Frequently Asked Questions about Copyright in non-US countries
This list was last updated on Sunday, 25-Apr-2004 15:59:58 MDT.Frequently Asked Questions about Copyright in non-US countries
IMPORTANT NOTE - The Copyright Policy described below applies to books published outside the United States! For information on copyright policies for books published in the United States, see Page 1.
ANOTHER IMPORTANT NOTE - I am not a lawyer. The information below is my interpretation of copyright laws after reading the laws and summaries available online. Please follow the links to the actual copyright policy pages in order to get the most accurate reading of the law. Not all countries represented on the BWO pages are listed here - I plan to add additional countries as information becomes available.
AUSTRALIA
Source document: "Australian Copyright Council" - see in particular the section "Research or Study (G53)"Australian copyright laws state that all published works are protected by copyright for the length of the copyright holder's life, plus 50 years. My reading of their fair-use provisions (as stated under their "infringement" regulations) is that they have a more narrow view of fair-use. Unlike US or Canadian laws, Australia extends copyright protection to reprints of works in the public domain - these are "topographical" copyrights, and last for 25 years following publication of the reprint.
CANADA
Source document: "Canadian Intellectual Property Office - A Guide to Copyright"Canadian copyright laws state that all published works are protected by copyright for the length of the copyright holder's life, plus 50 years (starting the first day of the calendar year following the author's death). So, if a work was published in 1930, and the author died in 1950, then the copyright would expire on Dec. 31, 2000. Currently, all works in which the copyright holder died before 1952 are in the public domain, and can be quoted freely. For all other works, the Canadian Fair Use provision is essentially identical to the American policy, so standard BWO policy on fair use (as stated on Page 1) still apply.
NEW ZEALAND
Source documents: "Copyright Act of 1994" - For Research or Private Study see Clause 43.New Zealand Copyright Council - and the section Copyright Licencing Ltd .
Coyright in New Zealand is for 50 years after death of author as in Australia & Canada. (With thanks to John Wilson for the websites and information).
UNITED KINGDOM
Source documents: "The UK Patent Office - Basic Facts about Copyright""GENUKI - Copyright for Family Historians"
Until 2000, all works published in the United Kingdom (England, Scotland, Wales, Northern Ireland) shared the Canadian policy. However, in 2000, the United Kingdom aligned its copyright policy to that of the European Economic Community (European Union). Now, all works published in the UK before or after 2000 are protected by copyright for the life of the copyright holder, plus 70 years. The fair-use provision is similar to Canadian and US policies, so follow BWO policies here. [Even though Ireland is not part of the United Kingdom, its policies are the same due to its membership in the EU.]
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