Information for Healthcare Professionals
LFB BIOMEDICAMENTS takes its legal obligations relating to the processing of personal data very seriously and implements various actions to ensure the protection of your data and respect for your privacy.
In this context, LFB BIOMEDICAMENTS undertakes to provide clear and concise information to any person concerned, in particular health professionals, on the processing of their data.
The purpose of this notice is therefore to inform you, in complete transparency, of the way in which your personal data is processed by LFB BIOMEDICAMENTS in the context of its promotional information activity by canvassing or prospecting, as well as in the context of the logistical management of events and compliance with our legal obligations in terms of transparency of links and DMOS.
Purposes
Your personal data is processed by LFB BIOMEDICAMENTS for the following purposes:
Purpose 1: management, follow-up and traceability of invitations to events (symposiums, conferences, congresses, webinars, etc.)
Purpose 2: management of communication campaigns (commercial, institutional, medical) related to our activity. These actions may take the form of emailing campaigns.
Purpose 3: non-automated profiling based on information strictly related to your professional activity. This profiling will make it possible to offer you communications or invitations to events relevant to your activity.
Purpose 4: managing the activity (medical and commercial) of LFB BIOMEDICAMENTS employees with whom you are in contact. For example, we may keep a record of your interactions with MSLs (Medical Science Liaison).
Purpose 5: Hospitality management, logistics and event organisation (excluding invitations).
Purpose 6: the management and monitoring of information activity by canvassing or prospecting aimed at promoting medicinal products in compliance with the Charter and the Certification Standards for promotional information activity established by the French National Authority for Health (HAS).
Purpose 7: Compliance with our legal obligations in terms of transparency of links and the Law on the Restriction of Advantages (LEA).
Legal basis
Depending on the purpose of the data processing, there are different legal bases:
- Purposes 1 to 4: LFB BIOMEDICAMENTS has a legitimate interest in processing your personal data. In particular, these are economic interests or interests linked to the organisation and development of the business pursued by LFB BIOMEDICAMENTS but also to ensure and guarantee compliance with high quality and safety standards for medicinal products and medical devices.
The legitimate interests pursued by LFB BIOMEDICAMENTS are balanced against your interests, freedoms and fundamental rights, which require your personal data to be protected. LFB BIOMEDICAMENTS' interests cannot take precedence over yours.
- Purpose 5: We process your data for this purpose in order to execute the hospitality agreement between you and LFB BIOMEDICAMENTS.
- Purposes 6 and 7: compliance with legal obligations relating to :
Transparency of links and the law governing advantages (LEA),
The charter and certification reference framework for information activity by canvassing or prospecting for the promotion of medicinal products.
Types and sources of data processed
As part of the processing operations described above, we may process the following categories of data:
Your identification data (surname, first name, title)
Your contact details (e.g. practice address, email address, telephone number)
Your professional data (e.g. speciality, RPPS number, OneKey identification code, publications, professional background and environment)
Your data related to interactions with LFB BIOMEDICAMENTS (example: participation in events organised by LFB BIOMEDICAMENTS, trace of interactions with LFB BIOMEDICAMENTS employees, answers given to questions asked [medical questions]).
Your data (identity, title, function, medical speciality, OneKey identification code and RPPS number, professional background and environment, professional contact details) may be collected directly from you (when we are in direct contact with you), from specialised service providers providing, among other things, access to databases of healthcare professionals and in particular IQVIA (specialised service provider for this purpose and providing the "OneKey" database), via professional associations or hospitals, or from sources accessible to the public such as the shared directory of healthcare professionals (RPPS), the healthcare directory and websites, in particular those of healthcare establishments and national professional associations.
Retention periods
Your data (identity, title, function, medical speciality, OneKey identification code and RPPS number, professional background and environment, professional contact details) are kept for the period during which you carry out your professional activity.
Data relating to the history of interactions between you and LFB BIOMEDICAMENTS is kept for a period of 3 years following the last contact with our laboratory. It may then be archived for a further 10 years.
Your targeting data is kept for a maximum of 3 years from the last contact with LFB.
