Privacy – Kyowa Kirin

Privacy notice for healthcare professionals

Please read this Privacy Notice, together with any other privacy notice that we may provide to you, as it contains important information about how we collect, manage, use and protect your personal data. It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “Your rights” section below. 

This Privacy Notice may also be used in conjunction with other privacy notices that we may provide you with in certain situations. We may change this Privacy Notice from time to time. Please check this notice frequently to ensure you are aware of the most recent version and the date that it was last updated. 

This notice was last updated in September 2022. 

Who are we?

Kyowa Kirin International plc is part of the Kyowa Kirin Group. The Group is made up of different legal entities, details of which can be found here and which may be updated from time to time. When we say ‘KKI’, ‘we’ or ‘us’ in this notice, we are referring to the relevant company in the Kyowa Kirin Group responsible for processing your personal data. 

KKI is a “data controller” of the personal data that we hold about you. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. 

What information do we collect?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

We may collect, use, store and transfer different kinds of personal data about you. We have grouped together the types of information that we may collect from you as follows: 

When you register for our newsletters or meetings or if you correspond with us: 

  • Identity and Professional Data including name, date of birth, occupation, place of work, professional registration number, professional background and interests, medical specialisation; 
  • Contact Data including home address, business address, email address, phone numbers; 
  • Proposal Data: including academic qualifications, partnered institutions and all the information you decide to incorporate into your research proposal/idea and the data potentially included into all ancillary documentation (e.g. letters of support). 

 

We may also gather personal data about you and your opinion of KKI, on the basis of publicly accessible social media content you post about KKI and our products and services. 

  • Information we receive about you from other sources. 
    • We may receive information about you if you use any of the other websites we operate or the other services that we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. 
    • We also work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, social listening providers and credit reference agencies) and may receive information about you from them.
    •  

How we might use your information?

We use information held about you in the following ways: 

  • To manage and administer our relationship with you 
  • To carry out our obligations arising from any contracts entered into between you and us, including to ensure compliance with any transfer of value disclosure obligations and be transparent of our financial relationship with you and any payments made by us to you in terms and for the purposes of this program and as further set out in the relevant between us agreement 
  • To respond to your requests 
  • To provide you with information about our activities or tailored information about a programme that you have signed up to, such as the Horizon Programme 
  • To process and evaluate your application to participate in the Horizon Programme 
  • To improve our level of service 
  • To notify you about changes to our service and notify you of new products and services 
  • To seek your views on our products and services 
  • For administrative and quality assurance purposes 
  • For the purposes of the establishment, exercise or defence of legal claims. 
  • To record, investigate and respond to complaints 
  • To understand our stakeholders’ needs and sentiments and market trends, so that we can improve our products and services Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive). 

Communications with you

We may text or e-mail you (depending on the contact details you completed on your application form) to provide you with information about the Horizon Programme. If you have send us any questions or complaints regarding the assessment or the application procedure, we will also use the contact details you provided to respond to your question/feedback.  

We will also communicate with you about future opportunities and about our activities and products if you have consented to such use of your personal data. Please note that you can withdraw your consent for communications regarding future opportunities at any moment without adverse effect to your application. 

What is our legal basis for using your information?

There are a number of lawful reasons for us to process your personal data. 

One of these is called ‘legitimate interest’ and means that we can process your personal data if (i) we have a genuine and legitimate reason; and (ii) are not harming any of your rights and interests. 

Our aim is the development and commercialisation of innovative medicines for the treatment of unmet therapeutic needs. 

We will use your personal data in order to help us achieve those goals and to give you the most appropriate information, products and services and to provide you with the best experience when dealing with us. Whenever we process your personal data for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection law. 

Also, in order to assess your application for the Horizon Programme we will process the data you have provided to us on the legal basis of taking necessary steps prior to entering into a contract with you. 

Other legal bases that we will rely on include the following: 

  • Use of your data for future purposes: When submitting your application, you are given the free choice to consent to the use of your data for future proposals and similar to Horizon programmes. If you agree to such future uses your data will be processed on the basis of your consent and you may withdraw your consent at any time. Where we are required to comply with our legal obligations, or to establish and defend our legal rights, or to prevent and detect crimes such as fraud. 
  • Transfer of value / public disclosure of payments: When having a relationship with you, we will publicize any personal -payment related- details on the legal basis of our legal obligations or our legitimate interests, to adhere to the EFPIA Code, the MedTech Europe Code and other applicable national disclosure codes and laws in order to be transparent and open about all of our interactions. If none of the above applies, we will  rely on the legal basis of your consent in order publicize such details according to the country specific legal framework and best industry practice standards.

 

Information may be used for statistical research but only in a form that does not identify you. 

How long will we hold your information for?

