Privacy Policy
UCB GENERAL PRIVACY POLICY FOR HEALTHCARE PROFESSIONALS
Find HERE the Privacy Policy for Healthcare Professionals in your language
UCB or we means UCB S.A., a Belgian company with registered office at Allée de la Recherche 60, 1070 Anderlecht and its affiliates. For more information on the contact details of the UCB affiliate in your jurisdiction, please visit the ‘UCB Worldwide’ overview at https://www.ucb.com/worldwide and select your country.
As controller, i.e. the legal entity that decides on the why and how information relating to you (personal data) is collected and processed by us in the context of your or your healthcare organisation’s relationship with UCB, we respect your right to privacy.
We will only process your personal data as described in this UGPPH or policy, supplemented by our other privacy policies - to the extent that those may apply to you - e.g. within the framework of your participation as a healthcare professional (HCP) in our Patient Support Programmes (PSPs), studies (including observational studies, clinical trials etc.), or when browsing any one of our websites for which separate website privacy policies are in place. We will at all times process your personal data in accordance with the relevant data protection legislation, including the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation or GDPR).
At UCB we have a data protection officer (DPO), who can be contacted by any of the following means for any privacy-related questions, including regarding how we collect, store and use your personal data:
E-mail: dataprivacy@ucb.com; or
Regular mail: To the attention of the (global) Data Protection Officer, Allée de la recherche 60, 1070 Anderlecht or to the attention of the local UCB Data Protection Officer at the postal address of the UCB affiliate in your jurisdiction. For more information, please visit https://www.ucb.com/worldwide and select your country.
As a leading biopharmaceutical company, UCB has close relationships and engages in a continuous dialogue with many HCPs. The UGPPH governs the general collection, use and retention by UCB of personal data relating to (i) HCPs and (ii) HCPs acting as a representative or contact person for a healthcare organization (HCO), with whom we have a business relationship. As indicated above, additional privacy related information may apply to you within the framework of your participation in e.g. our PSPs, studies or when browsing any one of our websites. You will find these additional privacy terms on the relevant webpage or tool. In other words, in addition to reading this UGPPH, please also carefully read through other privacy related information which may apply to you and this prior to participating in any UCB PSP, study or browsing any one of our websites.
The UGPPH consists of five main components and informs you about:
Who we are and how you can contact us;
The reason behind this policy;
The purposes for which we process your personal data, the related legal basis under GDPR and applicable retention periods;
What your rights are in relation to the personal data we hold about you and how you can exercise them; and
Further details on how we process (including transfer) your personal data.
The UGPPH may be updated periodically to reflect changes in our personal data processing activities. In that case we will inform you of any significant changes by posting a prominent notice on UCB.com (the Website) or by informing you through the same channel we usually use to communicate with you.
The table below indicates per purpose (i) the categories of personal data we collect and process concerning you, (ii) the source, (iii) how long we retain your personal data, (iv) who we share it with, and (v) the relevant legal basis under GDPR.
1. To manage our professional relationship with you, including:
a) planning and following up (including UCB internal reporting) on interactions and communications with you - including call and visit management;
b) optimizing our interactions and communications with you based on your preferences (including in terms of content, format, preferred channels and frequency);
c) stakeholder segmentation within your geographical area and area of expertise (including identifying key opinion leaders as well as in order to enable us to identify relevant study sites for the conduct of clinical trials);
d) avoiding duplication as well as improving the quality of our interactions with you - based on your indicated needs and preferences;
2. To efficiently manage our relationship with you within the framework of collaboration agreements with our partners (including e.g. other pharmaceutical companies) and avoid duplication in interactions with you
3. To obtain your feedback and professional insights (including through advisory boards, market research and survey tools) on (i) what is important to you and/or your patients, (ii) important trends in patient management in your area of expertise; (iii) how UCB and its products are perceived by you; and (iv) how we can further evolve and customize our services and products, and offer these to you. We may also combine your personal data collected through direct marketing campaigns, with other personal data we collected through other channels for the same purposes as outlined here (including customization of our services/products and related offer)
UCB Collects the following personal data about you:
1. Master data (i.e. data used to identify you in our systems)
a) Your general and identification details: including your full name, title, language, a unique identifier assigned to you by and in our databases
b) Your contact details: postal address, phone number(s), e-mail address
c) Your professional details: including your job title, your medical education, your professional background information, your area(s) of expertise
d) Information that would allow stakeholder segmentation within your geographical area and area of expertise
e) Aggregated information relating to digital behavior: Information on digital presence, digital audience and digital activity
2. Activity data (i.e. data related to our professional interaction with you other than clinical activities):
a) Your insights: including your outlook on therapeutic concepts and approach to the products and/or therapeutic areas of our company
b) Any other information or feedback on our company, products and/or therapeutic areas that you may provide at your discretion in the context of our relationship with you
Failure to provide the abovementioned information prevents UCB from fulfilling our legitimate interests (indicated below). Please note that if such information is shared in the context of a contract with you, certain data will be required for the purpose of entering into a contract (see further below under point 8). Failure to provide such personal data would prevent UCB from executing a contract with you.
