DATA PRIVACY NOTICE AND PERSONAL DATA CONSENT FORM
Sanofi shall protect all personal information you provide in compliance with the Data Privacy Act of 2012 and its implementing rules and regulations (“Data Privacy Laws”). Sanofi shall not collect, disclose or process any such personal information unless you voluntarily choose to provide us with it, or give your consent, or unless such disclosure is required by applicable laws and regulations.
By contacting us, you confirm that you freely and voluntarily give consent to the collection and processing of your personal information, which may include personal information and/or sensitive personal information (hereafter the “Data”) set out in this form and/or otherwise provided by you or possessed by Sanofi.
Sanofi shall keep the Data for a period of ten (10) years for record purposes, among others. Sanofi shall take appropriate and commercially reasonable technical and organizational measures to ensure the required data security to protect the Data against unauthorized disclosure, access or processing. Sanofi shall require its affiliates, subsidiaries and third parties who process the Data to similarly comply with the requirements of the Data Privacy Laws.
You understand that you are given rights under the Data Privacy Laws, including the right to: object to the processing of your data, access your data, correct any inaccurate data, and erasure or blocking of your data. For more information on these rights, and for requests to exercise your rights under the Data Privacy Laws, please contact Sanofi through +632-8859-5555 or firstname.lastname@example.org.
By contacting us, your personal information will be collected and processed by Sanofi, and you further agree and consent to its transfer, processing, use and disclosure as further stated in the terms and conditions which shall be considered an integral part of this form.
TERMS & CONDITIONS
Sanofi (sanofi-aventis Philippines Inc. and/or Sanofi Pasteur, Inc.) has caused, and will continue to cause in the future, the set-up, development, or use of validation, analytics, CRM, data repository, data input, MD profiling, activity management, digital marketing, data processing and reporting tools, and other processing systems which may contain your personal information and other data. Specifically, the data collected and processed by Sanofi, as well as its associated/affiliated companies, business partners or third parties described below, includes: (a) Profile Information (i.e., name, gender, contact details, signature); (b) Professional Information (i.e., specialty, PTR no., PRC no., clinic location, clinic schedule, affiliations/ societies, professional experience, no. of patients, TIN no., etc.); (c) Activity Information (activity data on website, email, webcasting, and other digital tools, face-to-face calls, event attendance, marketing activities, etc.); and (d) financial information for purposes of determining the manner of payment of future honoraria (including relevant bank account details, identification of the branch, and images of your ATM card, bank passbook, or checkbook, as the case may be, to validate and authenticate the financial information to ensure payment of honoraria in the correct bank account). It is understood that the above described (d) shall only apply to MDs who may be engaged as speakers, moderators, module developers, or otherwise be engaged by the Company for other such similar services.
Sanofi collects and thereafter processes personal data either through its employees or third parties. Third parties may be other entities and individuals performing services on our behalf (i.e., Home Health Care, Inc., MailChimp, Milk Communications, etc.), or our business partners which include, but are not limited to, Medport, MDC, IQVIA - IMS Health and Quintiles, Xcellen, MDI, RX Labuyo, Oncocare, Complete Solutions, Gapan Drug. Such third parties may also include data analysis firms, customer service and support providers, vendors of multi channels, web hosting and program development companies and other entities which are or will be engaged by Sanofi. These third parties may be provided with access to personal information needed to perform their functions, but they may not use such information other than on our behalf and subject to contracts that protect the confidentiality of the information.
Apart from information directly collected from you or your representatives, Sanofi may merge the same with other information which may have been previously collected from you, online or offline, as well as your personal information which Sanofi received and will receive from other sources, including publicly available information sources (i.e., social media profiles, directories, signages, etc.), and other third parties as mentioned above. You agree that publicly available Information may be regularly updated by Sanofi in its tools and systems.
PURPOSES OF COLLECTION AND PROCESSING
The purpose of collecting these data is to support and facilitate interactions between you and Sanofi and thus to best serve our shared interests. Sanofi collects, processes and uses personal information only as necessary for the purposes for which it was obtained. Sanofi may use your personal information for some or all of the following purposes:
Validation of Information: For validation, checking, analytics and cross-validation of information received by Sanofi from the one or combination of the tools, to ensure completeness and integrity of data, and compliance with the relevant laws and rules. This shall include the subsequent submission of your information as part of the regular re-validation of Medical Doctors (MDs) who conduct activities and engagements for Sanofi.
Operations: For profiling and segmentation of MDs relevant to business operations, formulation of company strategy, and planning of activities.
Performance Management and Monitoring: For use in measuring resource allocation efficiency, performance management and monitoring, analysis on MD engagements and activities, analysis of trade activities, evaluating and assessing company and sales force performance, sales force incentive computation, and overall review of the status of the business and operations of Sanofi.
Reporting to Internal and External Parties: For reporting as required by local regulating agencies in connection with events, or as may be necessary or required.
