Privacy Notice: Healthcare Professionals
Lundbeck Limited at all time complies with data protection laws including the UK Data Protection Act 2018 and the EU General Data Protection Regulation or GDPR.
The fair and lawful and processing of your personal data has a top priority for us. Therefore, we would like to inform you about the way in which we process information about you that we collect in the course of our business contact with you.
This privacy notice is in addition to the general privacy notice on our website which provides more information on how we process your personal data.
Lundbeck Limited ("we", "Lundbeck") is the data controller for the processing of your 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:
- Contact details (e.g. last name, first name, title, address(es), business telephone and fax number, e-mail address, preferred communication method)
- Work-related information (e.g. professional qualification, professional registration number(GMC, GNC etc), specialisation(s), treatment focus(s), , position, opening hours and preferred visiting hours)
- Information on professional interests and focuses (information on practical observations, indication and medication, products and services as well as events and publications
Processing of personal data in the field.
As part of our regular interaction with you, our field representatives and office staff take down notes about you (contact data, work-related information, details of professional interests and business focus). We process this data in order to provide you with technical information tailored to your your interests and business focus on a regular basis (e.g. as part of the next visit of our field representatives).
Processing of personal data collected at trade fairs, conferences and other events.
You may also provide us with contact details, work-related information and/or information on your interests and business focus at trade fairs, conferences or other events. We use this data to send you information tailored to your interests by telephone, in writing or electronically or to contact you in any other way.
Where required by law, we will ask for your consent before contacting you by email or other electronic means with any unsolicited direct marketing materials.
Processing of personal data relating transfers of value.
Lundbeck and other affiliated companies of the Lundbeck Group of Companies are members of the Association of the British Pharmaceutical Industry ("ABPI") in the UK and the Irish Pharmaceutical Healthcare Association (IPHA) in Ireland. The ABPI/IPHA Codes of Practice require companies to document and publish any transfers of value such as benefits and payments granted to Healthcare Professionals and Healthcare Organisations each calendar year.
If you are in receipt of any transfers of value your personal data will be processed in order for us to comply with our obligations under the ABPI/IPHA Codes of Practice. It is in our legitimate interests to process your data to comply with these requirements.
However, we will only disclose your name in relation to such payments, if we have obtained your prior consent to do so. We do this by sending you a separate consent form.
If you do not consent, the ABPI/IPHA Codes requires that we publish the benefits and payments received by you together with other benefit recipients in aggregated form, without it being possible to identify your personal data from that information.
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 personal data collected as described above in our Customer Relationship Management system. We use the OneKey database currently provided by IQVIA for this purpose.
How is your data processed?
As an over-riding principle, we only process such data as is necessary to achieve the various purposes (data minimization principle) of processing. Where possible, we make use of the possibilities of pseudonymization and anonymization of data.
Depending on the processing purpose, we may create profiles in order to address contacts with similar interests and focuses in a consistent form. You have the right to object to such profiling.
However, in the event of any objection, we will not be able to continue to send you information tailored to your interests using profiling. We may still send you information on relevant products, services and events for example, without utilising profiling to do so.
How long do we store your data?
We process your data only 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). We keep business letters and comparable correspondence for a period of six years and invoice-related documents and contract documents for a period of seven years.
We keep your personal data stored in our CRM system for the duration of the business contact with you.
The ABPI/IPHA Code data on transfers of value is disclosed for a period of five years after its first publication in the current calendar year and subsequently deleted, unless subject to statutory data retention requirements.
Who has access to your data?
Access to your data is restricted to Lundbeck personnel to the extent necessary for processing the data for above-mentioned purposes.
Our CRM-system is provided and maintained by IQVIA Commercial GmbH & Co. OHG, Albert-Einstein-Allee 3, 64625 Bensheim, Germany. The IQVIA privacy notice for the One Key Database can be found here.
In addition, we 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.
We ensure that all organisations that process your personal data comply with the requirements of the UK Data Protection Act 2018 or GDPR as relevant.
Your rights to information, correction, deletion and data portability.
Right to File a Complaint
You have the right to file a complaint with the UK Information Commissioner or for Ireland the Data Protection Commissioner if you believe that we do not process your data in a lawful manner.
As at: 02 May 2019