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This privacy notice is intended for healthcare professionals and other experts with whom AstraZeneca wish to collaborate with or who already work with AstraZeneca.

As a leading pharmaceutical company, we understand and respect that privacy matters to you. This respect is core to all our values and we are committed to protect and treat your personal data fairly, lawfully and with care. The global digital landscape is continually evolving and the personal data that organisations hold about us are broader and more complex than in the past. In light of this and in compliance with various privacy regulations across the world, we would like to take the opportunity to explain to you what personal information we collect about you, the way in which we use your personal data, how we keep it safe, what your rights are and how you may exercise them.

This privacy notice has been developed with the aim to meet the requirements of privacy laws and data protection legislations throughout the world and being in line with AstraZeneca’s Data Privacy Standard it aims to explain our general approach and practices. However, if a country has different regulatory requirements that oblige AstraZeneca to not process or process personal data in a different manner, then we will always abide by the local law.

Personal data means any information or piece of information which could identify you either directly (e.g. your name) or indirectly (e.g. a unique ID number).

AstraZeneca (“We”, “Us”, “Our”) may interact with you in a variety of ways. We may collect and use some or all the following data or categories of data about you depending on the particular purpose for processing your personal data and the lawful basis for it. Where We process your personal data, the local AstraZeneca company that has a relationship with you is considered the controller of your personal data. Local AstraZeneca companies and contact information.

  • Name, surname and title(s) or prefix, gender, age or date of birth, preferred language
  • Professional information and experience, such as information related to your medical specialty, qualifications, skills and areas of expertise, place of practice, professional registration number, and medical certificate number
  • Business contact information that enables Us to contact you, such as your email, mailing address, and telephone numbers
  • Professional biography, such as your CV/resume, photograph, academic information, details about your publishing activities and participation in professional meetings, seminars, advisory boards and conferences, information about public institutions you may be affiliated with, information about your participation in clinical trials and other research studies, and your professional profile on a social media platform
  • Technical information about devices from which you access AstraZeneca websites and other services and network activity information, such as your IP address, device ID, hardware model and version, browser type and version, browsing history, search history, access time, pages viewed, physical location, and other standard server log information and online identifiers
  • Your professional interests such as any specific health care topics you want to discuss with or request from AstraZeneca, topics you may read about on Our websites, social media pages or emails We send you, and your professional opinion about scientific and health-related topics
  • Information about your experience with AstraZeneca and Our products including comments, and/or sentiments, including those you may make on public domains such as social media, regarding your experience with Us and Our medicines
  • Information about your publications, your participation in meetings, seminars, advisory boards and conferences, information about your relationship with other single persons or institutions, information about your participation in clinical trials and non-interventional studies, as well as information about other professional skills and information from publicly available sources.
  • Preferred method of communications with Us and Our services you may use
  • Photographic images, video, and audio recordings from Our virtual or live meetings and events that you attended or similar information made in relation to articles, publications, and trainings where We collaborated with you
  • Financial and travel-related identification information, such as your bank account number, credit/debit card numbers and other financial and compensation details; your national identification number, national insurance number, passport number, driving license number, tax identification number, and travel preferences if We have contracted with you for paid services
  • Other information related to protecting Our interests and meeting Our legal obligations such as confirming no conflicts of interest exist or to verify if you hold a government position or if you are a candidate for public office, checking publicly accessible information for confirmation that you have not been involved in any activity against the law; ensuring safety of Our products and to manage security, risk and prevent crime

You are free to decide not to provide Us personal data when We ask you to provide it. However, if you choose not to give Us your personal data, it may limit or preclude Us from a relationship with you such as not being able to provide the services you requested or fulfilling a contract for services We have with you.

 

We may collect your personal data through several processes.

  • Data you provide to or share with Us in your interactions with Us such as when you:
    • Get in touch with Us for support or to provide feedback
    • Reply to Our surveys in which you choose to participate
    • Share adverse events or medical information enquiries with Us; in the event you report an adverse event related to an AstraZeneca product, please review the adverse event reporting notice for your relevant country, to get further information on how We process your personal data
    • Share or use your social media profile to contact AstraZeneca
  • Data we collect when you use Our services such as when you:
    • Create an account or profile on or use an AstraZeneca platform or website, app, or system
    • Register to receive promotional materials from Us
    • Attend an AstraZeneca online event such as a virtual meeting, conference, webcast, or seminar
    • Attend live meetings, such as advisory boards, congresses, or conferences
  • Data that is derived from Our cooperation with you such as:
    • Your visits and engagement with one of Our representatives such as sales representatives, medical science liaisons, and other roles that may interact with you or our call centres
    • Your interest in Our email campaigns including email open rate metrics
  • Data we collect from other sources (where permitted by applicable law) such as:
    • Public sources such as official registers, hospital websites, healthcare provider directories and social media
    • Joint marketing partners or partners in joint scientific projects
    • Third parties providing services on Our behalf
    • Third parties providing information services in the healthcare sector to companies like Ours
    • Patient organizations
    • Professional social media platforms
    • Public social media platforms when you share opinions about AstraZeneca or mention an AstraZeneca product in a comment

