The privacy and security of your personal information is very important to the ABPI. This policy explains how and why the ABPI uses your personal data and explains your privacy rights under data protection law. For the purposes of data protection law, the ABPI is the “data controller”.
Links to Other Websites, Plug-Ins and Applications
This website may include links to third party websites, plug-ins and applications. Clicking on those links, enabling those communications may allow third parties to collect or share data about you. We do not control those third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website that you visit.
Other Policies that May Apply to You
If you are an HCP that has participated in Disclosure UK, please see the Disclosure page on www.abpi.org.uk for more information about how the ABPI processes your personal data.
This privacy notice supplements the other notices and is not intended to override them.
Who Are We?
In this policy when you see the words, “we”, “us, “our” or “ABPI”, it refers to the Association of the British Pharmaceutical Industry (“ABPI”).
The ABPI represents innovative research based biopharmaceutical companies, large, medium and small in the UK.
The ABPI is a company limited by guarantee with registration number 09826787 and its registered office at 7th Floor Southside, 105 Victoria Street, London SW1E 6QT.
What is Personal Data & Purpose of this Notice
In this policy the words, “personal data” means any information that identifies you, for example, your name, address, telephone number, email address.
What Personal Data Does the ABPI Collect?
The ABPI will collect, use, store and transfer the following different kinds of personal data about you:
- Your full name, including your title;
- Your employment status and history;
- Your contact information, including telephone number, email address and postal address;
- Photographs and CCTV images;
- Date of birth;
- Attitudes, opinions, feedback, survey responses;
- Communication preferences;
- Technical information, including the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, as well as browser plug-in type and versions, operating system and platform and if you access our website via your mobile;
- information about your visit, including but not limited to the clicks used to navigate to, through and from our website (including date and time), items that you viewed or searched for, page response times, download errors, length of visit to certain pages, page interaction information (such as but not limited to scrolling, clicks and mouse-overs), methods used to browse away from the page, any phone number used to contact us;
- The terms that you use to search our website.
How is Your Personal Data Collected?
Your personal data is collected in a number of different ways including when:
- You give us your personal data by:
- Completing the Get In Touch form on our website:
- Participating in any of our expert networks, working groups or other groups convened by the ABPI;
- Subscribing to receive newsletters and updates;
- Corresponding with us (in any form).
- We receive personal data about you from third parties and public sources, including public websites, as well as paid for subscription services.
How We Use Your Personal Data
Your personal data will be saved in the ABPI’s contacts database and may be viewed by ABPI employees, contractors and representatives.
We will only use your personal data on relevant lawful grounds as set out in the Data Protection Act 2018, such as for performance of a contract with you, to comply with our legal obligations, where you have given us your consent and in pursuit of our legitimate interests. We explain how we rely on these lawful grounds below.
The ABPI does not sell your personal data and we only share it with the organisations that we work with when necessary.
The main uses of your personal data are set out below, as well as the legal basis that we rely on for this processing.
We would like to use your details to keep in touch about things that matter to you and your company.
If you choose to hear from us, we may send you information about activities that may be of interest to you. This might be about our work, government or industry initiatives, events, membership or other matters.
We will only send these to you if you agree to receive them. If you choose to receive this information, you can change your mind at any time. In all communications you will be provided with a link to unsubscribe from all communications.
If you choose not to receive these communications, you may not hear about events or other work that we do that may be of interest to you.
When we send you email communications we use technology that enables us to track who opens particular emails This helps us to understand which issues are of most interest and helps us to ensure that you continue to receive useful information.
The ABPI uses a third party provider, Dotmailer, to deliver our newsletters. For more information, please see Dotmailer’s Privacy Notice available here: https://www.dotmailer.com/terms/privacy-policy/
When we send marketing communications to you, we rely on your consent to do so.
Research and Surveys
The ABPI is regularly contacted by members of our expert network groups and by third parties in the healthcare sector to assist them with obtaining feedback on technical questions as well as different initiatives and projects.
When we contact you for this purpose, we use your identity and contact information. We consider that using your personal data for this purpose is necessary for our legitimate interests for the purpose of providing services to our members and to allow us to serve the wider purpose of facilitating collaboration within the healthcare environment and the exchange of industry knowledge, best practice, and understanding.
To Register You as a Representative of a Member Company
If you are the nominated representative of your company we will use your identity, career and contact information in order to contact you in relation to your company’s membership of the ABPI. We consider that using your personal data for this purpose is necessary for our legitimate interests in order that we can operate the ABPI’s membership and our relationship with your company effectively.
