Pharmacosmos UK (Pharmacosmos) is firmly committed to protecting the privacy of information we may collect from our online visitors or directly from Healthcare Professionals or directly from patients in relation to our monitoring of the safety of our products.
Pharmacosmos at all time complies with data protection laws including the UK Data Protection Act 2018 and the EU General Data Protection Regulation or GDPR. It is our intent to balance our legitimate business interests and legal compliance obligations in collecting and using information received from and about our online users Healthcare Professionals and patients with their reasonable expectations of privacy. The following policy explains:-
The information we gather
1) visitor statistics
2) Other personally identifiable information
We do not link aggregated visitor statistics with personally identifiable information.
Aggregated visitor statistics
When you visit our website, we automatically collect general information about your computer and its location, as well as the web-site you came from if applicable. This information is only used in aggregate form to inform us where our visitors come from, what they look and act on, and where the most time is spent.
Information we collect automatically:
A cookie is a simple text file that is stored on your computer or mobile device by a website’s server and only that server will be able to retrieve or read the contents of that cookie. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier and the site name and some digits and numbers. It allows a website to remember things like your preferences – e.g. choice of language.
You can learn more about cookies in general here, including how to deselect cookies.
Personally identifiable information
At times, we need to collect more personal information about you. Some areas/parts of our website might require you to register in order to log in and we might ask you for information such as your age and occupation to better understand the purpose of your visit and to improve your visitor experience.
In any case, whenever we ask you for any personal information through this website that can be used to identify you as an individual, we will always provide a privacy notice for you at the time of collection to provide an explanation as to why we gather the personal information, how we gather it, how we store it, and how we plan on treating and using it and, if required, we will ask for your consent.
Collection of sensitive data
We do not collect or retain sensitive personal data such as relating to your health, ethnic origin, religious beliefs or political conviction etc. on this site. In the rare case where we do seek to collect such data through this website we will do so in strict compliance with local data privacy laws and as above, we will inform you by providing a privacy notice at the time of collection to inform you of what we will do with your data and obtain your consent if required.
The fair and lawful and processing of the personal data of Healthcare Professionals is a top priority for us. If you are a Healthcare Professional, we would like to inform you about the way in which we process the personal data that we collect in the course of our business contact with you.
Pharmacosmos is the data controller for the processing of your personal data.
Which personal data do we process?
As part of our professional dealings with you, we regularly collect, store and use the following types of personal data:
Processing of personal data in the field
As part of our regular interaction with you, our sales representatives take down notes about you (contact data, job-related information, details of professional interests and business focus). We process this data in order to provide you with technical information tailored to your needs and interests, which corresponds to your interests and business focus at a regular basis (e.g. as part of the next visit of our sales representatives).
Processing of your personal data through consent to send information regarding marketing and/or events
During Pharmacosmos representative visits we may ask for your consent to contact you by email or other electronic means with both promotional and non-promotional content on our products and services including information and invitations to upcoming promotional /non promotional meeting and/or events.
Your personal data will be collected and processed only with your agreement and consent for each specific purpose. Where we process your data to send you information electronically based on your consent to do so, we will give you the opportunity in each contact to update your preferences and to unsubscribe and withdraw your consent.
On the withdrawal of your consent we will cease all processing of your personal data for those purposes but note that we may still retain and process your personal data for the purposes set out above based on the requirement to do so for the purpose of our professional dealings with you.
Processing of personal data collected at trade fairs, conferences and other events
You may also provide us with contact details, job-related information and/or information on your interests and business focus at trade fairs, conferences or other events. We may use this data to send you information on our products by telephone, in writing or electronically or to contact you in any other way. We will give you the opportunity in each subsequent contact with you to update your preferences and to unsubscribe from future communications.
Processing of personal data relating to payments
Pharmacosmos complies with statutory and self-regulatory requirements with regards to disclosing payments and any other transfers of value made to members of the health profession and other service providers. We will document and publish the benefits and payments granted by Pharmacosmos to Healthcare Professionals and Healthcare Organisations each calendar year.
