EEA HCP PRIVACY NOTICE
This EEA privacy notice for Health Care Professionals (hereinafter – “HCP Privacy Notice” or “Privacy Notice”) describes which Personal Data about you as a healthcare professional (HCP) are collected by the EEA Pfizer companies enumerated in the chapter below “Contact us” (hereinafter – “Pfizer” and “we” and any other forms or implied references of this pronoun) when we communicate or have another contact with you; how we use such data; how we store them and what your choices can be in respect of your Personal Data. We urge you to read this HCP Privacy Notice, press the provided links, or choose “More information” if you want further information on a specific issue.
If you have contact with us by internet, then please also read the privacy notice available in the website or application you use.
“Personal Data” means information identifying you or pertaining to an identified person. We will collect Personal Data in the event of meeting you, while you participate in our programs, activity, business sector events, commercial exhibitions or send queries to or communicating with us. We will also collect Personal Data from data companies providing information services in the healthcare sector, publicly available professional information sources and joint marketing partners.
Personal Data that we may collect:
- Name and surname
- Contact information (postal address, telephone numbers, email address and fax number)
- Your preferred language
- Professional photo
- Your interests (e.g. healthcare topics on which you request information from us)
- Professional biography, including data on your education, licenses, specialization, professional contacts (e.g. membership in medical communities or HCP networks), publications, powers of attorney and other professional achievements, and stamp number
- Data related to your use of our products, relations with us, your preferred way of contacting us and services to persons on whose healthcare you have been working)
- Financial and bank data that you provided for getting paid for the services you offered and compensation of professional fees, travels, accommodation and other expenses incurred
- Personal number, passport number, taxpayer code
- Your requests for travels
When we request you to provide Personal Data, you can refuse to do that. If, however, you choose not to provide data that are necessary for us to be able to offer services you request or fulfil the obligations under the agreement, we may be unable to offer you such services or comply with such obligations.
If you provide or allow us to collect any Personal Data pertaining to another person, including data on adverse effects, you confirm that you have the right to share such data and allow us to use them as described in this EEA HCP Privacy Notice.
HOW WE USE PERSONAL DATA
We use Personal Data for the following purposes:
- Communicate or maintain another contact with you where we are in contractual relationships or we have legitimate interests in that.
Communication or maintaining another contact includes the following:
- Responses to your inquiries and requests.
- Compliance with our contractual provisions defining relationships with you (e.g. medical events, publications, consultation meetings etc.) and, if applicable, payments to you for the specified or agreed services or compensation of your expenses, planning calls, meetings, travels and other related communication with you, sending administration information to you and documentation of our relationships with you.
- Creation and maintaining of data bases of Pfizer healthcare service providers in order to identify you and, if applicable, contact you (by digital or other means) as a scientific expert or major opinion-maker in various healthcare areas based on your professional experience and opinion, and, if applicable, your previous communication with us:
- Inviting you to participate in congresses/commissions, HCP professional meetings and educational activity.
- Contacting you to get your professional assessment, communicating information on our products through our professional representatives or using surveys pertaining to pharmacy products or services.
- Carry out our activity in compliance with our legal obligations, for statistics purposes or seeking legitimate interests to maintain our business activity.
Our business activity includes:
- Compliance with the obligations for supervision and reporting, including obligations pertaining to adverse effects, complaints on products and product safety.
- Checking if you have the right to get certain products, services and data that can be provided only to licensed HCP, or other screenings related to your biography to ensure that we are not restricted from working with you.
- Conducting training and ensuring quality control.
- Identification, prevention or investigation of misconduct.
- Compliance with anti-corruption and transparency obligations.
- Analysis or forecasting of HCP requests in order to identify common tendencies in respect of our products, services or creation, improvement or modification of our business activity.
- Protection of rights, privacy, security or property of our companies and companies related to us, you or other persons.
- Provide you with marketing and promotional communications in the scientific/health area (by digital and other means) that can be individually adjusted based on your professional field and interests, if we get your consent or have legitimate interests in that.
HOW WE DISCLOSE PERSONAL DATA
We disclose Personal Data in the following cases:
- To other Pfizer companies (the list of our companies is available at https://selfservehosteu.pfizer.com/legal-entities) for the purposes stipulated in this EEA HCP Privacy Notice.
- To third parties that are providers of our services, such as data analysis, data technology and provision of related infrastructure, client support, audit and other services.
- To data companies providing information services in the healthcare sector ensuring that your data are relevant and correct.
- To other companies with which we are communicating on joint development, distribution and/or marketing of certain products or services.
- In compliance with the requirements of legal acts, provisions of legal proceedings, orders of court or governmental authorities or requirements in respect of legal procedures commenced in respect of us.
- In undertaking legal actions or otherwise defending safety, rights or property of our clients, the society, Pfizer and companies related to us.
- In preparing, effecting or completing reorganisation, merger, sale, appointment or transfer, forming a joint venture or otherwise disposing of our business, assets or securities or part thereof (including bankruptcy or similar procedures).