We may use your data for the following purposes or for purposes reasonably compatible with the ones listed in this notice such as to:

  • Provide you Our services and products
  • Deliver medical samples to you
  • Provide you with information about Our products, news, and the latest scientific developments, when We respond to your queries or when We believe Our products and services may be of interest to you. If We intend to share electronic marketing with you, We will ask for your consent, where required, and you can opt out at any time.
  • Send you invitations or offers to participate in scientific meetings, events, and surveys and obtain insight about your experience with Our products or services and/or disease areas and activities and the effectiveness of Our information channels
  • Identify and maintain information about healthcare professionals working in disease areas of interest to Us and who are considered to be key opinion leaders in their medical specialty with whom We may wish to collaborate on scientific initiatives such as clinical trials, advisory boards, and educational activities
  • Contact the identified healthcare professionals and other experts with whom We may wish to engage in scientific collaboration such as clinical trials, advisory boards, and educational activities
  • Evaluate and classify your scientific expertise and skills to improve Our visits to you and understand Our possibilities of scientific collaboration with you based on
    • Public sources such as publications and conferences
    • Your prior and future engagements with Us
    • Your interest in Our products and content

Under certain circumstances, you may have a right to oppose (object to) such processing

  • Combine data about you from various sources, including the information you provide to Us and personal data, which is collected during your relationship with Us. This data may come directly from you or from other parties, including from your usage of Our websites and applications and is used to perform data analyses, market research and segmentation in order to understand your preferences, personalize your experience when interacting with Us, improve the content and functionality of Our products and services and websites, and identify which products, services, and offers may be relevant for you or of interest to you, or identify Our possibilities for collaboration with you,
  • Coordinate visits to you by Our representatives such as sales representatives, medical science liaisons, or other roles that interact with you.
  • Report the adverse events you notify Us about
  • Meet regulatory and industry requirements relating to healthcare professionals, keep records related to Our relationship with healthcare professionals and manage security, risk and prevent crime.
  • Ensure the safety of Our products by investigating incidents and taking action against illegal or harmful behavior related to Our products security and by assisting law enforcement and regulatory bodies
  • Protect yours or another individual’s vital interests
  • Perform analytics and produce metrics including those using artificial intelligence or machine learning
  • Manage and maintain Our network and information system security and improve, test or develop new IT systems and applications that We use to conduct and improve Our business operations
  • Provide online services such as virtual events, webcasts, and surveys
  • Manage your account/s on AstraZeneca’s portals, websites or applications, and validate your professional registration
  • Collect feedback, opinions and insights through photographs, voice/video recordings, and statements from you in connection with the services rendered by you to AstraZeneca or in relation to an event held by Us. If an event will be recorded, you will be informed that the recording will take place upon joining the meeting. Our practice is not to publish such recordings externally but if We plan to do so, you will be clearly informed prior to making such recordings. We store and make them available for educational purposes to invited guests and a controlled group of Our employees. You will be provided with an additional privacy notice if your data will be used for other purposes not described herein.
  • Manage Our contractual relationship with you including payment of honoraria and taxes and monitoring such payments for compliance with Our internal procedures relating to engagements with healthcare professionals and experts; management of your travel and accommodation arrangements; submission of records to public authorities under any applicable law; and for Our own internal evaluation and business overview purposes.
  • Comply with openness and transparency principles and legislation that are key for the pharmaceutical industry. These principles and/or provisions of the law aim to increase the understanding about collaborations between pharmaceutical companies and healthcare organizations and its co-workers. As part of this goal, transfers of value, such as consultancy fees from pharmaceutical companies to healthcare professionals and healthcare organizations are publicly disclosed on an annual basis. The information remains publicly available for a limited period; in Europe, the retention period is set to three years calculated from the date on which the information was first published. If under local law or other regulations of the country where you reside in, We need your consent for this purpose and should you disagree with your information being shared individually, We would only publish it in an aggregated manner.
  • Comply with applicable laws and regulations
  • Defend Us against potential or actual legal claims
  • Support activities related to a sale, divestment, collaboration, or joint venture for all or part of Our business
  • Communicate with you in relation to changes to Our policies, terms, and conditions

We will only process your information when one of the following circumstances applies:

  • When We are preparing, initiating, and fulfilling a contract We have with you (e.g. when We pay honoraria or use your travel-related identification information when We have contracted with you for paid services)
  • When it is Our legal duty (e.g. when We are obligated to monitor and report adverse events or comply with anti-corruption and transparency requirements)
  • When it is in the public interest based on applicable laws
  • When We establish, exercise or defend legal claims
  • When We have your consent as required by local law
  • When it is in Our legitimate interest such as to:
    • Improve the consistency and internal awareness of Our external scientific interactions
    • Achieve effective and coordinated engagement with key external experts to maximize Our impact and improve medical practice and drug development
    • Create and maintain a database in order to identify and engage with you based on your professional experience and expertise on various collaborations
    • Send direct marketing materials to you (where you will always have the right to opt-out)
    • Improve Our business processes and activities
    • Design and conduct training
    • Verify your capacity as a healthcare professional in order to grant you access to certain products, services and data that may be provided only to licensed healthcare professionals or to perform additional background checks to ensure We are not precluded from working with you.

Note: When We have a scientific, business or commercial reason of Our own to use your information, this is called ‘legitimate interest’. We will tell you what that is if We are going to rely on it as the reason for using your data and, even then, it must not unfairly go against your interests.

 

You can withdraw your consent at any time for activities where We are required by law to seek your consent for processing your personal information.

Consent is generally sought in the following situations, where and in line with applicable laws:

  • When We send you electronic marketing materials and communications
  • Before We place digital trackers, such as cookies, on your device to find out how you use Our websites and apps. These allow Us to personalize your experience by tailoring content and communications to the things of interest to you.
  • During any other case where We are obliged to request your consent

We have implemented a variety of privacy and security measures and technologies to help protect your personal data and make sure it is not shared with or used by anyone who is not allowed to see it. We have also put in place personal data protection, privacy and security policies which are intended to ensure, as far as reasonably possible, the security and integrity of all Our information, including your personal data.

We have a dedicated process to carefully select the service providers and partners We work with which includes a check that they have technical and organizational security measures in place to protect your personal data and a confirmation that those third parties can comply with the obligations promised in the data processing and sharing agreements We sign with them.

AstraZeneca has developed and implemented robust data transmission and storage systems which aim to ensure an appropriate level of security and protection for personal data. However if you suspect or believe that your interactions with Us are no longer secure, please contact Us as soon as possible; see the Contact information for Data Privacy section.

More information on how AstraZeneca complies with its data privacy obligations can be found in Our Global Privacy Standard.

Your personal information may be shared with:

  • Other AstraZeneca group companies
  • IT providers for the purposes of system management and maintenance, system security and improvement, development, testing and technical support
  • Market research companies to include you in Our surveys or other scientific opportunities to obtain insight about your experience with Our products or services and/or disease areas
  • Advertising companies to serve you ads that may be of interest to you
  • Third party service providers, event agencies, and other media service providers that support AstraZeneca in arranging virtual or live events
  • Healthcare service providers and other pharmaceutical companies who partner with Us in relation to disease areas and other products, participation in scientific events, clinical studies, and advisory bodies, and visit data recorded by sales representatives, medical representatives, or other roles that interact with you
  • Auditors and consultants to verify Our compliance with internal and external requirements
  • Web analytics service providers using cookies to analyze use patterns and information about your use of Our websites. Some of Our websites may use Google Analytics, provided by Google, Inc. (“Google”). More information on Google Analytics. You may choose to opt-out of having your data used by Google Analytics. Further information around how We use cookies and other web analytics services is available below and on each AstraZeneca site you visit.
  • Statutory bodies, law enforcement agencies, legal advisors and litigants when required for a legal reporting requirement or defending or instigation a legal claim
  • A successor or business partner to AstraZeneca or to an AstraZeneca group company in the event that it sells, divests or sets up a collaboration or joint venture for all or part of its business
  • Other third parties providing contracted services on Our behalf

AstraZeneca operates all over the world, therefore, We may need to transfer your personal data outside of the country where We collect it from you. Recipients such as AstraZeneca entities and third parties may be based anywhere in the world, which could include countries that may not offer the same legal protections for personal data as your country of residence. We will follow local data protection requirements and Our global privacy standard as We apply the necessary safeguards under the applicable law of the country transferring the data in such transfers. Irrespective of the country to which your personal data is transferred, We will only share your personal data under a strict “need-to-know” basis and under appropriate contractual restrictions and, where required, additional measures including AstraZeneca’s Binding Corporate Rules and EU Standard Contract Clauses or equivalent instruments approved by the European Commission or by a local Supervisory Authority. You are entitled to receive a copy of AstraZeneca’s Binding Corporate Rules and/or the AstraZeneca’s EU Standard Contract Clauses upon request by contacting AstraZeneca on Privacy@astrazeneca.com. Law enforcement, regulatory and security authorities or courts in the countries We transfer your personal data to may have the right to see your personal data.

