[Tomte]

> I used to think that copyright is always assigned to the creator, like in Germany, and it appears that I was wrong: according to Wikipedia, at least English law actually defaults (no contract clause needed!) to assigning your copyright to your employer if the contribution was done as part of work for hire

It‘s basically the same in Germany. Urheberrecht is not the same as copyright, but comprises personal rights and exploitation rights. 99% of questions about Urheberrecht in commercial settings are about exploitation rights, so ~ about copyright in an American sense.

Personal rights (mostly the right to be named) stay with the author and can never be transferred, exploitation rights default to the employer in employment situations (and are usually explicitly transferred in work contracts, to be safe).

[strogonoff]

Copyright is not the same as licensing. There is a big difference between granting your employer a license to your work (or OSS contribution), vs. making them the copyright holder (meaning they actually created the work, and you are entirely out of the picture for all intents and purposes). I’d like a lawyer to chime in regarding this English law.