1. The International ISBN Agency Limited
The International ISBN Agency Limited (we/us/our) is a private company limited by guarantee without share capital registered in England and Wales with company number 05332288. Our registered office is at 48/49 Russell Square, London, WC1B 4JP, UK.
We are the global registration authority for ISO 2108, the International Standard Book Number. ISO 2108 sets out the rules regarding the scope and implementation of the ISBN which uniquely identifies publications in the book supply chain. We maintain the websites www.isbn-international.org and www.grp.isbn-international.org.
2. What is covered by the policy
For the purpose of the Data Protection Act 2018 (the Act) and General Data Protection Regulation (GDPR), we are the data controller responsible for your personal data.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Our site may, from time to time, contain links to the websites of our partner networks, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability. Please check these policies before you submit any personal data to these websites.
3. What personal data do we collect?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Personal data we collect:
We may collect, use, store and transfer different kinds of personal data about you; the data we collect will depend on the purposes for which you are contacting us or the services we are providing to you:
- Identity and Contact Data includes first name, last name, username or similar identifier, title, date of birth, gender, address, email address, telephone number, fax number, educational history, employment history, names and contact details of referees, tax status and job title.
- Financial Data includes bank account, and other data necessary for processing payments and ensuring security requirements.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
- Usage Data includes your username and password, feedback and survey responses, as well as information about how you may use our website and services.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
4. How is your personal data collected?
We may collect personal data from or about you in the following circumstances:
i) when you enquire about using, or use, our products or services;
ii) when you offer to provide, or provide, products or services to us;
iii) when you correspond with us by email, phone, through our website (online contact forms), mail or fax;
iv) when you provide us with information directly (through conversation or otherwise);
v) when you attend any events hosted by, or connected with, us;
vi) when you complete a survey;
vii) when you interact with our websites;
viii) when we enquire or request such personal data from publicly available sources or third parties (for example, from previous employers, ISBN registration agencies, Companies House, educational institutions, etc.).
If you apply for a job with us then we will ask for your Identity and Contact Data.
If you are employed by us or are a Director of the company then we shall need to ask for your Identify and Contact Data and Financial Data. You do not have to provide this information to us but if you choose not to do so we may not be able to fulfil our duties.
If you are a representative of a prospective ISBN registration agency, then we may ask you for your Identity and Contact Data in order to process your application.
If you are a representative of an ISBN registration agency, then we may ask you for your Identity and Contact Data in order to give details to the public on where to apply for ISBN.
If you are a supplier of services to us then we may ask for your Identity and Contact Data, and Financial Data in order to communicate with you and to pay you.
Information that we get from your device
We may collect your Technical Data and Usage Data for system administration and to report aggregate information. This is statistical data about users’ general geographical location (e.g. country), browsing actions and patterns and does not identify any individual.
Information from other sources
We work closely with ISBN registration agencies who may provide us with details of ISBN assignments made to you and your corresponding Identity and Contact Data if you are a publisher. ISBN registration agencies will ask for your permission to share your personal data with us.
5. How we use your data
We will only use your personal data when the law allows us to – either for the performance of a contract with you, to comply with a legal obligation and/or because it is necessary for our legitimate business interests.
Performance of a contract
We may collect and process personal data for the purpose of negotiating, finalising or fulfilling a contract with you. For example:
- We may ask for Identity and Contact Data in order to provide you with information, products or services that you request from us and to allow you to participate in interactive features of our service, if you wish to.
- If you are an employee then we will process Identity and Contact Data, as well as Financial Data, in order to fulfil our payroll duties and to report to HMRC. If you are a Director, then we will need to process Contact and Identity Data in order to register you with Companies House.
- We may need to use Identity and Contact data that you have provided to us in order to issue you with membership notices or renewals, to provide an entry for your agency in the ISBN Agency directory, or to send you logistical and other information about events that we organise and which you may be attending. We may also need to ask for and collect any specific dietary or mobility requirements, for example, in order to assist your attendance at an event.
We may collect and process personal data for purposes required by law. For example:
- To carry out our legal obligations arising from any contracts between you and us. For example, if you are employed by us or are a Director of the company then we shall ask for Identity and Contact Data, and Financial Data, in order to fulfil our legal and statutory duties. You do not have to provide such personal data to us but if you choose not to do so we may not be able to fulfil our duties; in such a case we may have to cancel any arrangement or contract we have with you.