Promotions and Information Cascade: For informing doctors of scientific research, articles and activities devoted to modern scientific developments, new techniques in the field of pharmacology and medicine, including those organized by Sanofi, about the goods produced by the Sanofi Group of Companies, through direct contact with doctors through communication facilities or channels doctors have subscribed to.
Other purposes: For providing you with the necessary service, including responses to your inquiries, complaints and general feedback about our products and Sanofi as a whole. Our service may be provided through various forms of communication, including via email, letter, telephone and other channels you agree to be reached, data analytics and communications, and all other purposes or cases of communication you approve or otherwise permitted by the relevant laws and rules.
Sanofi stores your information in secure operating environments, databases, and tools (locally or in servers located overseas), which are only accessible to authorized Sanofi employees, agents and third parties. Sanofi undertakes to observe generally accepted industry standards and practices in the storage of your personal information.
USAGE AND PROCESSING
By providing us with your information, signing the form, and/or agreeing to these terms and conditions, you confirm that you voluntarily consent to the processing of your information which is received by Sanofi or is in its possession, or is otherwise publicly available. Processing of your personal information may include, but not be limited to, the collection, recording, organization, storage, updating or modification, sharing, retrieval, consultation, use consolidation, blocking, erasure or destruction of your data.
Sanofi shall retain your Personal Information for a period of ten (10) years for record purposes and historical analysis, and for as long as it is necessary for the above-mentioned purposes. This shall likewise take into account the need for Sanofi to comply with legal requirements under applicable laws and rules.
For record keeping purposes, some or all of your Personal Information in Sanofi’s possession may be retained by the ITS departments of Sanofi or its associated companies, including the ITS departments of its business partners and third parties mentioned above (i.e., IQVIA Australia, Xcellen Singapore, etc.).
After the period of ten (10) years, or when the personal information collected from you is no longer required, Sanofi, or its regional ITS department or its associated companies shall destroy, delete or dispose of the same in a secure manner, following generally accepted industry standards and practices.
DISCLOSURE / SHARING / ACCESS
Sanofi will treat these data confidentially and use it for appropriate professional purposes only. Sanofi shall not share your personal information with any third party intending to use the same for direct marketing purposes, unless you have provided specific consent in relation to this. You agree that Sanofi may share your personal information with the following third parties (whether located in the country or abroad) for other purposes: (a) Sanofi associated or affiliated companies for legitimate business purposes; (b) business partners, service providers, agents or contractors acting on Sanofi’s behalf, as mentioned in this document, in the process of providing their services to Sanofi. Sanofi shall endeavor to cause such third parties to comply with the relevant Data Privacy Laws in the course of its engagement with Sanofi and require such company to use and protect your personal information consistent with this document; or (c) others, either in compliance with law, when required by a government entity or regulator, or in the event of transfer of business of Sanofi. Sanofi may likewise disclose aggregate or anonymized data derived from personal information (but without identifiers that will disclose your identity) to third parties.
EXERCISE OF RIGHTS AND CONTACT INFORMATION
Under the Data Privacy Act of 2012, you have the right to the access, correct/rectify, erase, and object to the processing of your personal information. Should you wish to exercise any of such rights, including the withdrawal of your consent, or any other rights in the applicable Data Privacy Laws, you may send the request to email@example.com.
LEGAL AND/OR PRIVACY NOTICES
Sanofi may update from time to time its Legal and/or Privacy Notices, including this Terms & Conditions. Changes to the same will be effective immediately upon updating of the same in the Sanofi website (http://www.sanofi.ph/) or in Campus Sanofi Philippines. Without prejudice to your rights under applicable laws and rules, Sanofi reserves its right to amend the Legal and/or Privacy Notices without prior notice to reflect technological advancements, legal and regulatory changes and good business practices. In the event there will be changes to Sanofi’s privacy practice, an updated version of the Legal and/or Privacy Notices will reflect the same and you will be notified of the changes by updating the effective date at the top of the relevant page. We encourage you to periodically review Sanofi’s website and these Terms and Conditions for the latest information on our privacy practices, and how this will affect the processing or use of your personal information.
Sanofi is committed to fully comply with the Data Protection Act and its implementing rules and regulations, as well as future amendments thereof, and therefore seeks your consent for Sanofi to collect, process and use your personal information for the purposes described in this document. By ticking on the checkbox or agreeing to the consent form, you hereby voluntarily agree that you have given consent to the collection and processing of your personal information by Sanofi, as outlined in the consent form and in these terms and conditions.
For your reference, the systems or tools that are currently being used by Sanofi are CRM platforms (e.g. Veeva, MI Touch, Centrix), Data Management Tools (e.g. Qlikview, XPower Tool, BEAMS or Budget, Expense, Activity Management System & Sales@Net, Campus Sanofi Philippines, eRep, Email Marketing.