We will hold your personal data on our systems for as long as is necessary to fulfil the purposes that we collected it, namely until the end of the Horizon Programme, including for the purposes of satisfying any legal, accounting, transparency obligations or other reporting requirements. If you have consented to your data being kept for future opportunities, then it will be retained at KKI’s databases for an additional period of 3 years, unless you withdraw your consent or we have established a relationship with you.   

By law, we are required to retain certain information for a prescribed period of time. In circumstances where there are no such legal requirements, to determine the appropriate retention period, we will consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we are processing your personal data and whether we can achieve those purposes through other means. 

Therefore, some information may be kept for more or less time depending on how long we reasonably feel it is required for. 

We review our retention periods for personal data on a regular basis. 

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 

If you ask us to delete your information in accordance with your rights set out below, we will retain basic information on a suppression list to record your request and to avoid sending you unwanted materials in the future. 

Who we might share your information with

We will NOT sell your personal data to any third parties. 

We may share your personal information with any member of our group where we have a legal basis for doing so. 

We may share your information with selected third parties and only to the extent necessary, including: 

  • When we use other companies to provide services on our behalf, e.g. answering questions about products or services, sending mail and emails, assessment and profiling and when using auditors or other professional advisors. 
  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you. 
  • Analytics and search engine providers that assist us in the improvement and optimisation of our site. 
  • IT service providers. 
  • Clinical Research Organisations. 
  • If we run an event in partnership with other named organisations your details may need to be shared. We will be very clear what will happen to your data when you register. 
  • If we merge with another organisation or form a new entity, your personal data may be transferred to that new entity. 

We may disclose your personal information to third parties to: 

  • Comply with any court order or other legal obligation or when data is requested by our regulators or by government agencies or law enforcement agencies or is required by any stock exchange rules where a member of the Kyowa Kirin Group is listed; 
  • Comply with our transfer of value obligations;
  • Enforce or apply our terms of use and any other agreements; 
  • Protect the rights, property, or safety of us, our employees or others. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. 

International transfers of personal data

As KKI is an international enterprise that consists of numerous entities worldwide, the data that we collect from you may be transferred to, and stored at, a destination outside the European Union (“EU”) for the purposes described in this policy, in particular to our parent company Kyowa Kirin in Japan. For a list of the other entities that your personal data may be shared with, please see http://www.kyowa-kirin.com/about_us/worldwide_locations/index.html#pharmaceuticals.  

It may also be processed by staff operating outside the EU who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the processing of your payment details and the provision of support services. 

Data may be transferred to and hosted by a third-party IT service provider in the countries outside of the EU as part of selected ‘Cloud’ services adopted by Kyowa Kirin International for the purposes of carrying out normal business practices. We may also share your data with other selected unaffiliated service providers or consultants acting on our behalf, such as external marketing agencies, speciality advisory services or lawyers. 

If we do this, your personal information will continue to be subject to one or more appropriate safeguards set out in the law, for example we may use model contracts in a form approved by regulators. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. A copy of the relevant mechanism can be provided for your review on request to the contact details below. 

If you fail to provide personal data

Where we need to collect personal data by law or under the terms of a contract we have with your or if you wish to participate in a programme and you fail to provide that data when requested, we may not be able to perform the contract we have with you or permit you to participate in the programme. If this is the case, we will notify you at the time. 

Your rights

You have a number of rights. If you would like to exercise any of these rights, please contact us using the details set out below in the ‘Contact Us’ section. If you exercise any of these rights, we may ask for proof of identity and sufficient information about your interactions with us so that we can locate your personal information. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge except in exceptional circumstances. 

You also have the right to lodge a complaint with the data protection regulator, the Information Commissioner’s Office, if you have concerns about how we use your personal information. You can contact the Information Commissioner’s Office at: https://ico.org.uk/global/contact-us/. 

If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html.   

Your rights include: 

  • transparency over how we use your data and to make a subject access request (right of access); 
  • a right to have your personal data updated and corrected (right of correction/rectification) 
  • a right to ask us to delete your information (right to be forgotten); 
  • a right to ask us to stop processing your information (right to restriction); 
  • a right to object to (i) processing based on our legitimate interests; (ii) processing of your information for direct marketing purposes; and (iii) automated decision making and profiling (right to object); 
  • a right to receive a copy of your information, or have this sent to a third party (right to data portability); and 
  • a right to claim compensation for material or non-material damage caused if we breach the data protection rules (right to compensation). 

 

If you would like to find out more about your rights, you can visit the Information Commissioner’s Office website (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr) or any other EU supervisory authority’s website on the link set out above. 

Contact Us

If you have any questions regarding this policy or about our privacy practices, wish to exercise any of your rights or wish to make a complaint, please contact our Data Protection Officer at: 

  • E-mail: [email protected] 
  • Post: Kyowa Kirin International Ltd, Head Office, Galabank Business Park, Galashiels, TD1 1QH, United Kingdom and marking your query for the attention of The Data Protection Officer 
  • Telephone: +44 1896 664 000