UK & Ireland Privacy Statement for interactions with healthcare professionals

Date of update: January 2025

This document describes how Almirall process personal data in relation to our interactions with healthcare professionals.

The first section consists of a basic information that you should know. In the second section you can find additional information that broadens and complements the basic information.

If you have any questions regarding this privacy statement, you can contact our DPO at dpo.global@almirall.com

1. Basic information

2. Additional information

2.1.  WHO IS THE CONTROLLER OF THE DATA YOU PROVIDE?

The data controller of your personal data is Almirall Limited, with registered address at Harman House, 1 George Street, Uxbridge, Middlesex, UB8 1QQ registered in England and Wales: company number 6320852.

For more information about this document or how we process your personal data, you can contact our Global Data Protection Officer at the e-mail address dpo.global@almirall.com.

You can contact Almirall Ltd at the telephone number +44(0)2071602500.

If you are based in the EU and have any questions about our privacy statement, your rights regarding your personal data, or how we use your personal data, please do not hesitate to contact our appointed EU representative, Symmetry Solutions Ltd, at:
- Email: almirall@symmetrygroup.ie
- Post: FAO Almirall EU Rep, Symmetry Solutions Ltd, The Tara Building, 11-15 Tara Street, Dublin 2, D02RY83, Ireland.

2.2. WHAT PERSONAL DATA DO WE PROCESS?

The personal data that we store and process for the purposes indicated in the following section are:

a) Contact information: this category of personal data includes, for example, your name and surname, your professional address (workplace), your telephone and fax number, your specialty, as well as your email address, identification code, your signature and other contact information. You might have given us voluntarily your information by filling in a form, either through our contact with you, or we might have extracted it from professional directories, or from other sources accessible to the public. The company IQVIA Information, S.A. also provides us your contact information for the purposes indicated in the following section.

b) Information about you that we gather: we document and include in our customer relationship tools, information about the visit by our sales representative, about your interests, your interaction with us, your capacity for influence and decision, etc.

c) Banking and financial information: this information is only processed if it is necessary to pay for your services or reimburse your expenses in relation to any specific activity.

d) Other professional information: this information may refer to publicly available professional information, such as publications, presentations and participation in events, clinical or research activities carried out, academic positions, or other relevant professional information. This information is also provided to us by the company Veeva Systems Inc.

2.3. FOR WHAT PURPOSES DO WE USE YOUR PERSONAL DATA?

We may process your personal data for one or more of the following purposes:

a) Visits of our sales representatives and/or other Almirall representatives to provide you with updated information about our products and our services and answer your specific questions on medical information;

b) Invitations to scientific meetings and/or medical education activities, both our own and those we sponsor and consider that may be of your interest;

c) Distribution of free samples of our products;

d) Adapt our professional interaction based on your specialty, your professional habits, as well as the interest shown in our products, based on the information obtained from our previous interactions with you, as well as publicly available information or information provided by third parties about your professional and medical experience;

e) Ensuring Almirall's regulatory compliance in pharmacovigilance matters. In relation to this purpose, you can find more information by visiting our website www.almirall.co.uk and accessing our UK/IE Drug Safety Privacy Policy. 

f) Ensuring compliance with Almirall's legal or deontological and ethical obligations of the Pharmaceutical Industry obligations regarding transparency in relation to Transfers of Value (TOV) that we can make in your favour as a result of an activity or the provision of a service. In this case we will inform you in advance about the applicable privacy statement to this particular data processing;

g) Recruitment and evaluation of suitability for participation in clinical trials and other research studies, advisory committees, presentations, provision of services, etc, to ensure Almirall complies with the Fair Market Value in relation to the fees related to these activities (Medical Tiering), in compliance with the legal obligations to which Almirall is subject, the codes of conduct to which Almirall is signatory and/or good market practices regarding the ethics standards in Almirall, as the case may be. This processing permits to match your data with the object of the engagement with you and determine the fair market value for any fees.

h) Carrying out surveys and market studies related to the medical/health sector which carry wider societal benefits;

i) Sending communications by electronic media and direct marketing, by any channel, to healthcare professionals to inform about new products and new approved indications of existing products, news or Almirall activities that may be of your interest. In this sense, we can also analyse the use you make of them (for example, if you click on the links received). In relation to this purpose, if your data comes from your registration on any of our web pages or mobile applications, in each of them you will have provided the specific processing conditions and previously you will have given your specific consent for each of the purposes.

j) Answering your queries, including Medical Information queries.

k) Interact with healthcare professionals through our profiles on social media.

2.4. HOW LONG WILL WE STORE YOUR DATA?

Your data will be stored as long as it is correct and you remain linked to a health-related profession, during the maximum period required by law or as required by sectorial self-regulation, without prejudice to the fact that, due to legal requirements, this temporary period may be extended.

