Privacy notice to consultants
The purpose of this privacy notice is to provide information on how Camurus Limited, Reg. No. 10571011, whose registered office is The Officers' Mess Business Centre, Royston Road, Duxford, Cambridgeshire, CB22 4QH (“we”/”Camurus”) processes your personal data in connection with your engagement to perform certain services for Camurus.
We respect your privacy and duly protect the personal data we process about you. All processing of personal data is carried out in accordance with the United Kingdom’s General Data Protection Regulation (the “GDPR”) and the UK Data Protection Act 2018 (together the "Data Protection Laws"). The following describes how we collect, process and share your personal data.
1. What personal data will be processed?
We may collect and process the following personal data about you:
- Contact information (g. name, address, email and telephone number);
- Position with the company you represent;
- Bank account details or other financial information as may be necessary to make payments to you as a consultant or the company you represent;
- Information about your physical location when using our entrance system (g. information regarding entrances and exits to office premises) if you have been provided an access tag to Camurus’ facilities;
- IT-related information (g. possibly stored information concerning data and telephone traffic and information regarding access to IT-systems, log files etc.) if you are provided access to Camurus’ IT system;
If applicable for your engagement to perform services, information (name, position, total remuneration for services) regarding the value of your contract with Camurus; and any other personal data that Camurus needs to process for the purpose of engaging you to perform the agreed services and as may be required for the purpose of Camurus’ compliance with legal obligations and/or industry code.
2. What are the purposes and legal grounds for processing?
- We process your personal data for the purposes listed in the table below. In the table, you may also see the legal basis for processing your personal data.
|Pay invoices for services performed or otherwise compensate you for the consulting services.||The processing of your personal data for this purpose is necessary for the performance of a contract with you or, if you are not a party to the agreement regarding your consulting services, the processing is based on our legitimate interest, as we have a business legitimate interest to make payments for your services. This is of mutual interest and we have conducted a balancing interest test with the result that our legitimate interest overweighs your interest in not having your personal data processed for this purpose. You are always entitled to object to this assessment. You can read further about your rights below.|
|Administrating your access to IT systems and office sites necessary for the conduct of the services.||The processing of your personal data for this purpose is necessary the performance of a contract with you or, if you are not a party to the agreement regarding your consulting services, the processing is based on our legitimate interest as we have a business legitimate interest to engage you as a consultant. This is of mutual interest and we have conducted a balancing interest test with the result that our legitimate interest overweighs your interest in not having your personal data processed for this purpose. You are always entitled to object to this assessment. You can read further about your rights below.|
|Complying with accounting laws and relevant industry regulations.||The processing of your personal data for this purpose is necessary for us to comply with our legal obligation to process certain personal data.|
|To fulfil and comply with our obligations under the Association of the British Pharmaceutical Industry ("ABPI") and the European Federation of Pharmaceutical Industries and Associations' ("EFPIA")|
The processing of your personal data for this purpose is necessary for our legitimate interest as we have a business legitimate interest to adhere to the relevant codes and/or practices in line with the industry standard guidance. This includes the public disclosure of ToVs (Transfers of values), eg. payments to healthcare professionals providing a consultancy service to Camurus, and/ or the payment or re-imbursement of associated expenses (such as travel, accommodation), on an individual (recipient) level, and by including information such as your name, position and principal practice address.
|To fulfil and comply with Camurus’ internal policies and SOPs.||The processing of your personal data for this purpose is based on our legitimate interest, as we have a business legitimate interest to fulfil and comply with Camurus’ internal policies and SOPs. We believe there is a mutual interest in this purpose. Furthermore, the processing is limited and does not affect personal integrity to a large extent. Based on the previously mentioned factors, we have conducted a balancing interest test with the result that our legitimate interest overweighs your interest in not having your personal data processed for this purpose. You are always entitled to object to this assessment. You can read further about your rights below.|
3. Who has access to your personal data?
- We may share your personal data with suppliers, partners and other third parties that carry out services on our behalf such as our IT suppliers, who provide IT systems and tools enabling us to store your personal data in a safe manner. Furthermore, your personal data may be shared with regulatory authorities if required under the Data Protection Laws.
- As a general rule, your personal data will not be transferred to a country outside the UK and/or EEA. However, we may transfer your personal data to a third country, if necessary for us to fulfil the purpose of our processing stated herein. If applicable, when transferring personal data to countries outside the UK and/or EEA, we use standard contractual clauses approved by the European Commission and/or UK Information Commissioner's Office (as applicable) to ensure sufficient levels of protection for your personal data.
