There’s also the football database case to consider. A database only attracts copyright if, under the national law, the selection or arrangement of its data amounts to an original expression of the creative freedom of its author. So a database will not qualify for copyright protection unless the skill and work necessary to create it have some originality of design. A database assembled by automated means cannot be protected by copyright. This has implications where data is collated by computer programs and there is no room for creativity.