Thank you for contacting Ferring Pharmaceuticals Ltd. We are committed to the right to privacy and data protection. This Privacy Notice will describe how Ferring Pharmaceuticals Ltd may collect, hold and process your personal data, and the ways in which we will ensure your privacy is respected and your data is protected, in accordance with applicable European and local national data protection laws. This Privacy Notice is only applicable to Safety Information, including adverse events and product quality complaints.
Maintaining the security of your data is a priority at Ferring Pharmaceuticals Ltd, and we are committed to respecting your privacy rights. We pledge to handle your data fairly and legally at all times. Ferring Pharmaceuticals Ltd is also dedicated to being transparent about what data we collect about you and how we use it.
This ‘notice’ provides you with information about:
- How we use your data
- What personal information we collect and where we store the data
- Data collected by third party
- How we ensure your privacy is maintained
- Your legal rights relating to your personal data
- Modification of Privacy Notice Related to Safety Information
- Contact information
HOW WE USE YOUR DATA
We use your data to meet regulatory requirements and improve drug safety, and in particular for the following reasons:
– To enable Ferring Pharmaceuticals Ltd, to collect, process and retain safety information from you; and
– Where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).
WHAT PERSONAL INFORMATION WE COLLECT AND WHERE DO WE STORE DATA
- We collect the following information for Pharmacovigilance: Reporter Name and Job Title or relationship to the patient
- Reporter contact details which may include postal address, Email Address and/or telephone number
- Patient initials, gender, date of birth or age
- Safety information, which includes the adverse event or product quality complaint, or both related to the anonymised patient
- Medical history of the anonymised patient
- Medicinal product name, batch number, expiry date
The reporter name, job title, relationship to patient and contact details are personal information and are not sent to Ferring Global PV, but retained in the UK internal secured server and securely stored on paper in our head office with only access to the compliance team. We send only anonymised patient information, safety information, medical history information and medicinal product information to Ferring Global PV in Denmark to process. The processed information is sent to the MHRA, as per regulatory requirements for Pharmacovigilance.
We collect the following personal information for Product Quality Complaints:
- Reporter Name and Job Title or relationship to the patient
- Reporter contact details, which may include postal address, Email Address and/or telephone number
We archive all the information in our internal secured server to meet regulatory requirements under Good Pharmacovigilance Practice and Good Distribution Practice for drug safety. All the data relating to Pharmacovigilance are retained indefinitely. All the data relating to product quality complaints only are retained for at least 6 years and deleted within 20 years.
We do not expect a child to report safety information and therefore do not hold name or contact details for children.
Safety information may relate to a patient who is a child however patient data is anonymised and the patient would not be able to be identified.
We do not use the Safety Information provided for any other purpose.
Data collection by third party
We use a specialist medical information third party to handle medical enquiries, which may include the report of safety information. All safety information is passed to Ferring Pharmaceuticals Ltd.
How we ensure your privacy is maintained
All the data collected are stored within the Ferring Group servers in the Economic European Area. Safety Information which includes an adverse event is retained indefinitely under regulatory requirements. Safety Information which does not include an adverse event will be retained for at least 6 years and deleted within 20 years.
Your legal rights relating to your personal data
– Right to access and rectification: You have the right to request a copy of the information we hold about you, as well as the right to request corrections, if the data is incorrect. We may require you to provide proper identification before we comply with any request to access or correct Personal Data.
– Right to erasure and restriction of processing: For legal reasons, we cannot delete information that has been collected and processed as part of an adverse event report unless it is inaccurate. However, you may have the right to restrict the processing of your personal data, if, for example, you believe the data is incorrect.
– Right to data portability: You have the right to request that we transfer the personal data we hold about you to another party, except if this cannot be permitted for reasons of public interest.
– Right to object: As the data collected as part of an adverse event report is processed for reasons of public health and interest, you cannot object to the data being used.
– If you wish to exercise any of the above rights, please contact us using the contact details set out below.
All enquiries should be made to the Global Privacy Office at firstname.lastname@example.org
The data subject has the right to contact or lodge a complaint with the supervisory authority and our Global Privacy Office via email at email@example.com
Modification of Privacy Notice
Any changes to this Privacy Notice will be communicated on the Ferring Pharmaceuticals Ltd website www.ferring.co.uk. We recommend you consult our Privacy Notice periodically to review any changes and to keep informed about our ongoing commitment to respecting the right to privacy and to providing the highest possible level of data protection.
All enquiries for your legal rights in regards to your personal data should be made to the Global Privacy Office at firstname.lastname@example.org.
Any other enquiries with regards to this Privacy Notice please contact Ferring Pharmaceuticals Ltd via the address or email email@example.com.
UK-RMMH-2000016 Date of preparation: May 2020