GDPR Template - Privacy Notice for HCPs (Collection and processing of your personal data – Information)
Ferring Pharmaceuticals is a global pharmaceutical business, whose ultimate parent company is headquartered in St. Prex, Switzerland. Our mission is to improve the lives of patients in the following key areas: reproductive medicine and women’s health, and in specialty areas within gastroenterology and urology. For more information about Ferring, please see the 'About' section of our website at https://www.ferring.com.
Ferring Pharmaceuticals, UK (“Ferring') respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal data about you, and how you can exercise your privacy rights. If you have any questions or concerns about our use of your personal data, then please contact Sean Davis, General Manager, Ferring Pharmaceuticals UK, using the contact details provided at the bottom of this Privacy Notice.
The data controller of your personal data is Ferring Pharmaceuticals, UK which is registered with the Information Commissioner’s Office with registration number Z5442925.
What personal information does Ferring collect?
We may collect personal data about you from a variety of sources, including directly from you and from: documents or forms that you provide in order to participate in Ferring-sponsored or supported initiatives, such as Ferring-sponsored clinical research and development activities, or in other contexts; publicly available sources; CVs and resumes; and online and other databases and websites.
Legitimate Interest as a legal basis for processing personal data
Our legal basis for collecting and using the personal information described below is our legitimate interest in maintaining a relationship with you.
If we ask you to provide personal data to comply with a legal requirement or to perform a contact with you, we will make this clear at the time of data collection and advise you whether the provision of your personal data is mandatory or not.
We process this data in our customer databases for the purpose of managing our relationship with you, including planning potential collaboration, contact, and helping ensure that we provide you with information that is relevant given your expertise, interests and preferences.
Ferring may collect and use some or all of the following categories of personal data for the purpose described below:
- personal details such as your name, age, gender and contact details;
- professional details such as your place of practice, job title, the medical field in which you are active, your professional qualifications and scientific activities (such as previous clinical trial experience, and participation in past or pending research studies with Ferring and other companies), publication of academic or scientific research and articles, and membership in associations and boards;
- financial details such as payment-related data, including tax identification number and
- details of interactions with us, such as what kind of meetings we have held, topics discussed, your knowledge of and questions you have had on our business and products, what kind of material we have displayed to you and any feedback that you have provided, as well as your opinions and routines on prescribing, routines regarding your patients and diagnosis, and similar data.
Who does Ferring share my personal information with?
We may disclose your personal data to the following categories of recipients:
- to our group companies,
- to third party services providers and partners who provide data processing services to us, or who otherwise process personal data for purposes that are described in this Privacy Notice or notified to you when we collect your personal data.
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Privacy Notice;
- to any other person with your consent to the disclosure.
How does Ferring keep my personal data secure?
We use appropriate technical and organisational measures to protect the personal data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data.
International data transfers
Your personal data may be transferred to, and processed in, countries other than the country in which you are resident.
Specifically, our servers are located in the European Economic Area, and our group companies and third party service providers and partners operate around the world in accordance with the legal safeguards and provisions covering the exchange of personal data with group companies and external third-party service providers. This means that when we collect your personal data we may process it in any of these countries. These countries may have data protection laws that are different to the laws of your country.
We retain personal data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal data, we will either:
- delete this based on a defined time frame of 6 years or
- anonymise it (so this is no longer personal data and the individual cannot be identified directly or indirectly)
- or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store and pause any processing of your personal data and isolate it from any further processing until 6 years.
Your data protection rights
You have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal data, you can do so at any time by contacting the Ferring Global Privacy Office at firstname.lastname@example.org using the contact details provided under the “How to contact us” heading below.
- In addition, if you are a resident of the European Union, you can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data. Again, you can exercise these rights by contacting the Ferring Global Privacy Office at email@example.com using the contact details provided under the “How to contact us” heading below.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact local Ferring management Sean Davis, General Manager, Ferring Pharmaceuticals UK.
- Similarly, if we have collected and processed your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted based on legitimate interest.
- You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
How to contact us
- If you have any general questions in regards to withdrawing your consent or your right to opt-out of marketing communications, please contact at email: FerringCommunicationsUK@ferring.comor your local Ferring management, Sean Davis, General Manager, Ferring Pharmaceuticals UK, Drayton House, Church Road, West Drayton, UB77PS.
- If you would like to exercise your other aforementioned data protection rights, please contact the Ferring Global Privacy Office via email: firstname.lastname@example.org or via post at: Ferring International Center S.A., Chemin de la Vergognausaz 50, 1162 St. Prex, Switzerland.
GEN.1397.2018.UKa May 2018