We will disclose your detailed personal information only if we have obtained your prior consent. Otherwise, we will publish the benefits and payments received by you together with other benefit recipients in aggregated form, without it being possible to draw any conclusions about you personally.
Where is your data stored?
In order to provide you with the best possible information and advice and to keep the information up-to-date, we process the data on Heath Care Professionals collected as part of our professional dealings with HCPs in our CRM system, which is the OneKey database currently provided by IQVIA.
All data collected and processed based on your consent and for marketing purposes is stored in our local CRM system and is not shared with IQVIA as part of the OneKey database. However, this data may be shared by us with our parent company, Pharmacosmos A/S, Rørvangsvej 30, 4300 Holbæk, Denmark.
Pharmacosmos is required by law to collect complaints and safety information concerning our products and whilst doing so to also protect the personal data of the patient and the person reporting the safety information which could be a Health Care Professionals such as a nurse, a pharmacist or doctor.
At Pharmacosmos we collect all safety information on our products received from patients directly or through their Healthcare Professionals into a database. We analyse the data on a regular basis to determine if there is any new information about our products that we need to share with health authorities, doctors and patients. This is all done for the purpose of securing the safety of our products and patients.
We collect personal data from the following sources:
Why do we process this personal data?
We process this personal data about you for the following purposes:
Pharmacosmos will collect and process personal data about you for the purposes described below.
To carry out our professional collaboration your professional contact information such as your name, email, phone number, title, specialisation, address may be stored in our databases. Consequently, we will process your data in relation to for the purpose of fulfilling our respective contractual obligations.
Our legal basis for such processing of personal data is the General Data Protection Regulation articles 6(1)(b).
If you contact us to report a complaint or safety information, such as adverse effects, concerning our products, we are under specific legal obligations and will then process the data on the legal basis of the General Data Protection Regulation articles 6(1)(c).
Your data will be treated as confidential information by those, who are allowed to process the data, and will only be used for the purposes as set out herein. It will be stored by Pharmacosmos or third party hosting provider and on a need to know basis may be accessed by Pharmacosmos’ group entities or disclosed to third party service providers who deliver services to Pharmacosmos, or to relevant public authorities, if required by law.
If your personal data is transferred to third party service providers or Pharmacosmos’ group entities which are located in countries outside the EU/EEA and which are not ensuring an adequate level of data protection, such transfer will be safeguarded by the EU Commission’s standard contractual clauses or by the EU-U.S. Privacy Shield.
We will delete your personal data when we no longer need to process it in relation to the purpose set out above.
You may object to your personal data being processed or request that your personal data is rectified. If you wish to do so, please contact us with this message. You can obtain a copy of your personal data in a structured, commonly used and machine-readable format. If technically feasible, you may request that the personal data is transmitted directly to another third party acting as a data controller.
To object, request data rectified, request a copy of your data, or simply obtain further information in relation to Pharmacosmos’ processing, contact us at email@example.com. If you have any complaints about Pharmacosmos’ processing of your personal data, you may contact the Information Commissioner’s Office.
We may amend this Privacy Notice from time to time. If we make changes, we will notify you by revising the date at the top of the notice and, depending on the specific amendments; we may provide you with additional notice. We encourage you to review the Privacy Notice whenever you access our services to stay informed about our information practices and the ways you can help protect your privacy.
When applying for a position with Pharmacosmos we ask you to disclose personal information, including name, email address, telephone number and a copy of your application and resumé.
The information you provide in connection with your application should not contain:
The purpose of collecting personal information is to evaluate your qualifications in respect to vacant positions with Pharmacosmos
Storage, deletion and changes
By accepting our terms you give your consent to Pharmacosmos to store your application for up to 6 months after your submission hereof. You always have the right and option to be informed about which personal data is being treated by Pharmacosmos and you are at all times entitled to withdraw your consent and to ask to have information changed or deleted. Simply contact firstname.lastname@example.org
You also have the right to complain to the Information Commissioner’s Office you believe the treatment of your data does not meet the applicable legislation.
Pharmacosmos takes all organizational and security measures to protect your information. All personal information will be kept confidential and will only be used in accordance with the purpose described above.