For Pharmacovigilance, after the maximum period of one (1) year following the completion of an adverse event case your data will be made unidentifiable. Such information will be kept secured in line with legal requirements to which Almirall is subject, during the commercial life of the product plus 10 years.
 
For Medical Information enquiries, your personal data will be kept for the time necessary for resolution and quality assurance purposes. As maximum we will keep your data for one (1) year after enquiry completion, after which your data will be made unidentifiable.

2.5. WHICH IS OUR LAWFUL BASIS TO PROCESS YOUR PERSONAL DATA?

Our lawful basis to process your personal data, according to the specific purpose may be one of the following:

• Purposes (a), (b), (d), (g), (j) and (k): necessary for the achievement of the legitimate interest of the Controller, in particular:
  • Purpose (a): This purpose is based on the legitimate interest for contacting with healthcare professionals to schedule a visit to inform about our products and services, allowing us to inform directly of this to healthcare professionals. This processing is beneficial for us, since it allows to inform about our products and services, as well as for the healthcare professionals as they can be informed about offers and services available in their respective professional sector. The processing is necessary, as well as proportionate, for contacting HCPs and health managers to inform them about our products and services.

    
    In addition, taking into account (i) the nature of the data, that is to say, identification and professional details about the HCPs; (ii) the way this data is processed to manage our relationship with those data subjects; (iii) and the reasonable expectation of this processing that the data subjects may have, we can conclude that the impact of this processing about the rights and freedoms of the data subjects does not result invasive nor disproportionate.

  • Purpose (b): This purpose related to the invitation of healthcare professionals to scientific or medical meetings and training is based on the legitimate interest since it is a way for publishing our products and services, as well as promoting in the professional healthcare environment, creating in turn an "Almirall" community.

    This processing is also beneficial for the data subjects as they have the opportunity to increase their contacts network and to improve their knowledge by attending to meetings and trainings.

    The processing activity is deemed as necessary and reasonable as it helps us to reach our objectives of marketing, taking into account (i) the nature of data, that is to say, identification and professional details about the HCPs; (ii) the way this data is processed to manage our relationship with those data subjects; (iii) and the reasonable expectation of this processing that the data subjects may have; We can conclude that the impact of this processing is not invasive nor disproportionate to the rights of the data subjects.

  • Purpose (d): To adapt our professional interaction based on your specialty, professional habits, declared interests, or other publicly available professional information is justified by our legitimate interest as it allows more efficient and personalized professional communication and to specify our collaboration proposals with the data subject more precisely. This activity will only be carried out to provide Almirall with a broader view of your professional information to contact you about projects or professional collaborations for mutual benefit.

    
    Considering that (i) the data processing is carried out with information solely related to the professional activity of the data subject; (ii) obtained from public information sources; (iii) the company that provides us with this information also communicates it to the data subject, so there is a reasonable expectation of this processing, (iv) the profiling is not exhaustive and does not involve automated decision-making, and (v) it only affects data subject’s in the direct professional interaction with Almirall, we can conclude that the impact of this processing is not invasive or disproportionate to the rights of data subjects.

  • Purpose (g): Recruitment and evaluation of suitability for participation in clinical trials and other research studies, advisory committees, papers, provision of services, etc. It is based on our legitimate interest to contact any of the professionals with whom we interact for carrying out collaboration activities, such as getting your opinion in any study, promotion of our products and services, etc. and matching the payments to the Fair Market Value. However, in some countries, this processing activity may be based on the legal obligations to which Almirall is subject in the field of compliance with Fair Market Value with HealthCare Professionals, in attention to the applicable laws.

    This processing is also beneficial for those data subjects as they have the opportunity to participate in clinical trials and other research studies, advisory committees, etc. Likewise, the processing is necessary since it allows us to contact professionals of the healthcare environment for their participation in our research activities.

    Also, taking into account (i) the nature of the data, which are merely identifying and professional data of the data subjects; (ii) the way this data is processed to manage our contact and payments with them; and, (iii) the reasonable expectation regarding the processing; We can conclude that the impact of this processing is not invasive nor disproportionate to the rights of the data subjects.

  • Purpose (k): The interaction that can take place with Almirall through Almirall's profiles on social media may include, but is not limited to, responding to messages or comments, sharing content, generating reactions, or other actions when the data subject follows us on social media. This processing is based on our legitimate interest in providing relevant information and interacting with other users on social media. Considering (i) the nature of the data (social media profile and any information shared with third parties), (ii) its processing for the purpose of interacting with the data subject through these channels, and (iii) the reasonable expectation of this processing by the data subject, we can conclude that the processing is based on a legitimate interest.

