ADDITIONAL INFORMATION ON DATA PROTECTION
Who is the data controller for your data?
Identity: CASEN RECORDATI, S.L. - TAX ID No.: B81094922
Postal address: AUTOVIA LOGROÑO KM 13,300 - CP: 50180 - UTEBO - ZARAGOZA, SPAIN
What purposes can we process your personal data for?
At CASEN RECORDATI, S.L. we may process your personal data for some or all of the following purposes:
▪ Management of the professional relationship with the data subject, whether for participation in events with scientific content, for collaboration in scientific and professional meetings or the provision of services; recruitment and/or payment of fees, as well as payment or reimbursement of expenses associated with such activities.
▪ Maintaining a detailed record of communications with the data subject for the implementation of the activities indicated in the section above.
▪ Publication of transfers of value (ToV) by CASEN RECORDATI, S.L. due to participation by the data subject in any of the activities covered by the Pharmaceutical Industry Code of Good Practices (“PHARMA INDUSTRY Code”).
▪ Medical visit and management of promotional activities, to provide you with information on the products and services offered by CASEN RECORDATI, S.L., and on any other projects in which CASEN RECORDATI, S.L. participates and which, related to our common sphere of activity, we believe may be of interest to you, by post, email, telephone, or any other electronic or physical means, provided that the data subject has given prior authorisation.
How long will we store your data for?
CASEN RECORDATI, S.L. will store the data subject’s data for as long as there is a mutual interest to maintain the purpose or purposes of the data processing. When it is no longer necessary for such purposes, the data will be removed with appropriate security measures to ensure the pseudonymisation of the data or their total destruction.
In the specific case of publication of transfers of value, the data subject’s data will be stored for a minimum of 5 years from the end of each period, and the information to be published -to comply with the transparency obligation-, for a minimum of 3 years from the date of publication of said information, which will be carried out during the six-month period following the applicable period, complying with the provisions of the PHARMA INDUSTRY Code, unless a shorter period is legally established in either case.
What is the legitimacy for processing your data?
The legal basis for processing your data is:
▪ Performance of a contract: For the fulfilment of the contract or the provision of the services requested, as well as for, in general, management of the professional relationship with the data subject and to keep a detailed record of communications with said data subject.
▪ Legitimate interest of CASEN RECORDATI, S.L.: To comply with the PHARMA INDUSTRY Code, in everything related to publication of transfers of value to healthcare professionals, in accordance with the considerations made by the Spanish Data Protection Agency (AEPD) in its Report 43318/2016 dated 22 April 2016.
▪ Consent of the data subject: For medical visits and management of promotional activities.
Automated decisions based on profiling will not be made.
Which companies need to know my personal data?
▪ The companies of the RECORDATI group, a list of which can be viewed on the website: www.recordati.com/en/pharmaceutical_operations/markets
▪ The service provider companies of the RECORDATI group, which will in any case process the data for the same purposes as CASEN RECORDATI, S.L.
There will be no international transfers of data to third countries outside the European Union or to countries that do not guarantee an adequate level of protection in accordance with the regulations in force.
Why do these companies need my personal data?
To manage the performance of the contract with the data subject; events with scientific content; billing thereof; keeping in contact with the data subject, as well as the professional relationship with the data subject. In addition, the management and publication of transfers of value by CASEN RECORDATI S.L., for its collaboration in scientific and professional meetings, or the provision of services (fees and related expenses, including accommodation and transport) for subsequent individual publication, in compliance with the PHARMA INDUSTRY Code.
Companies providing services to CASEN RECORDATI, S.L. that participate in any of the activities described herein will do so in any case as data processors on behalf of CASEN RECORDATI, S.L.
Where will personal data related to transfers of value be published?
The personal data of the data subject relating to transfers of value will be published individually and cumulatively for each category, as shown in the table below, on the company’s website:
What data does the information related to transfers of value contain?
▪ Professional address
▪ First name, last name
▪ National ID Document
Who will be able to know my personal data related to transfers of value?
In accordance with the PHARMA INDUSTRY Code, your data will be published on the website of CASEN RECORDATI, S.L. (casenrecordati.com) and will be freely accessible to the public, complying with the current transparency standards of the Pharmaceutical Industry.
What are your rights when you provide us with your data?
Any person has the right to obtain confirmation as to whether CASEN RECORDATI, S.L. is processing their personal data.
The data subjects have the right to access their personal data and to request the rectification of inaccurate data or, where appropriate, to request their erasure when, among other things, the data are no longer necessary for the purposes for which they were collected.
In certain circumstances, data subjects may request a restriction on the processing of their data, in which case they will only be kept for the exercise or defence of claims.
In certain circumstances and on grounds relating to their particular situation, data subjects may object to the processing of their data. In this case, CASEN RECORDATI, S.L. will stop processing the data, except for compelling legitimate reasons, or the exercise or defence of possible claims.
You may materially exercise your rights by writing to the data controller's address (CASEN RECORDATI, S.L.), Autovía de Logroño, km 13, 300 C.P. 50180 Utebo-Zaragoza or by sending an e-mail to: firstname.lastname@example.org, stating the right to be exercised.
If you have given your consent for a specific purpose, you have the right to withdraw the consent given at any time, without this affecting the legality of the processing based on the consent prior to withdrawal, or for other purposes consent for which, if any, you have not withdrawn.
If you feel that your rights have been breached with regard to protection of your personal data, especially when you have not satisfactorily exercised your rights, you may file a complaint with the Spanish Data Protection Agency through its website: www.agpd.es.
HOW DID WE OBTAIN YOUR DATA?
The personal data we process at CASEN RECORDATI, S.L. comes either directly from the data subject concerned, or from the company IQVIA (formerly IMS Health) located at C/ Juan Esplandiu, 11 - 6º C.P. 28007 as a provider of the ONE KEY platform, which contains a database of healthcare professionals worldwide, and which pharmaceutical companies use to manage the different activities and legitimate services contracted with healthcare professionals in different medical specialities.
The categories of data being processed are:
▪ Identifying data
▪ Contact details
▪ Data relating to the professional activity
▪ Financial data
No special categories of personal data are processed (i.e. data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data aimed at uniquely identifying a natural person, health data or data relating to the sex life or sexual orientation of a natural person).