When the processing of your personal data meets a legal obligation, we keep your data for the time necessary to meet this obligation. Thus, as part of the management of the transparency of links of interest and the management of the anti-gift system, your data is kept for 10 years on the LFB BIOMEDICAMENTS database. Please note that this data is also kept for 5 years on the public database.
Data relating to hospitality agreements are kept for a period of 10 years.
Recipients and transfers outside the EU
Your data is accessible to the relevant LFB BIOMEDICAMENTS departments and may be shared with the following entities and service providers.
Other processing
Other data processing operations may be implemented by LFB BIOMEDICAMENTS in addition to those described above.
Your data may be processed for pharmacovigilance management purposes (if you report an adverse reaction), for medical information purposes (if you ask a medical information question), for monitoring the correct use of our medicinal products (if you report use outside the MA), etc.
Specific information will be provided for each data processing operation.
This information leaflet may be updated regularly. We invite you to consult it regularly on the LFB BIOMEDICAMENTS website.
Contact
LFB BIOMEDICAMENTS (data controller) 3 avenue des Tropiques, BP 40305, 91958 Courtabœuf Cedex- France
Data Protection Officer :
Postal address: LFB BIOMEDICAMENTS - Direction des Affaires juridiques et Conformité - Délégué à la protection des données (DPO) 3 avenue des Tropiques, BP 40305, 91958 Courtabœuf Cedex - France
Email : Privacy@lfb.fr
Purpose
Management and monitoring of information activity by canvassing or prospecting for the promotion of medicinal products.
Providers
IQVIA
EURIS
The healthcare establishment in which you carry out your activity if the latter so requests or if this provision is included in the visiting rules imposed by the management of your establishment.
In addition, your data may be accessible to other recipients acting as subcontractors on behalf of LFB BIOMEDICAMENTS (to the extent necessary to carry out the work entrusted to them).
In the event that Personal Data is entrusted to a subcontractor, an agreement will be concluded with the latter in order to ensure and guarantee that Personal Data is processed in accordance with LFB BIOMEDICAMENTS' instructions and that adequate technical and organisational measures are taken to protect it.
Your personal data is processed in the European Union.
However, depending on the project, certain data may be transferred to countries outside the European Union. We transfer your data to countries with a level of protection that is adequate to that provided within the European Union.
Where we transfer your data to countries that do not offer a level of protection equivalent to that provided within the European Union, we put in place appropriate technical and legal safeguards to protect your data against unauthorised access, use or disclosure.
Your rights
Within the limits and conditions laid down by law, you have the right to access, rectify and delete your data, the right to limit processing and the right to object to processing.
You may freely accept or refuse interactions with LFB BIOMEDICAMENTS in the context of prospecting and canvassing (for example, you may refuse medical visits from LFB BIOMEDICAMENTS' ASHs). In particular, you may ask to be removed from our "prospects" database and/or the "OneKey" database dedicated to LFB BIOMEDICAMENTS managed by IQVIA, without having to justify yourself.
However, when you accept promotional information actions from LFB BIOMEDICAMENTS, the processing operations that come under a legal obligation of LFB BIOMEDICAMENTS in accordance with the Charter and the Promotional Certification Standards (e.g. planning and traceability of interactions between you and LFB BIOMEDICAMENTS, processing operations relating to the transparency of links or the anti-gift law) may not be the subject of a request for deletion or opposition.
Furthermore, where processing is based on the performance of a contract, you do not have the right to object.
You may also request clarification of the balance between the legitimate interests pursued by LFB BIOMEDICAMENTS and your own.
You may exercise your rights by contacting our Data Protection Officer (DPO) at the following address: privacy@lfb.fr or LFB BIOMEDICAMENTS - Direction des Affaires Juridiques - DPO - 3 avenue des Tropiques, BP 40305, 91958 Courtaboeuf Cedex.
You may, at any time, lodge a complaint with a supervisory authority, in particular in the Member State in which you habitually reside, your place of work or the place where you consider that a breach of the regulations has occurred (the CNIL in France, for example).