UCB obtains this personal data from:
You
Our third party processors (as detailed in section 5.A)
Social media companies in accordance with their terms and conditions
Publicly available online sources (such as PubMed, Clinical Trials.gov, congress websites or university websites)
UCB retains (*) your personal data for:
Master data: for the duration of our professional relationship with you. In relation to HCP retirement or cessation of professional activities: for a maximum of 36 months after we are informed of your retirement / cessation of professional activities
Activity data: this data is kept for 60 months after the relevant activity took place (e.g. an event, a congress, a visit, a call)
Consent management data: this data is kept for 120 months following receipt of your consent
UCB shares your personal data with:
UCB affiliates and third party processors (as detailed in section 5.A)
UCB relies on the following GDPR legal basis:
Processing necessary for the purpose of the legitimate interests pursued by UCB to conduct its business (including research and development of new medicines creating value for people living with severe diseases in in UCB’s therapeutic areas of interest) and to maintain a professional relationship with you. To this end, UCB strives to maintain a fair balance between its need to process your personal data and the preservation of your rights and freedoms, including the protection of your privacy (**). (Regarding the processing of information for the execution of a contract with you, e.g. in relation to your participation in an advisory board or in relation to certain market research, we refer to what is set out below under point 8.)
4. To respond to your queries and provide you with requested support
5. To allow and document the distribution of product samples to you
6. To invite you to attend and permit your attendance to academic, scientific and promotional meetings, events, conferences (sponsored by us) linked to your medical expertise and to promote such meetings, events, conferences and other services to you, including based on your previous attendance and other information which will help us, for example, offer you attendance at the events that better suit your interests. We may also combine your personal data collected through these events, with other personal data we collected through other channels for the same purposes as outlined here (including promotion)
UCB Collects the following personal data about you:
1. Master data (i.e. data used to identify you in our systems):
a) General and identification details: including your full name, title, language, a unique identifier assigned to you by and in our databases
b) Your contact details: postal address, phone number(s), e-mail address
c) Your professional details: including your job title, your area(s) of expertise
d) Country specific identifiers (including your local registration number as an HCP in relation to the local healthcare system)
2. Activity data (i.e. data related to our professional interaction with you - other than clinical activities - and related to you attendance to said meetings, events and conferences):
a) Information about events/ conferences in which you participated/which you attend
b) Information about topics that were discussed, key messages from you, product information shared with you, and any interests you have shared regarding such topics, meetings, events and/or conferences
c) Travel details and logistics, dietary preferences (as applicable), as well as any other information required to enable your attendance to UCB sponsored or organized conferences, meetings or events, for which you signed up
Failure to provide us with the abovementioned information prevents us from inviting you to and allowing your attendance to UCB sponsored conferences, meetings or events.
UCB obtains this personal data from:
You
Our third party processors (as detailed in section 5.A)
UCB retains (*) your personal data for:
Master data: for the duration of our professional relationship with you. In relation to HCP retirement or cessation of professional activities: for a maximum of 36 months after we are informed of your retirement / cessation of professional activities
Activity data: this data is kept for 60 months after the relevant activity took place (e.g. an event, a congress, a visit, a call)
Consent management data: this data is kept for 120 months following receipt of your consent
UCB shares your personal data with:
UCB affiliates and third party processors (as detailed in section 5.A)
UCB relies on the following GDPR legal basis:
Processing based on your consent for information related to the sending and receipt of any communications regarding UCB sponsored academic, scientific and promotional meetings, events, conferences
Processing based on performance of a contract for any information required to enable your participation in the UCB sponsored conference, meeting or event for which you signed up.
