Privacy notice for healthcare professionals

Berlin-Chemie/A. Menarini Suomi Oy
Customer and Cooperation Partner Register Privacy notice

1 Register Controller

Berlin-Chemie/A. Menarini Suomi Oy, Hitsaajankatu 24, 00810 Helsinki, Finland

Later in the privacy notice reference to Register Controller is made as “Menarini”.

2 Contact person for issues relating to registers

Ari Heinonen, aheinonen@berlin-chemie.com

3 Name of Register

Menarini Finland Customer and Cooperation Partner Register.

4 Purpose and grounds for processing of personal data

4.1 Grounds for processing

The processing of personal data is based on one or more of the following grounds:

(i) Customer relationship between Menarini and the registered person or their employer/sponsor or equivalent other relationship or appropriate connection, and the associated legitimate interest of Menarini. Such legitimate interests include various measures associated with maintaining and developing the relationship, as well as marketing and communication activities;

(ii) contractual relationship between Menarini and the registered person or their employer;

(iii) obligations of Menarini based on legislation and authority regulations, such as the obligation to notify health care professionals about issues relating to the safety of a medicine, to ensure the marketing and distribution of medicines to appropriate parties; and

(iv) consent given by the registered person.

4.2 Purposes of processing

The purposes of processing of personal data are associated with Menarini’s business, its analysis and its promotion. Such processing measures include, for example, various activities associated with marketing, and cooperation related to lecturing and training. In addition, the processing of personal data ensures that the obligations set for Menarini in legislation and associated authority regulations, regarding Menarini’s obligation to ensure that the person receiving a medicine sample is authorised to prescribe such medication, and that the marketing of the medicine is only targeted to persons authorised to prescribe and supply medicines. The processing of personal data also takes into account the Pharma Industry Finland Code of Ethics.

Personal data may be processed for, for example, the following purposes:

Maintenance, realisation, development and follow-up of customer and cooperation relationship, customer service and associated communication.
The distribution of Menarini’s products and training, communication and marketing associated with the products.
Mailing of e-mail newsletter and customer notification.
Analysis, grouping and reporting of customer and cooperation relationships as well as other purposes associated with the follow-up and development of Menarini’s business.
Collection and analysis of feedback and satisfaction information.
Realisation of market research and opinion polls.
Identification of person receiving a medicine or medicine sample.
Calculation and payment of remunerations and travel costs.

Part of the processing of personal data is based on a contractual relationship between Menarini and the registered person or their employer, in which case the purpose of processing of personal data is the appropriate realisation of this contractual relationship.

Personal data may also be processed for the development and making available of different contents and services. Such situations of processing personal data include, for example, training services and platforms offered by Menarini, and associated processing of personal data as well as processing of personal data of website visitors. Additional information about the processing of personal data concerning the website is available at https://www.berlin-chemie.fi/en-us/Privacy .

Processing tasks may be outsourced to Menarini's group companies and/or external service providers in accordance with data protection legislation and within limits imposed by it.

5 Information content of the register

5.1 Groups of registered persons

In the register, information will be saved about health care professionals and other persons functioning within health care and pharmacology with whom Menarini cooperates with regard to Menarini product-related training, marketing and sales.

In addition, in the register, information will be saved about health care professionals who have received medicine samples, as well as doctors who have prescribed or may prescribe Menarini’s medicines to patients (among others the pharmacovigilance obligations).

In the register, information may also be saved about other clients and cooperation partners of Menarini, such as parties to whom Menarini markets products or for whom they organise product-related trainings or other encounters.

The register also contains information about the users of Menarini's training services, as well as visitors to their website.

5.2 Information groups

Information which may be saved about registered persons include, for example:

Identification data of the registered persons, such as name, date of birth, social security number and (in case the registered person is a doctor) the physician's identification number.
The registered persons’ contact details, such as address, e-mail address and phone number.
The registered person's qualification, specialty field and office data, position in the organisation, as well as other information about the job description, and job-related and professional interests.
Information about what type of patients the registered is in contact with (note! No identification information about patients, Pharmacovigilance obligations).
Information about cooperation between a health care professional or other registered person and Menarini, such as lectures given by a professional person, travels, meetings and events associated with the cooperation, as well as information about compensations and remunerations paid by Menarini to the registered persons.
Information about medicine samples and other products supplied by Menarini and received by the registered person.
Information about the registered person’s participation in encounters, trainings and other events organised by Menarini.
Contents produced by the registered persons themselves, such as information about the contents of encounters organised by Menarini, various feedbacks as well as additional information provided by the registered person themself, such as wishes regarding cooperation, satisfaction information, interests and other similar information.
Information about using the services and website, such as information about sites visited and their contents.
Information about completed trainings and their contents.
Prohibitions, restrictions, consents and other choices made by the registered person.
Information about processing of data, such as date of saving and source of information.

Public sources, such as internet pages.

6 Storage period of personal data

When determining the storage period of personal data, Menarini takes into account the obligations deriving from legislation and subsequent authority regulations, as well as the necessity of the stored personal data with regard to the purposes of use indicated in section 4 of this privacy notice. The data being up-to-date is made sure by regular updates, where outdated data is removed from the register.

7 Regular data sources

Data is primarily obtained from the following sources:

The registered person themself, or events related to communication and doing business between the registered person and Menarini.
The employer and sponsor of the registered person.
FIMNET and aPureBase registers as well as other reliable registers provided by third parties, such as various marketing registers.
Other cooperation partners of Menarini.
Public sources, such as internet pages.