In order to adhere to the ABPI and EFPIA codes and/or practice and to ensure transparency in our business operations, we will need to share your personal data with the ABPI.
4. For how long is your personal data stored?
Your personal data will only be stored for as long as the purpose for which it is kept exists and for as long as permitted or required under the Data Protection Laws. The currently required storage time is defined by the year of the ToV transaction, plus additional 5 years.
5. Security measures
We have implemented appropriate technical and organisational measures to protect your personal data against loss, unlawful access, etc. The number of persons with access to your personal data is limited. Only individuals that need to process your personal data in accordance with the purposes above will have access to your personal data.
6. What are your rights?
Camurus Limited, Reg. No. 10571011, whose registered office is The Officers' Mess Business Centre, Royston Road, Duxford, Cambridgeshire, CB22 4QH ("Camurus") is the controller of your personal data. This means that Camurus is responsible for your personal data being processed correctly and in accordance with applicable laws. If you have any questions about this Privacy Notice, how we handle your personal data, or would like to exercise any of your rights, please contact us by e-mail at email@example.com or by post at the address above.
You have the following legal rights in relation to your personal data:
- Right to be informed – You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and what your rights are. This is why we are providing you this Privacy Notice.
- Right of access – You have the right to obtain access to your personal data we process and certain other information (similar to that provided in this Privacy Notice). This is so you are aware and can check that we are using your information in accordance with Data Protection Laws. You may ask for:
- A copy of your information;
- Details of the purpose for which it is being processed;
- Details of the recipients or classes of recipients to whom it is or could be disclosed, including if they are overseas and what protections they have in place;
- The period for which it is held (or the criteria which determines this);
- Any information available about the source of the data; and
- Whether we carry out any automated decision-making or profiling, and where we do information about the logic involved and the outcome or consequences of that decision or profiling.
To help us find the information, please give us as much information as possible about the type of personal data you would like to see.
- Right to rectification – You are entitled to have your information corrected if it is inaccurate or incomplete. If you would like us to do this, please contact us.
- Right to ask us to stop contacting you with direct marketing – You can ask us to stop contacting you for direct marketing purposes. If you would like to do so, please contact us. Alternatively, you can also click the 'unsubscribe' button at the bottom of the email newsletter. It may take up to 7 days for this to take place.
- Rights in relation to automated decision making – Camurus does not make use of automated decision making when processing your data, so this right is not applicable in relation to this privacy notice.
- Right to erasure – This is also known as the 'right to be forgotten' and, in simple terms, enables you to request the deletion or removal of your information where:
- You do not believe that we need your data in order to process it for the purposes set out in this Privacy Notice;
- If you had given us consent to process your data, you withdraw that consent and we cannot otherwise legally process your data;
- You object to our processing and we do not have any legitimate interests that mean we can continue to process your data; or
- Your data has been processed unlawfully or have not been erased when it should have been.
- Right to restrict processing – You have rights to 'block' or suppress further use of your information. When processing is restricted we can still store your information, but may not use it further. You may request that we stop processing your personal data temporarily if:
- You do not think your data is accurate. We will start processing again once we have checked whether or not the data is accurate;
- The processing is unlawful but you do not want to erase your data;
- We no longer need the personal data for our processing, but you need the data to establish, exercise or defend legal claims; or
- You have objected to the processing because you believe that your interests should override the company's legitimate interests.
- Right to data portability – You have rights in certain circumstances to obtain and reuse your personal data for your own purposes across different services.
- Right to object to processing – You have the right to object to certain types of processing, including processing based on our legitimate interests and processing for direct marketing
- Right to withdraw consent – If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, that does not mean anything we have done with your personal data with your consent up to that point is unlawful).
You can exercise these rights free of charge, by contacting firstname.lastname@example.org. We will respond to any rights that you exercise within a month of receiving the request unless the request is particularly complex, in which case we will respond within three months.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response
Please be aware that there are exceptions and exemptions that apply to some of these rights, which we will apply in accordance with the Data Protection Laws.
It is important that you ensure you have read this Privacy Notice. If you do not think that we have processed your data in accordance with this Privacy Notice, you should let us know as soon as possible. You also have the right to complain to the UK Information Commissioner's Office. Information about how to do this is available on its website at www.ico.org.uk.
We regularly review and, where necessary, update our privacy information. If we plan to use personal information for a new purpose, we update our privacy information and will communicate the changes via an update to this supplementary privacy notice and/or to our website privacy notice. Please check our website to ensure you are aware of the most recent version of our website privacy notice.