TRANSFERS OF VALUE (TOV) & DATA PROTECTION PRIVACY POLICY

TRANSFERS OF VALUE (TOV) & DATA PROTECTION PRIVACY POLICY

1. What is a transfer of value?

As a pharmaceutical company and member of the European Federation of Pharmaceutical Industries and Associations ("EFPIA") and the Association of British Pharmaceutical Industry ("ABPI") Almirall Limited ("Almirall", or "we" or "us") is/are required to document and publically disclose certain transfers of value ("ToV") made to health care professionals and other relevant decision makers ("HCP" or "you").

The concept of ToV includes information about direct or indirect payments in cash or in kind that we make to HCPs for the following activities, in order to ensure the independency and integrity of these professionals when they are prescribing/recomending, dispensing and/or providing medicinal products to their patients in connection with the development or sale of medicines:

2. Which personal data Almirall are we required to process and disclose?

If you give us your consent, we will disclose TOVs made to you to the ABPI  on an individual basis. This means that it will include the following personal data:

3. Who is the "controller" of the personal data provided?

We are the controller of these data. Below you can find Our corporate details and also you can explore a little bit more about Us at www.almirall.co.uk or contact us at TOVconsentuk@almirall.com.

Almirall Limited is a UK company, with registered address at Harman House, 1 George Street, Uxbridge, Middlesex, UB8 1QQ registered in England and Wales: company number 6320852 You can contact us at +44(0)2071602500.
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

4. For what purposes is Almirall going to use your personal data?

We will use your personal data to process and disclose ToVs made to you to comply with the ABPI and EFPIA Codes. This will also be proof that you have read and expressly accept Almirall UK Privacy Policy.

Appendix A – Privacy Policy. In order to do this we need your consent for:

1. Almirall and/or its affiliates (please visit www.almirall.com to check the updated list):

a) storing and using your information for the purposes of meeting our obligations under the Codes;

b) making public disclosures of such information consistent with the Codes and with applicable laws, from time to time in force;  please note that such disclosure may be made using any media, including printed reports, electronic communication, Almirall's corporate website or its affiliates or other platforms;

c) disclosing such information to the ABPI its contractors and sub-contractors as may be required in furtherance of the objectives of the Codes which include monitoring the activities of member companies and those agreeing to abide by the Codes to ensure compliance with the terms and spirit of the Codes, particularly in relation to the prohibition of inducements to supply or prescribe particular products;

d) for the purpose of enabling us to meet its obligations under the Codes, transferring such information to other affiliates and/or to any third party providing services to the Almirall, who may be established in jurisdictions outside the European Economic Area, for the purpose of storage, use and public disclosure of such information and/or to comply with codes of practice;

2. The ABPI:

a)    making public disclosures of such information consistent with the Code; such disclosures will be made on the ABPI disclosure central platform, and will identify you by name as having received ToVs from Almirall and details of those payments;

b)    or its contractors or sub-contractors, contacting you to verify the accuracy of the data transferred to the ABPI by or on behalf of us;

c)    or its contractors or sub-contractors, performing statistical analysis on the information provided to the ABPI by us; and

d)    using the information to inform the ABPI's engagement with the media around the transparency provisions of the Codes.

5. For how long do we keep this information, including your personal data?

We are required to disclose ToV per calendar year within the first six month of the following year. Your personal data will be published on the ABPI central platform for a 3 year period. Your data will be retained by us for a minimum period of 3 years and stored for a minimum of five (5) years once the relevant payment has been disclosed up to a maximum of seven (7)  years.

6. Rights that you have

At any time you may exercise any of the following rights:

a)    Right of access: you may obtain access to your information.

b)    Right to rectification: you are entitled to have your information corrected if it is inaccurate or incomplete.

c)    Right to erasure: you can request the deletion or removal of the information concerning yourself where there is no compelling reason for an organisation to keep using it. This right is also known as "the right to be forgotten".

d)    Right to restrict processing: you can  ‘block' or suppress further use of your information in certain circumstances. When processing is restricted, we may still store your information, but may not use it further.

e)    Right to data portability: you can obtain and reuse your personal data for your own purposes across different services with a different data controller. If you request the direct transfer of the data to another data controller, this will only take place if it is technically feasible.

f)    Right to object: you can object to certain types of processing, in certain circumstances.

Your consent to individual disclosure is voluntary. Therefore, exercising any of the above rights is not detrimental and will not have other effects to the agreements We have with you.

7. Contact details and our support

You may contact Almirall at any time to correct any mistakes or request deletion of personal information relating to you. The consequence of a request for deletion that places Almirall Ltd. or its affiliates in breach of obligations under applicable codes and laws will be that Almirall Ltd. shall be entitled to terminate this Transfers of Value agreement on written notice to you.

To correct any mistakes, exercise your data protection rights or request deletion of personal information please email TOVconsentUK@almirall.com
You can contact the Information Commissioner's Office (ICO) https://ico.org.uk/ for any claim related with the use of your personal data, as we are registered with them.