Public sources, such as internet pages.

8 Regular data disclosures and data transfers outside of the European Union and European Economic Area

Data is disclosed to Menarini’s group companies for purposes described in section 4 of this privacy notice, and possibly to Menarini’s other personal data registers, but nevertheless always in accordance with the data protection legislation and within limits set by it.

Information about trainings are disclosed to that party (usually the employer or sponsor of the registered person) with whom the agreement about training or use of a training platform has been made.

In principle, data is not disclosed outside Menarini, its group companies or parties functioning on behalf of Menarini for production, development or maintenance of services and communication, other than in accordance with an agreement, separate consent and/or specific regulations.

We also use external data processing service providers who support us in the implementation of our marketing measures (e.g. in the operation of our websites, the clearing of address and contact data and the sending of invitations and newsletters). These service providers process data only in accordance with the instructions and under the control of Menarini and exclusively for the purposes described in this data protection information. For the processing of your data we also use service providers located in third countries outside the EEA area (e.g. by using the e-mail service "G Suite" of Google Ireland).

If your data is transferred to countries outside the EEA region, we ensure an appropriate level of data protection through appropriate guarantees, such as the so-called standard data protection clauses provided by the EU Commission, an EU adequacy resolution or the so-called EU-US Privacy Shield. You can request a copy of the standard data protection clauses or other relevant warranty(s) at the contact details below (section 13).

9 Description of the principles of register protection

Any possible manual material is stored in a locked space with access only for persons having specific right of access. Digital material may only be accessed with the personal user name and password of a legitimate employee or service partner. There are different levels of access rights, and sufficient, but as restricted as possible, access rights with regard to attending to the task are assigned to each user.

10 Profiling

As part of processing the personal data saved in the register, Menarini may also utilise the data for profiling purposes. Profiling is done by creating an identifier for each registered person by which various information about the registered person created during the cooperation or use of services can be combined. After this, the profile created as described above can, for example, be compared with profiles created of other registered persons.

The purpose of profiling is to clarify the demand for Menarini’s products and services, and to analyse the cooperation between Menarini and the registered person, as well as more broadly, Menarini’s business and its focus points. However, profiling does not include such automatic decision making that would have juridical or similar effects on the registered persons.

11 The registered person’s right to object the handling of personal data and direct marketing (Right to opt out)

The registered person has, in association with a specific personal situation, the right to object the profiling of themself and other processing which Menarini targets on the registered person's personal data regarding processing which is based on the customer relationship between Menarini and the registered person, or other similar pertinent connection. The registered person may present their claim regarding objection in accordance with section 12 of this privacy notice. In connection with the claim, the registered person must specify the specific situation based on which they object the processing.

Where so called cookies are used for the processing and collection of information, the registered person may exercise their right of opting out by changing the settings of their browser. However, disabling cookies may cause problems in the browsing and utilisation of websites provided by Menarini, and their contents, as well as in the use of services offered over the net, or may altogether prevent their use.

The registered person may agree to or opt out of Menarini's direct marketing per channel.

12 Other rights of the registered person related to the processing of personal data

12.1 The registered person’s right to access data (right of inspection)

The registered person has the right to inspect what information about them has been stored. The request for inspection shall be made in accordance with section 13 of this Privacy notice.

12.2 The registered person’s right to request rectification, erasure or restriction of processing of data

If the registered person becomes aware or notices that their personal data saved in the register is inaccurate, unnecessary, incomplete or outdated, the registered person should on their own accord request Menarini to rectify, remove or complete such data in accordance with section 13 of this privacy notice.

The registered person also has the right to request the register controller to limit the processing of their personal data, for example, in a situation where the registered person is waiting for a response from Menarini to a request for rectification or removal of their data.

12.3 The registered person’s right to data transfer

The registered person has the right to data transfer of what information about them has been stored. The request for data transfer shall be made in accordance with section 13 of this Privacy notice.

12.4 Other rights

Where personal data is processed on the basis of the registered person's consent, the registered person has, at any time, the right to withdraw their consent by notifying Menarini about it in accordance with section 13 of this privacy notice.

12.5 Realisation of requests

In principle, the request for review described in section 12.1 and provision of a copy, as well as the realisation of the registered person's other rights as described in sections 11 and 12 are free-of-charge. However, Menarini may charge a reasonable fee for the realisation of these requests, based on administrative costs, if the registered person repeatedly requests copies or the requests are apparently unjustified or unreasonable, or refuse to realise the request on similar or other legal grounds.

If necessary, Menarini may ask the registered person to clarify their request in writing and, if necessary, the registered person’s identity may be verified before undertaking other measures.

13 Contact types

The data subject should contact Menarini about all questions about the processing of personal data and in all situations associated with exercising their own rights. The data subject may exercise their rights by contacting Menarini by sending an e-mail message to dpo.finland@berlin-chemie.com

or by sending mail to Berlin-Chemie/A. Menarini Suomi Oy, Data Protection, Hitsaajankatu 24, 00810 Helsinki, Finland.

14 Data subject's right to lodge a complaint to a supervisory authority

A data subject has the right to lodge a complaint to the competent supervisory authority if the controller has not followed the applicable legislation on data protection in their operations ( www.tietosuoja.fi ).

Privacy notice 22.9.2021