• Purpose  (c) and (h): The legal basis for such purposes is the consent given by the data subject. Such consent may have been given through a clear affirmative action that reflects a manifestation of free, specific, informed, and unequivocal will of the data subject to accept the data processing.
• Purpose (e): The legal basis for this purpose is the fulfilment of legal obligations arising from sector self-regulation, as well as public interest in health.
• Purpose (f): The legal basis for this purpose is the fulfillment of legal obligations arising from sector self-regulation.
• Purpose (i): The legal basis for such purpose is the consent given by the data subject. Such consent may have been given through a clear affirmative action that reflects a manifestation of free, specific, informed, and unequivocal will of the interested data subject to accept the data processing. Likewise, the legal basis may also be the fulfilment of contractual obligations or to manage pre-contractual relationships.
• Purpose (j):The legal basis for this purpose is compliance with the regulatory obligations to which Almirall is subject as a pharmaceutical company, as well as our legitimate interest in providing you with information about our products. These inquiries may relate to product information, scientific information (Medical Information), as well as any other type of questions you may raise with Almirall. This processing is also beneficial for the data subjects, as they have the opportunity to seek clarifications about Almirall’s products and/or other related scientific matters. Likewise, the processing is necessary as it allows us to provide the necessary information in response to the requests we may receive from you. Additionally, considering (i) the nature of the data, which are merely identifying data, and the content of your inquiry; (ii) the way these data are processed to provide Medical or other types of Information; and, (iii) the reasonable expectation regarding the processing, we can conclude that the impact of this processing is not invasive nor disproportionate to the rights of the data subjects.

2.6. WITH WHOM WILL WE SHARE YOUR DATA?

Your data will not be transferred to third parties, except to public bodies and authorities (administrative or judicial), as long as they are required in accordance with legal and regulatory provisions. Personal data regarding transfers of value will be disclosed as fully detailed in our privacy statement related to such processing which will be timely informed.

Likewise, we may share your data with companies that help us carry out the different purposes indicated in section 2.3 above with which we have signed service agreements or data processing agreements that ensure the processing of your data on a confidential basis and under the legislation applicable at any time.

Whenever information needs to be transferred and that requires an International Transfer of personal data, Personal Data will be duly protected by standard contractual clauses approved by the European Commission and/or UK standard contractual clauses, binding corporate rules of the data processor or other mechanisms that ensure appropriate safeguards for international transfers.

2.7. WHAT RIGHTS DO YOU HAVE IN RELATION TO YOUR PERSONAL DATA AND HOW CAN YOU EXERCISE THEM?

(i) Your right to be informed: This privacy statement provides you with information on the purpose for processing your personal data. This includes the right to be informed about the source of personal data if we hold it because of a third party (such as the Onekey database controlled by the company IQVIA or Veeva Systems Inc.).

(ii) Your right of access: You have the right to obtain confirmation that your personal data is being processed, have access to your personal data, and other supplementary information – (as provided in this legally compliant privacy notice). Accordingly, Almirall will provide details of the information we hold about you on request.

(iii) Your right to rectification: Almirall will rectify any personal data that is inaccurate or incomplete. If any inaccurate personal data has been disclosed to third parties, Almirall will inform them of the rectification where possible.

(iv) Your right to erasure: You have a right to have personal data erased and to prevent processing in specific circumstances, as set out under the GDPR. For example, where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed or when you withdraw consent or when you object to the processing and there is no overriding legitimate interest for continuing Almirall’s processing.

(v) Your right to limit or restrict processing: You can require Almirall to restrict the processing of your personal data, for example where you contest the accuracy of the contact date used. In such case, Almirall will pause, continue to store the data but do nothing else with it, and will re-consider the processing and the accuracy of the data.

(vi) Your rights in relation to profiling: You have the right not to be subject to solely automated decisions and if Almirall makes any such automated decisions, you have a right to have a person review the decision.

(vii) Your right to data portability: This refers to your right to obtain a transferable copy of your information we hold on our servers and databases so you or we can move it to another data controller or location.

(viii) Your right to object: You have the absolute right to object to processing of your personal data if it is for direct marketing. This is not something Almirall intends to do often but is listed as one of our business purposes at clause 2.3 above. Linked to this you have a contingent right to object to the processing of data where the processing is based on either the conditions of public interest or our legitimate business interests. Furthermore, you have the right to prevent processing that is likely to cause unwarranted substantial damage or distress to you.

To exercise your rights, you can send a written request addressed to Almirall Ltd, Harman House, 1 George Street, Middlesex, Uxbridge UB8 1QQ. 

You can contact the Information Commissioner’s Office (ICO); https://ico.org.uk or any European supervisory entity for any claim arising from the processing of your personal data, although you are first invited to get in contact with our Data Protection Officer at dpo.global@almirall.com for any queries in relation to the processing of your personal data. You can find an updated list of said organisations by jurisdiction at https://edpb.europa.eu/about-edpb/about-edpb/members_en.