7. To enable UCB to send you personalized direct marketing communications by email or other electronic means, regarding medical and scientific updates (including relevant and up to date information about certain diseases and treatments), corporate information and/or products and services we promote, or containing deeplinks to UCB websites containing such information and analyze your interactions with such communications (e.g., which content/links you may have interacted with, or whether you opened our messages at all), to better understand what communications would be interesting for you. We may also combine your personal data collected through direct marketing campaigns, with other personal data we collected through other channels for the same purposes as outlined here (including personalized direct marketing)
UCB Collects the following personal data about you:
1. Master data (i.e. data used to identify you in our systems):
a) General and identification details: including your full name, title, language, a unique identifier assigned to you by and in our databases
b) Your contact details: e-mail address
c) Your professional details: including your job title, your area of expertise
d) You interest area
e) Country specific identifiers (including your local registration number as an HCP in relation to the local healthcare system)
2. Electronic identifiers:
a) Information collected through cookies and other tracking technologies that will be set when you visit UCB websites or when you interact with our communications (e.g. when you are directed to our websites by clicking on “deeplinks” provided in e-communications to you). (Deeplinks mean hyperlinks inserted in UCB communications, which allow HCPs to visit certain UCB websites dedicated to them and skip the usual log-in). For more information on cookies and other tracking technologies used on UCB websites, please check the cookie policy on that website.
3. Activity Data (i.e. data related to our professional interaction with you other than clinical activities):
a) Activity information, including whether or not e-mails sent to you by us were opened, if you accepted our invitation to e.g. online content, etc.
4. Consent management data (i.e. information on your utilization and preferences relating to communication format, channels and frequency):
a) Whether you opted in for receiving such communications
b) Whether you opted out for receiving such communications
Failure to provide the abovementioned information will prevent UCB from sending to you the requested direct marketing communications
UCB obtains this personal data from:
You
Our third party processors (as detailed in section 5.A)
UCB retains (*) your personal data for:
Master data: for the duration of our professional relationship with you. In relation to HCP retirement or cessation of professional activities: for a maximum of 36 months after we are informed of your retirement / cessation of professional activities
Electronic identifiers: for more information on the retention periods of any cookies used, please check the cookie policy on that website
Consent management data: this data is kept for 120 months following receipt of your consent
UCB shares your personal data with:
UCB affiliates and third party processors (as detailed in section 5.A)
UCB relies on the following GDPR legal basis:
Processing based on your consent
For cookies and other tracking technologies, processing based on your consent (except for strictly necessary cookies). For more information please consult the cookie policy of the website you are visiting.
8. In order to enable UCB to:
a) [on an aggregate user level – through Google analytics] support and improve the functionality of and better understand usage patterns relating to our websites, we use cookies, including by retaining and evaluating information on recent use you made of our website and how you access different features of our website for analytics purposes so that we can make our websites more intuitive;
b) [on an individual level] obtain insights regarding your preferences and interests by tracking your browsing behaviour on the UCB website(s) you visit, so that we may use this information to tailor our interactions (including face-to-face meetings and other communications) with you, and our offers to you.
We may also combine your personal data collected through cookies, with other personal data we collected through other channels for the same purposes as outlined here (including to tailor our interactions and offers to you)
9. (To the extent applicable) to execute a contract with you/ the HCO you are working for and to perform our obligations and exercise our rights under such contract (including billing and invoicing - to the extent applicable to our relationship with you)
10. To enable UCB to (i) comply with its EU/EU Member State legal obligations (including but not limited to pharmacovigilance, archiving and record keeping, transparency laws, etc.), (ii) perform regulatory audits, and (iii) respond to requests from (EU/ EU Member State) regulatory or judicial authorities
UCB Collects the following personal data about you:
Your identification details: including your full name, function/ title, initials;
Your contact details: including your e-mail address, telephone number, postal mail address;
Your professional details: including your job title
Any other information required as per our legal obligations (e.g. in relation to adverse event reporting, further information on the adverse event and your involvement therein; in relation to transparency reporting, information on transfer of value, etc.)