BASIS FOR DATA PROCESSING
We will process your Personal Data under the following legal grounds:
Consent: (i) for direct marketing communications provided by Pfizer; (ii) for communication and maintaining other contacts;
Legitimate interest: (i) while keeping financial accounting of expenses for healthcare professionals; (ii) while communicating and maintaining other contacts; (iii) while providing marketing and promotional communications; (iv) while carrying out activity, ensuring quality, for statistics and other legitimate purposes;
Legal obligation: (i) in view of the obligation established in the Law on Pharmacy of the Republic of Lithuania and legal acts implementing this law, Pfizer must disclose to the State Medicines Control Agency under the Ministry of Health information pertaining to transferred values in order to improve the quality of provided healthcare and/or pharmaceutical services, improve the professional qualification of healthcare and/or pharmacy professionals, as well as to healthcare and/or pharmacy professionals for services provided to registrators of medicinal products and/or their representatives in order to transfer the available knowledge and experience in the field of medicine to registrators of medicinal products and/or their representatives, except for healthcare or pharmaceutical services that are provided while working in an individual healthcare institution or pharmacy; (ii) ensuring the compliance with the requirements of other legal acts applied by Pfizer.
DISCLOSURE OF REMUNERATION AND OTHER DATA ON TRANSFERRED VALUES
In view of the obligation established in the Law on Pharmacy of the Republic of Lithuania and legal acts implementing this law, Pfizer will disclose to the State Medicines Control Agency under the Ministry of Health information pertaining to transferred values in order to improve the quality of provided healthcare and/or pharmaceutical services, improve the professional qualification of healthcare and/or pharmacy professionals, as well as to healthcare and/or pharmacy professionals for services provided to registrators of medicinal products and/or their representatives in order to transfer the available knowledge and experience in the field of medicine to registrators of medicinal products and/or their representatives, except for healthcare or pharmaceutical services that are provided while working in an individual healthcare institution or pharmacy. Such data can include, inter alia, the amounts of the support provided by Pfizer to you, sizes of registration fees to professional (scientific) events, expenses of travels to professional (scientific) events and accommodation. Pfizer will also disclose to the State Medicines Control Agency under the Ministry of Health your name and surname, professional qualification and stamp number.
The above information will be published on the website of the State Medicines Control Agency under the Ministry of Health. Such information is published for a period of two years from the first day of its publication on the website of the State Medicines Control Agency under the Ministry of Health.
We will store such Personal Data for three years from this first day of the publication of such information on the website of the State Medicines Control Agency under the Ministry of Health.
Such data are processed and disclosed with a view to:
- Increasing the transparency of cooperation of registrators of medicinal products and/or their representatives with healthcare and pharmacy professionals and individual healthcare institutions.
- Ensuring the public interest to know about transferred values and their recipients to enable patients to make reasonable decisions based on such information in selecting physician, being more active in choosing and administering the required treatment or making decisions on acquisition of medicinal products in pharmacies.
If you wish to review, rectify, keep up to date the Personal Data you provided, prohibit, restrict or object to the processing of such data, withdraw your consent, or if you wish to get an electronic copy of such Personal Data in order to transfer it to another company, you can contact us as indicated in the chapter “Contact us”. We will respond to your inquiry in compliance with the requirements of the applicable legal acts.
Please specify in your request which Personal Data you would like to change, if you would like to prohibit them in our data base or indicate other restrictions you would like to apply to our use of such data. Prior to complying with your request, we may need to verify your identity, for the sake of your security. We will try to comply with your request as soon as possible.
Please note that we may need to retain certain Personal Data for the purpose of documentation and/or to complete the operations that you have started prior to requesting to change or remove the data.
We do our best to apply reasonable organisational, technical and administrative measures in order to protect your Personal Data. Unfortunately, no data transfer or storage system can be absolutely safe.
We will store your Personal Data as long as it is necessary or allowed taking into account the purpose for which such data were obtained and as stipulated in this Privacy Notice. The criteria for setting our storage period: i) a period during which our relationships with you last and we provide the services of the Website to you, ii) if we are subject to any legal liabilities, or iii) if storage is advisable taking into account our legal situation (e.g. taking into account the provisions of using the Website, applicable restriction regulations, litigation or control analyses).
Data collected by us through the Website can be stored and processed in any country where we have infrastructure or use service providers, including the United States of America and countries where companies related to us are operating.
Some of non-EEA countries are recognised by the European Commission as providing data protection of a sufficient level under the EEA standards (the full list of such countries is here https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en). When transferring data from EEA to countries that are not deemed by the European Commission as ensuring a sufficient level of data protection, we have arranged for sufficient measures, e.g. ensuring that a recipient complies with the provisions of the EU standard agreements, in order to protect your Personal Data. You can get the list of such measures by contacting us as specified in the chapter “Contact us”.
USE BY MINORS
The Website is not intended for persons under sixteen (16) years old and we do not collect knowingly Personal Data from such persons. If you are not of the consent age provided for in your jurisdiction, you will need your parents’ or legal guardian’s consent to use the Website. Please consult your parents or legal guardian before using the Website.
In case you provide us with Personal Data of persons under sixteen (16) years old, you confirm hereby that you are authorised for that and can prove such right upon Pfizer’s request.
From time to time, we update this Privacy Notice. Any amendments will come into effect after we publish the amended Privacy Notice on the Website. The last time this Privacy Notice was updated on the above date of the “Last update”.
The below company is responsible for the collection, use and disclosure of your Personal Data under this Privacy Notice:
Pfizer Luxembourg SARL Lithuania Branch
A. Goštauto str. 40A, Vilnius,
If you have any questions about this Privacy Notice or would like to exercise your individual rights, please write to the following address:
Pfizer Luxembourg SARL Lithuania Branch
A. Goštauto str. 40A, Vilnius,
You can also contact the responsible data protection official of your country or region. You will find his contact information at DPO.Pfizer.com.
To get a copy of these measures, visit https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
LODGING A COMPLAINT WITH SUPERVISORY AUTHORITY
You can lodge a complaint with the data protection authority situated in your country or region or the place of the alleged infringement. Contact information of such authorities is provided here http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080