- To maintain records and compliance checks, as required by law.
Legitimate business interests
We may collect and process personal data for purposes which we consider to be in our legitimate business interests. For example:
- For the purposes of maintaining, managing and administering our business relationship with you, as well as for the purpose of analysing the effectiveness of our services.
- We may retain correspondence that you have sent to us in order to respond fully to you and to maintain effective communication with you.
- If we invite you to respond to a survey for research purposes to help us to improve and develop our services and you choose to respond, we will compile statistics of the responses (e.g. geographical response patterns). Any reports of the results of the survey will be anonymised and will not identify any individual.
- To process membership queries, applications, renewals and terminations and to collect and administer subscriptions.
- If you apply to us for a job, we will keep you updated and let you know the status of your application. With your permission we will also contact your referees in order to get more information about your experience and performance to date. It is your responsibility to obtain permission from your proposed referees before passing their details to us.
- One of our responsibilities as the registration authority for ISBN is to publish a searchable database of ISBN and ISBN block assignments and corresponding publisher details (the Global Register of Publishers). This helps to promote the ISBN standard and enables publishers and their books to be more easily discovered, possibly resulting in more sales. We also need to have comprehensive information about ISBN assignments that have been made in order that we can continue to monitor and manage the overall capacity of the ISBN system. We receive the details of these assignments from ISBN registration agencies based all over the world.
- We obtain some information by using cookie files. Cookies help us to improve our site and to deliver a better service. We use two types of cookie – technical and analytical – and you can find out more about each of them here
6. With whom and how your data may be shared
The data we collect may be transferred to, processed and stored, outside the European Economic Area (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:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Regarding cases where we may use providers based in the US and any potential transfer of data to them, a new EU-US Data Privacy Network has been agreed in principle and a new adequacy decision for the US is in preparation. In the meantime, all the safeguards that the Commission has agreed with the US Government in the area of national security (including the redress mechanism) will be available for all transfers to the US under the GDPR, regardless of the transfer tool. For further details, see European Commission: EU-US Data Privacy Network
Our sites use Google Analytics which is a service provided by Google and enables us to prepare reports on website activities and general user locations although it does not identify any specific individual. Some processing by Google happens in the US.
If we cease to be the Registration Authority for ISBN, data about publishers and their ISBN allocations may be transferred outside the EEA. We will take all steps reasonably necessary to ensure your data is treated securely, in accordance with this policy and with GDPR.
If a new ISBN agency is appointed, and we are contractually obliged to transfer data about prior ISBN allocations to the new agency, we shall enter into agreements to guarantee that any such transfer and subsequent processing shall comply with GDPR.
In order to carry out our obligations arising from agreements between you, or our members, and us, and, unless you have asked us not to, we may disclose your personal information to third parties but this this will not be for marketing purposes.
If we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets and we shall enter into agreements to guarantee that any such transfer and subsequent processing shall comply with GDPR.
7. How long the data will be stored for
We will only keep data about you for as long as we need it to fulfil services to you including any statutory, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we will always consider the amount, the nature of the information, how sensitive it is, the potential risk of harm from unauthorised use or disclosure, the purpose for which we have collected and are processing the data (and whether we can achieve those purposes through other means) and other relevant legal requirements.
By law we have to keep basic information about our members (including Contact and Identity Data and Financial Data) for at least six years after they cease being members for tax purposes.
If you are a publisher who has received ISBNs or ISBN blocks and has given consent for your personal data to be collected, we will retain your personal data, even if you cease to publish, in order to provide information about your ISBN allocations.
If you are a user of our websites and have an account, your personal data will be retained for as long as your account is active. If you are a user of our website without an account, your personal data will be retained for a maximum of two years.
8. Your right to complain
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, we would appreciate the chance to deal with any concerns you may have before you approach the ICO, so please contact us in the first instance. You may contact us via:
Email address: firstname.lastname@example.org
Telephone number: +44 (0)20 7580 8536
9. Your rights in relation to the data
Under certain circumstances, you have rights under data protection laws in relation to your personal data to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. We reserve the right to charge a reasonable fee if the request is excessive and/or for the administrative costs of additional copies of personal data.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
For example, If you do not want your personal data to appear in the Global Register, you should contact your ISBN registration agency (https://www.isbn-international.org/agencies) and also inform us (email@example.com) in order that we can remove your personal details.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
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