The provision of this information is a statutory requirement. Failure to provide it will prevent UCB from fulfilling its legal obligations.
UCB obtains this personal data from:
You
(To the extent applicable) the HCO you work for/with;
Our third party processors (as detailed in section 5.A)
UCB retains (*) your personal data for:
For as long as required as per our legal obligations. E.g. in relation to adverse event related information for a period of 10 years following the end of the marketing authorisation for the relevant product
UCB shares your personal data with:
Competent regulatory and government agencies/authorities
UCB affiliates and third party processors (as detailed in section 5.A)
The general public in relation to transparency disclosures
UCB relies on the following GDPR legal basis:
Processing necessary for compliance with our legal obligations (including but not limited to pharmacovigilance laws, transparency laws etc.)
11. To enable UCB to comply with industry guidelines relating to transparency (as opposed to mandatory law which is described above under point 9)
12. To safeguard UCB’s business interests, including against legal claims and in legal proceedings and in order to provide evidence of transactions
13. To (i) perform audits based on non-European laws, (ii) comply with non-European laws and regulations and (iii) handle requests from non- European judicial or regulatory authorities
If you wish to exercise any of the rights mentioned above, please contact UCB as set out under section 1 (“Who we are and how you contact us”). Please clearly identify the right(s) you wish to exercise and include your contact details (including a valid e-mail or postal address) so that we can respond to your request. Please note that you may be asked to provide proof of your identity.
When you contact us to exercise any of the rights mentioned above, we will respond to your request within one month following receipt of the request. This period may be extended by two additional months where necessary, but in that case we will inform you of any such extension within one month of receipt of your initial request together with the reasons for the delay.
In accordance with article 77 GDPR you have the right to lodge a complaint with a supervisory authority, in particular in the European Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that UCB’s processing of your personal data infringes the GDPR. Please visit the website of the relevant national supervisory authority for more information on how to submit such a complaint.
Principle
We will disclose your personal data only as described in this UGPPH (as further detailed above), as may be updated from time-to-time.
UCB affiliates and third party processors
UCB transfers or discloses your personal data to its personnel, affiliates, our third party service providers processing personal data on UCB’s and/or their own behalf for the purposes set out above and our partners (including e.g. other pharmaceutical companies) with whom we have a collaboration agreement and who have a need to know this information.
Third party service providers include CRM and cloud service providers, IT services/ consulting/ outsourcing companies, database providers, market research suppliers, homecare delivery suppliers, event agencies and organizers, marketing and data analytics services providers, travel agencies and providers, banks and insurance companies that deliver services to us. These service providers provide their services from locations within and outside of the European Economic Area (EEA).
Other third parties include regulatory and government agencies (see further below in this UGPPH), our advisors and external legal counsel, our auditors and potentially, third parties with whom UCB may merge or which may be acquired by UCB (see further below in this UGPPH).
Compliance with laws and legal proceedings
UCB will disclose your personal data where:
UCB is required to do so by applicable law, by a governmental body or by a law enforcement agency;
To establish or exercise our legal rights or defend against legal claims;
To investigate, prevent or take actions against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies or as otherwise required by law.
Other
If a third party acquires all (or substantially all) of our business and/or assets, we will disclose your personal data to that third party in connection with the acquisition. However, such disclosure will occur subject to and in accordance with applicable data protection laws, including the GDPR.
UCB will transfer your personal data to its affiliates, including our affiliates outside of the EEA. In that case UCB relies on UCB’s Binding Corporate Rules, which can be accessed through the following link: https://www.ucb.com/UCB_BCRs.pdf.
The transfer of your personal data to third party service providers (as set out above under section 5A) in countries outside of the EEA that do not ensure an adequate level of (data) protection, occurs on the basis of Standard Contractual Clauses that have been executed between UCB and the relevant third party service provider. You may - by exercising your rights set out above under section 4.B (How to exercise your rights) - obtain a copy of the relevant safeguard UCB has put in place or ask UCB to redirect you to the place where they have been made available.
In the absence of the aforementioned appropriate safeguards, UCB may – to the extent permitted under and in accordance with applicable data protection laws (including the GDPR) - rely on a derogation applicable to the specific situation at hand (e.g. the data subjects’ explicit consent, the necessity for the performance of an agreement, the necessity for the establishment, exercise or defense of legal claims).