INFORMATION WE MAY COLLECT ABOUT YOU
We will collect any information that you provide to us when you:
make an enquiry over the phone, by email or on our website
submit manuscripts or other content to us by post, email or via our website
enter into a contract with us to represent us
submit an application to a job vacancy
provide a business service for us
‘follow’, ‘like’, post or interact with our social media accounts, including Twitter and Pinterest
The information you provide to us will include (depending on the circumstances):
Identity and contact data: Title, names, addresses, email addresses and phone numbers;
Financial and contract data: If we represent you, you may also provide us with your bank details, VAT and tax information, immigration and residency information, your existing contracts (and related correspondence) with publishers or other licensees of your work;
Employment and background data: If you are submitting a manuscript for review or submitting a job application, you may also provide additional information about your academic and work history, qualifications, skills, projects and research that you are involved in, references, proof of your entitlement to work in the UK, your national security number, your passport or other identity document details, your current level of remuneration (including benefits), and any other such similar information that you may provide to us;
Business Supplier Data: If you are providing us with a business service we may ask for contact and banking details and the names of your staff who will provide the service.
Information we receive from third parties:
In certain circumstances, we will receive information about you from third parties. For example:
Employers, recruitment agencies and referees: If you are a job applicant we may contact your recruiter, current and former employers and/or referees, who may be based inside or outside the EU, to provide information about you and your application;
Publishers and other licensees of your work: If we represent you, you will normally authorise us to receive information about you from your publishers and other licensees such as information about your contracts, performance, royalties and other payments;
Third parties who can verify submitted information: If you submit a manuscript to us for our review, we may use third party providers to verify the information that you provide to us in connection with that submission. For example, we will use book search websites to confirm your publication history;
Website security: We will collect information from our website security service partners who are based inside the EU, about any misuse to the website, for instance, the introduction of viruses, Trojans, worms, logic bombs, website attacks or any other material or action that is malicious or harmful.
We might also receive information about you from third parties if you have indicated to such third party that you would like to hear from us.
Our website is not intended for children. We do not knowingly collect or maintain the personal information of children under the age of 13. If you are under the age of 13, please do not access our website at any time or in any manner. We will take appropriate steps to delete the personal information of persons under the age of 13.
HOW WE USE INFORMATION ABOUT YOU
We will use your information for the purposes listed below on the basis of:
performance of your contract with us and the provision of our services to you;
your consent (where we request it);
where we need to comply with a legal or regulatory obligation; or
our legitimate interests or those of a third party
We use your information for the following purposes:
To conduct business with you: to contact you and manage and facilitate our business relationship with you, including (if we represent you) the administration of your contract with us
To provide access to our website: to provide you with access to our website in a manner convenient and optimal and with personalised content relevant to you including sharing your information with our website hosts and developers (on the basis of our legitimate interest to ensure our website is presented in an effective and optimal manner);
User and client support: to deal with enquiries or complaints about the website and share your information with our website developer and IT support provider as necessary to provide support (on the basis of our legitimate interest in providing the correct services to our website users and to comply with our legal obligations);
Recruitment: to process any job applications you submit to us, whether directly or via an agent or recruiter including sharing this with our third party recruitment agency (on the basis of our legitimate interest to recruit new employees or contractors);
Social media interactions: to interact with users on social media platforms including Twitter and Pinterest, for example, responding to comments and messages, posting, ‘retweeting’ and ‘liking’ posts
Research: to carry out research about general engagement with our website on the basis of our legitimate interest in providing the right kinds of services to our website users;
Fraud and unlawful activity detection: to protect, investigate, and deter against fraudulent, unauthorised, or illegal activity, including identity fraud (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so);
Compliance with policies, procedures and laws: to enable us to comply with our policies and procedures and enforce our legal rights, or to protect the rights, property or safety of our employees and share your information with our technical and legal advisors (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so); and
As outlined above, in certain circumstances we may use your personal information to pursue legitimate interests of our own or those of third parties. Where we refer to using your information on the basis of our “legitimate interests”, we mean our legitimate interests in conducting and managing our relationship with you, including the legitimate interest we have in:
personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you;
detecting and preventing fraud and operating a safe and lawful business;
improving security and optimisation of our network, sites and services.
Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing please refer to details of “Your Rights” in the paragraph below.
WHO WE MIGHT SHARE YOUR INFORMATION WITH
In connection with the purposes and on the lawful grounds described above and in addition to the recipients of your information as described above, we will share your personal information when relevant with third parties such as:
Our service providers: third parties we work with to deliver our business (including, for example, hosting or operating the website and our databases and site analytics);
Publishers, licensees, sub-agents, advisors and service companies: if we represent you, any publishers or other licensees of your work (or prospective publishers and licensees) as well as sub- or co-agents and advisors (such as your solicitor or accountant), where applicable.
Prospective sellers and buyers of our business: any prospective seller or buyer of such business or assets, only in the event that we decide to sell or buy any business or assets; and
Other third parties (including professional advisers): any other third parties (including legal or other advisors, regulatory authorities, HMRC, courts, law enforcement agencies and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.
We require third parties to maintain appropriate security to protect your information from unauthorised access or processing.
HOW WE LOOK AFTER YOUR INFORMATION AND HOW LONG WE KEEP IT FOR
We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, including the physical and digital security of our offices, equipment and devices, limiting access of your personal information to those who need it in the course of our business and giving data security training to our staff.
We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our lawful business purposes, such as for the purposes of exercising our legal rights or where we are permitted to do so.
YOUR RIGHTS TO THE INFORMATION WE HOLD ABOUT YOU
You have certain rights in respect of the information that we hold about you, including:
the right to ask us not to process your personal data for marketing purposes;
the right to request access to the information that we hold about you;
in certain circumstances, the right to receive a copy of any information we hold about you (or request that we transfer this to another service provider) in a structured, commonly-used, machine readable format
the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;
the right to withdraw your consent for our use of your information in reliance of your consent which you can do by contacting us using the details in Contact Us, below
the right to object to our using your information on the basis of our legitimate interests (refer to paragraph 4 above to see when we are relying on our legitimate interests) (or those of a third party)) and there is something about your particular situation which makes you want to object to processing on this ground;
in certain circumstances, the right to ask us to limit or stop processing information about you, or erase information we hold about you; and
the right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/), as well as with the relevant authority in your country of work or residence.
Please note that we may need to retain certain information for our own record-keeping and research purposes.
HOW TO EXERCISE YOUR RIGHTS
You may exercise the rights set out above by contacting us using the details in CONTACTING US below.
We may need to request specific information from you to help us confirm your identity and to enable you 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.
CHANGES TO YOUR DATA
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us by updating your profile account information or contacting us via the contact details in CONTACTING US below.
The 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.
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Felicity Bryan Associates Ltd.
2a North Parade Avenue
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This document was last updated on 22nd May 2018