Pharmacosmos UK (Pharmacosmos) is a limited company registered in England and Wales whose registered office is The White Building, 6th Floor, 33 Kings Road, Reading, RG1 3AR. We take our Data Protection obligations very seriously and this notice gives you information about our approach to Data Protection legislation (UK General Data Protection Regulation, Data Protection Act 2018, Privacy & Electronic Communications Regulations (PECR)) and provides you with information about how we manage your personal data.
For the purposes of this notice Pharmacosmos is the Data Controller. This means that we are responsible for deciding how we hold and use personal information about you. We are required under Data Protection Legislation to notify you of the information contained in this privacy notice.
This notice applies to our processing of personal data in respect of Healthcare Professionals (HCP). We may update this notice at any time, details of which are found at the end of this document. It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Please note our website and services are not intended for children and we do not knowingly collect data relating to children.
Pharmacosmos will collect and process your Personal Data for the purposes described below.
To carry out our professional collaboration with you:
To carry out and continuously improve our professional collaboration regarding iron deficiency, your professional contact information such as your name, email, phone number, job title, specialisation, place of work, qualifications, address, and educational background, photo and CV may be stored in our databases.
We will process such Personal Data in relation to booking of meetings, publications, training, invitations and other collaborative work.
Our legal basis for such processing of data is GDPR article 6(1)(f) - our legitimate interest in maintaining and continuously updating our database containing contact information of relevant HCPs.
The Personal Data will be stored for the duration of our current or potential professional collaboration.
Contractual relations:
If we enter into an agreement with you for your provision of services to Pharmacosmos, we may, in addition to the information above, collect:
We process the data for the purpose of performance of our contractual obligations or any such agreements with you.
Our legal basis for such processing of your Personal Data is:
We will process Personal Data to comply with the statutory requirements of The Association of the British Pharmaceutical Industry in order to publicly disclose certain transfers of value made directly or indirectly to health professionals and healthcare organisations.
Medical Information Management System:
When entering medical queries, adverse events, and product quality complaints received from you in our Medical Information Management System (Podio), we will also record your Personal Data such as name, address, email, fax and phone number.
Our legal basis for such processing of your Personal Data is the GDPR article 6(1)(c) to comply with our legal obligations.
Events:
In connection with attending our events, we might collect Personal Data such as your name, email, specialization, job title, dietary requirements, address, educational background, photo, phone number, place of work and travel data.
Our legal basis for such processing of your Personal Data is the GDPR article 6(1)(a) - your consent or GDPR article 6(1)(b) performance of our contract with you.
Recordings:
When you give a lecture or other scientific presentation, we may take photos and record (audio and/or video) you during such presentation for the purpose of publishing, distributing and using the photos and recordings to promote and inform about healthcare subjects, our products and our business. Publication of the recordings may take place in any form and through any medium. When publishing the photos and recordings, we may also publish your name, job title and place of work. The recordings will be stored until the scientific presentation becomes outdated.
Our legal basis for such processing of your Personal Data is the GDPR article 6(1)(a) – your consent, or the GDPR article 6(1)(b) – our performance of a contract with you.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, however only where this in accordance with Data Protection legislation, is required for a proportionate reason or is strictly permitted by law.
We only share your information where we are strictly able to and only in accordance with Data Protection legislation. Your Personal Data will be treated as confidential information by those who are allowed to process your Personal Data and will only be used for the purposes set out herein. It will be stored by Pharmacosmos or a contracted third-party hosting provider.
We may transfer your Personal Data to our affiliated companies and other third parties as follows:
If your Personal Data is transferred to one of our affiliated companies or a third party located in a country outside the EU/EEA, Pharmacosmos will ensure that such transfer(s) will be carried out in accordance with the applicable data protection legislation, including the GDPR.
If your Personal Data is transferred to our affiliated companies outside the EU/EEA, without an adequacy decision, the transfer will be based on Pharmacosmos Intra-Group Agreements including the EU Commission’s Standard Contractual Clauses.
Transfers to third parties outside the EU/EEA, without an adequacy decision, will be safeguarded by ensuring that the third party enters into the EU Commission’s Standard Contractual Clauses and the UK ICO Addendum and the relevant assessments (TRA/TIA).
Should such requirements change, we will review the obligations and amend this notice as appropriate. More information can be obtained by contacting our Data Protection Officer.
Our retention schedule is in place to ensure your Personal Data is maintained only for as long as is necessary to achieve the respective purpose of the processing or to be able to comply with legal obligations (e.g. data retention requirements). Further information regarding our retention of your Personal Data can be obtained from our Data Protection Officer.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
Right to be informed by the provision of a privacy notice when your personal information is processed.
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request rectification of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing.
Right to object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you.
Request the transfer of your personal information to another party.
In the limited circumstances where you may have provided your consent to the processing of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
Automated decision making, including profiling
We will not use automated decision-making technology except in the recruitment process where we use psychometric testing. Further information regarding this processing can be obtained by requesting our recruitment privacy notice from our Data Protection Officer.
If you want to exercise any of your rights, please contact our Data Protection Officer in writing at the contact details below.
We have put in place appropriate security measures to prevent your personal information from being accidently lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to our personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breaches and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have appointed a Data Protection Officer to oversee compliance with our Data Protection obligations. Our DPO can be contacted at info@pharmacosmos.co.uk , or in writing to our registered office, The White Building, 6th Floor, 33 Kings Road, Reading, RG1 3AR.
If you have any questions about this privacy notice or how we handle your personal information, please contact our DPO. 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 legislation.
From time to time, we may revise this Privacy Notice. Any such changes will be reflected on this page. Pharmacosmos recommends that you review this Privacy Notice regularly for any updates. The date on which this notice was last revised is located below.
V.1.0 Initial creation 16/03/23 DPO