How personal data is used
We will only gather and store personally identifiable information for the purpose stated during the gathering process. When we finish processing your information for the stated purpose, we will erase and destroy it to ensure your privacy. More details of how your personal information will be used if it is collected will be provided to you in a privacy notice at the time the data is collected.
How we ensure data security
We take protecting your personal data very seriously and comply strictly with the provisions of data protection laws and the GDPR in relation to the adequacy of our data security provisions. Under no circumstances is the collected data sold on to third-parties for any reason.
Disclosure to third parties
We will never sell personally identifiable information to a third party, unless we explicitly state so at the time of collection of that personal information, or when we ask for your permission before doing so.
Transfer of personally identifiable information to a third party, including other companies within the Pharmacosmos group will be conducted in accordance with the legal requirements of GDPR. With the exception of information gathered through use of our website, if transfer is to occur, this will usually be stated at the time of collection of that personal information, or your permission may be asked before doing so.
We will generally only share information on Healthcare Professionals with our contracted service providers, such as IQVIA as part of our use of the OneKey database and our advisors. However, in order to comply with legal obligations, to protect the rights, property or safety of Pharmacosmos, its employees and others, or in the event we sell or liquidate any part of business or assets, your personal data may be shared.
We may also share personal data as it relates to product safety with Health Authorities, other Pharmacosmos entities (e.g., Pharmacosmos affiliates in other countries) and partner companies that assist us (e.g. licence partners, consultants, IT service providers) with this data.
Any sharing of personal data will be in compliance with data protection laws.
How is your personal data processed?
Personal data is collected by our sales representatives, or on our website, or through any other methods, such as directly from patients or Healthcare Professionals related to product safety. We only process your personal data as is necessary to achieve the various purposes (data minimisation principle) for which it was collected or in line with any consent provided. Where possible, we make use of the possibilities of pseudonymisation and anonymisation of personal data.
How long do we store your data?
We process your data only as long as this is necessary to achieve the respective purpose of the processing or to be able to comply with legal obligations (e.g. data retention requirements).
For personal information collected from you in relation to product safety, we are required by law to keep this data for 10 years after the expiry of our authorisation to sell the relevant products.
We keep business letters and comparable correspondence for a period of six years, invoice-related documents and contract documents for a period of seven years.
We keep your personal data stored in the OneKey system for the duration of the business contact with you. We keep your personal data collected and processed for marketing purposes with your consent on our local CRM database until you unsubscribe from all such communications.
The data that we collect on any payment or transfers of value we provide to you is disclosed with your consent and is held by us for a period of five years after its first publication in the current calendar year and then is subsequently deleted, unless it is subject to statutory data retention requirements.
Who has access to your data?
Access to your personal data is restricted to Pharmacosmos personnel to the extent necessary for processing for the above-mentioned purposes (e.g. field service, Healthcare Professionals).
Access to your personal data as it relates to product safety may be shared with Health Authorities, other Pharmacosmos entities (e.g., Pharmacosmos affiliates in other countries) and partner companies that assist us (e.g. licence partners, consultants, IT service providers) with this data.
Our CRM-system (OneKey) is provided and maintained by IQVIA Holdings (UK) LTD of 210 Pentonville Road, London, N1 9JY and we share personal data of Healthcare Professionals as part of this CRM system with IQVIA. In addition, we may use other technical and professional service providers to process your data. Subject to our instructions and based on a data processing agreement with us, they perform specified tasks in the processing of your data.
Your rights to information, correction and deletion
You are entitled to know whether we hold personal information about you and, if we do, obtain insight to that data, object to or request a restriction on what we do with your personal information and require it to be corrected if it is inaccurate. You are also entitled to know the purposes for which it is processed and in some cases you may be able to request that it is deleted.
Who to contact
If you are unhappy about the way we have dealt with your personal information or how a request has been handled, or you believe that your request has not been complied with, you have the right to complain to the Information Commissioner’s Office.
Information on how to make a complaints can be found at: https://ico.org.uk/make-a-complaint/.