We may use cookies and similar tracking technologies on Our websites and apps, and in emails We send to you.

Cookies are small computer files that are sent to your computer, tablet, or mobile phone by websites when you visit them. They stay on your device and get sent back to the website they came from when you go there again. Cookies store information about your visits to that website, such as your choices and other details.

We track emails to help Us improve the communications We send. We use small images called pixels within Our emails to tell Us things like whether you opened the email and how many times and the device you used. We may also set a cookie to find out if you clicked on any links in the email.

If, and to the extent, that your local laws consider the information collected by cookies and other technologies as personal data, We will treat that information to the standards provided within this privacy notice. In several countries We operate in, you may choose to accept of decline cookies as afforded by local data protection and ePrivacy laws and regulations. We provide you with a clear option to consent where applicable and required by law.

To find out more about how We use cookies, please see the cookie notice on the AstraZeneca website you are visiting.

Your data may be processed by manual and automatic means and stored in Our internal database for the number of years as may be legally required in some jurisdictions and in accordance with local laws and Our document retention policies. The data may be stored for as long as it is necessary to satisfy Our legitimate business interests, legal or contractual obligations, the retention time specified in your consent, or in order to establish, exercise, or defend legal claims. If your personal data is no longer needed for these purposes, it will be permanently deleted. For more information on AstraZeneca's internal document retention policy.

It is Our obligation to let you know about the rights you have and how you may exercise them. Generally, your rights will depend on the local law in your jurisdiction and on the lawful basis We rely on for processing your personal data. There could be certain exceptions in relation to both the list of rights available to you and your ability to exercise them.

  • Request information on how We process your personal data
  • Request access to the personal data We hold about you
  • Ask that We correct any mistakes to the personal data We hold about you which you think is inaccurate or incomplete
  • Request Us to delete (erase) your personal data
  • Request information on Our document retention policy
  • Request portability of your personal data
  • Object to Our processing of your personal data, where the law permits this right to you
  • Object to the processing of your personal data for automated decision making

Note: Automated decision making helps Us to make sure Our decisions are quick, fair, efficient and correct, based on what We know about you. They can affect how We interact with you now or in the future, the products and services We offer you or the price that We charge you for them. They are based on personal data that We have or that We are allowed to collect from others.

  • Withdraw consent for any processes that required consent
  • Withdraw consent or object to Us processing your personal data for direct marketing (opt-out of further communication from Us or change your previous choice to receive information about Our products or services)
  • Complain to your local data protection authority. If there is a Supervisory Authority for your country, the relevant Supervisory Authority name and contact details.
  • You may exercise any of the above rights by visiting AstraZeneca Personal Data Retention.

We may ask you to verify your identity before fulfilling your request. We have a duty to ensure that information is retained and, when legally required, disclosed in a secure manner. Therefore, We must be satisfied that you are who you say you are before We respond to any request in order to protect your privacy as well as the privacy of others. You may be required to provide identification documentation to validate your identity and/or authority to act on another's behalf. After they have been checked, any original identification document(s) will be returned, photocopies of identification documents will be destroyed, and any electronic copies will be securely deleted.

If such a request places Us or Our affiliates in breach of its obligations under applicable laws, regulations or codes of practice, then We may not be able to comply with your request, but you may still be able to request that We block or restrict the use of your personal information for further processing. You may also have a right to data portability to another data controller which in general means that you can ask Us to transfer information you have given Us from one company to another, or to give it to you.

AstraZeneca has assigned a Data Protection Officer that is responsible for overseeing Our compliance with data protection laws around the world. You may contact the DPO with questions or concerns regarding the processing of your personal data at Privacy@astrazeneca.com or by mail at: Global Data Protection Officer, AstraZeneca Middlewood Court, Silk Road, Macclesfield, Cheshire, United Kingdom SK10 2NA. See the section titled, Who is the Controller of your Personal Data, to access the link to each AstraZeneca site and contact information.

Reminder, to exercise your rights related to any of the rights in the section titled, Your rights in relation to your personal data and how to exercise them, visit: AstraZeneca Personal Data Retention.

We will review this notice on an annual basis and, if necessary, update this notice at that time or more frequently if there are important changes that require an update. Such changes become effective when We post the revised privacy notice on Our website and the date of last update is identified. We will provide additional notice to make you aware of those changes if We make material changes.

Policy last updated date here. July, 2022.