Please refer to Feefo’s privacy note for more information on how Feefo uses the reviews that you submit.

Other third parties

We use various external companies to assist us in the effective operation of our business, such as externally hosted software, data hosting, IT services partners, business directories, data cleansing companies, business process outsourcing partners (who may be based offshore), marketing agencies, printing/mailing companies, works/recording usage matching organisations, music recognition technology companies, music usage collecting organisations, event organisers and third party websites.

From time to time, we may also require the assistance of various external providers of professional services (e.g. lawyers, accountants, auditors and experts).

In respect of website visitors, we send certain information to Google regarding website analytics. See above for further information.

We keep your information only for as long as it is needed for a particular purpose. We maintain appropriate security measures (including physical, electronic, and managerial controls) to prevent your personal information from being lost, disclosed, altered or used in any unauthorised way.

We keep your information in accordance with our retention policy. This states different periods of time depending on the purpose for which we hold the information. This is based on why we need the data, legal and regulatory requirements, limitations for taking legal action, good practice and our business purposes. In respect of Licensees, we typically retain personal information for the duration of your licence and for up to 6 years after you cease to be a Licensee.  For more information on our retention periods, please contact us using the details below.

We are based in the United Kingdom. However, many third party service providers have a global operating model (such as IT services and business process outsourcing), which means that your personal information may be sent outside the UK.

Where your information is transferred to an organisation located in a country outside the UK, we will ensure your information is adequately protected under applicable data protection law. Where the transfer is to a country with laws not deemed by the UK Government to adequately protect personal information, we will take steps to ensure your information is protected by other means, for example by putting in place an agreement to include standard international data transfer terms (as approved by the UK Government) and assessing the risks of transfer.

Our website contains links to websites run by other organisations. We have no control over the content or privacy practices of these organisations. They will have their own privacy notices and are not covered by this Privacy Notice. We encourage you to read the privacy notices on any websites you may visit.

If you have any questions relating to the use of your personal information or to exercise a right under data protection law (listed below), please contact us by email at dataprotection@pplprs.co.uk or write to us at:

Data Protection Team

PPL PRS Limited
Mercury Place
St. George Street
Leicester LE1 1QG

You have a right to ask us to:

  • provide you with further details about how we process your personal information
  • provide you with a copy of your personal information
  • update any inaccuracies in the personal information we hold about you
  • delete any of your personal information that we no longer have a lawful basis to use
  • restrict how we process your personal information
  • transfer your personal information to a third party in a machine readable format
  • object to the processing of your personal information where it is based on legitimate interests (unless our reasons for undertaking that processing outweigh any prejudice to your data subject rights and interests)
  • where processing is based on consent, stop that particular processing by withdrawing your consent

In certain circumstances, these rights may be limited, for example if fulfilling your request would disclose personal information about another person, if your request is manifestly unfounded or excessive, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.

We aim to respond within one month of receiving your request and we will let you know if we anticipate your request taking any longer. Please note you may be asked to supply us with proof of identity.

You have the right to object to receiving marketing communications. Please be aware that if you object to receiving marketing communications, you will still receive non-marketing communications (which may include essential information about your licence, communications about a licence that is legally required, as well as investigation and legal action relating to copyright infringement or unpaid royalties).

If you have any concerns about how we are handling your personal information, we would like you to give us an opportunity to help resolve these. You can contact our Complaints team at https://pplprs.co.uk/complaint.

Alternatively, you can contact our Data Protection team using the details set out in above, who will aim to respond within 20 working days.

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 the Information Commissioner’s Office. Further information, including contact details, can be found on their website at ico.org.uk.

This Privacy Notice will be amended from time to time. Please check back regularly to view any updates.