To Engage with You as Part of an Expert Network, For a Particular Project or For the ABPI’s Strategic Objectives
If you decide to participate in any expert network or working group that is convened by the ABPI we will use your identity, career and contact information as well as attitudes, feedback and opinions for the purpose of engaging with you and for exchanging information with you about the network or group’s activities. We consider that using your personal data for this purpose is necessary for our legitimate interests in order that we can engage with you for the purpose of gathering expert analysis in relation to project and activities and to deliver content that is relevant to your organisation.
We will use your identity and career and contact information to meet our strategic objectives. We consider that this is necessary for our legitimate interests in order to manage relationships and effective communication with government, healthcare professionals, patients and the general public.
To Engage with the You if You Are a Member of the Media
The ABPI uses contact information in order to contact members of the media to initiate and respond to stories relating to the pharmaceutical industry. We consider that this is necessary for our legitimate interests in order that we can efficiently meet our objectives as a trade association representing the pharmaceutical industry in the media.
When You Visit the ABPI Office
If you visit the ABPI office, please be aware that CCTV is in operation at our office door and in the reception area. This is necessary for our legitimate interests for security of our premises and our personnel.
To Respond To A Question Raised Through www.abpi.org.uk
When you contact the ABPI using the Get In Touch form on www.abpi.org.uk, your contact information will be retained by the ABPI. We consider that this is necessary for our legitimate interests in order that we can communicate with you in relation to the matter raised by you and track our response to you.
To Manage Our Relationship With You as a Supplier
We will use your identity and contact information for the purpose of performance of the contract between your company and the ABPI.
Disclosures of Your Personal Data
If asked by any police, regulatory or government authority we may need to provide your personal data to these agencies in order to comply with our legal obligations and to pursue our legitimate interests in engaging with and responding to governmental, regulatory and public bodies.
Other than set out in this Privacy Notice and any other notice that may be delivered to you, the ABPI does not sell or transfer personal data to third parties.
We do not transfer your personal data outside of the European Economic Area.
The ABPI has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents and contractors and representatives who have a business need to know it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and the relevant regulatory authority of a breach where we are legally required to do so.
For How Long Will Your Personal Data be Retained?
The ABPI will only retain your personal data for so long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
Details of retention periods for different aspects of your personal data are available in the ABPI’s retention policy and you can request this from us by contacting us using the Get in Touch form available on the ABPI’s website: www.abpi.org.uk
Your Legal Rights
Under certain circumstances, you have the rights set out below under data protection laws in relation to your personal data:
- Access to Personal Information – You have a right to obtain access to the personal information that we hold about you.
- Change Inaccurate Information – You have a right to ask us to correct inaccurate personal information and to update incomplete personal information.
- Request to Delete Your Information – You have a right to request that we delete your personal information if you believe that we no longer need your information for the purposes for which it was provided; or we are not using your information in a lawful manner; or we have requested your permission to process your personal information and you wish to withdraw your consent. Please note that if you request us to delete your information, we may have to stop engaging with you.
- Request to Restrict the Processing of Your Information – You have a right to request that we restrict the processing of your personal data if you believe that any of the information that we hold about you is inaccurate; we no longer need your information for the purposes for which it was provided but you require the information to establish, exercise or defend legal claims; or we are not using your information in a lawful manner. Please note that if you request us to stop or restrict the processing of your information, we may have to stop engaging with you.
- Request Your Personal Data in a Portable Format – You may have the right to ask us to provide your personal information in a portable format.
- Object to the Processing of your Personal Information – You have a right to object to the processing of your personal information unless we can demonstrate compelling and legitimate grounds for the processing. Please note that if you object to the processing of your information, we may have to stop engaging with you.
- Object to Direct Marketing – You have a right to object to use of your personal information for direct marketing purposes.
- Withdraw Consent – Where we rely on your permission to process your personal information, you have a right to withdraw your consent at any time. Please note that if you withdraw your consent, we may have to stop engaging with you.
- To Complain - You have the right to make a complaint at any time to the Information Commissioner’s Office, the UK regulatory authority responsible for data protection issues. If you are based outside the UK, you can contact your national regulator. We would appreciate the opportunity to resolve any concerns before you approach the Information Commissioner (or your local regulator if outside the UK) and therefore, wherever possible, we request that you contact the ABPI in the first instance.
We may need 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). We may also contact you to ask you for further information in relation to your request.
We will try to respond to your request within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case we will provide you with updates.
Last Updated: 17 July 2018.