Healthcare Professional (HCP) Privacy Notice
Healthcare Professionals who engage with Otsuka
This Privacy Notice (“Notice”) for Health Care Professionals (“HCPs or you”), including individuals within a Health Care Organisation who could influence in any way the administration, consumption, prescription, purchase, recommendation, sale, supply or use of any medicine but who is not a health professional (“Other External Decision Makers”), describes what types of personal data we collect about you, how we process it and provides you with information about your rights under data protection laws. Your personal data will be processed according to applicable legislation, including the EU or UK General Data Protection Regulation (“GDPR”) and other local laws applicable to the processing of personal data. You should read this Notice and any other Notices that we provide to you.
The controller of your personal data is Otsuka Pharmaceutical (U.K) Ltd., 2 Windsor Dials, Arthur Road, Windsor, SL4 1RS, United Kingdom which is registered with the Information Commissioner’s Office with registration number Z9662792 (“Otsuka”, "we", “,us” or “our”). We have appointed a data protection officer who can be contacted at Otsuka Pharmaceutical (U.K) Ltd., 2 Windsor Dials, Arthur Road, Windsor, SL4 1RS or by submitting your query
In this Notice, when we talk about personal data, we mean any information that relates to an identified or identifiable person – in this case, you.
We may process personal data about you from a variety of sources. As a rule, we collect and process personal data that you disclose to Otsuka and that we otherwise collect in the context of our business relationship and other interactions between you and Otsuka (e.g. documents or forms that you provide in order to participate in Otsuka sponsored or supported initiatives, such as advisory boards, congresses, consultancies, clinical research or development activities, or in other contexts).
We also collect and process personal data from third party sources, including publicly available sources (e.g. publications, speaker engagements and educational background such as CVs and resumes, and online or other databases and websites), public or private registries, data providers of your business data (e.g. name, title, expertise and speciality, medical licence, business contact details such as address, telephone number and email address), joint marketing partners or partners in joint scientific projects, or service providers (e.g. medical communication agencies).
Otsuka may process some or all of the following categories of personal data for the purpose(s) described in this Notice:
- Personal details, such as your name, age, gender and contact details (private address, telephone number, email address);
- Professional details, such as your place of practice, job title, position, place of work, medical licence, the medical field in which you are active, your professional qualifications and scientific activities (such as previous clinical trial experience), and participation in past or pending research studies with Otsuka or other companies, publication of academic or scientific research and articles, and membership of relevant associations and boards;
- Financial and banking information that you provide to us to pay for your services and to reimburse you for fees, travel expenses, accommodation and expenses;
- ID and/or passport number, tax identification number; and
- Details of interactions with us, such as what kind of meetings we have held, topics discussed, your knowledge of and questions you have had on our business and products, what kind of material we have displayed to you and any feedback that you have provided, as well as your opinions and routines on prescribing, routines regarding patient diagnosis, and similar information (provided that this information regarding patients is aggregated or anonymised and does not relate to individual patients). In some circumstances, it will also be necessary to collect your signature;
We process the personal data listed above for the following purposes and on the following legal bases, which may vary depending on where you live and where we operate:
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Purpose |
Legal Basis |
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Managing our relationship with you, including planning our (potential) collaboration, arranging visits, meetings, other activities, such as training activities (in-person and virtual) and events, and to communicate with you (i.e. answering your inquiries, and contacting you for any such purpose). This includes the processing of your personal data in our customer relationship management system. In particular to build a profile about you and better understand and adapt our content and formats of the communications with you to make them more efficient and adapted to your needs and preferences as well as to present you products and offers tailored to your expertise, interests and preferences. In order to address you in a more targeted manner, we also may enrich/combine your personal data with additional data – including from third parties. The purpose described herein may also be supported by artificial intelligence. Otsuka will not make any decisions about your profile based solely on automated processing and will ensure appropriate safeguards are maintained, in order to preserve your rights and interests. |
Management of our contractual relationship in the cases where we have a contract or you have requested that we consider executing one with you (Art. 6 (1) b) GDPR). In some cases this processing (e. g. the use of automated processing) is conditional on you having provided your prior consent (Art. 6 (1) a) GDPR). We have a legitimate interest in developing our business and relationship with you (Art. 6 (1) f) GDPR). |
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Ensuring that, to the extent allowed under applicable legal and regulatory provisions, we provide you with marketing and promotional communications on scientific/health matters by engaging with you in person, sending you materials, by digital means (e.g. through our HCP website) or otherwise, which may be personalized to your expertise, interests and preferences. |
In some cases, for example receiving information relating to promotional and/or non-promotional materials according to therapeutic areas through electronic means, this processing is conditional on you having provided your prior consent (Art. 6 (1) a) GDPR). We have a legitimate interest in managing our business efficiently in the case we have engaged with you in the past (Art. 6 (1) f) GDPR). |
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For collaborations and conducting business and market research and surveys, to better understand Otsuka products, services and business activities, disease or therapeutic areas and generally improve our understanding of the pharmaceutical landscape. We further process personal data to partner with other organisations including private or public alliances, institutions, regional/local discussions, life science industry groups and associations to improve our products and the general delivery of healthcare. |
This processing may be conditional on you having provided your prior consent (Art. 6 (1) a) GDPR). We have a legitimate interest to better understand our products and the area we both operate in, and to ensure the quality and safety of our products (Art. 6 (1) f) GDPR). |
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To internally and externally implement and provide training courses, and in the context of Otsuka events and congresses in order to enable you to participate (i.e. invitation, managing travel arrangements, accommodation), be part of interviews, panel discussions and act as a speaker or an ambassador. In this respect, Otsuka also uses media content to promote, educate and comply with public health, diseases and awareness, and on Otsuka websites, social media or on documentation to support such activities. |
Management of our contractual relationship in the cases where we have a contract or you have requested that we consider executing one with you (Art. 6 (1) b) GDPR). Otsuka has a legitimate (business) interest to conduct such trainings and events (Art. 6 (1) f) GDPR). This processing may be conditional on you having provided your prior consent (Art. 6 (1) a) GDPR). |
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Enforcing our contractual terms and fulfilling our contractual relationship with you, including the completion of any required due diligence (such as anti-bribery, corruption checks or verifying your eligibility to use certain products, offers, services and information that may only be made available to approved healthcare professionals, or other background checks, to ensure that we are not prohibited from working with you), processing contracts, organising travel, facilitating the payment (of fees and expenses, where relevant), and documenting our interactions with you. |
Management of our contractual relationship in the cases where we have a contract or you have requested that we consider executing one with you (Art. 6 (1) b) GDPR). This processing may be necessary for compliance with a legal obligation (Art. 6 (1) c) GDPR). Otsuka has a legitimate (business) interest for collaborating with trusted partners (Art. 6 (1) f) GDPR). |
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Complying with transparency obligations as a member of EFPIA, in particular the EFPIA code on disclosures of transfers of value and/or any applicable national disclosure codes. |
In some cases, for example, where this is prescribed by national disclosure codes, this processing is conditional on you having provided your prior consent (Art. 6 (1) a) GDPR). |
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Complying with applicable (local) laws, our regulatory monitoring and reporting obligations, including those related to adverse events, product complaints and patient safety. Processing data as a result of documentation and notification obligations or in the public interest, in particular notifications regarding pharmacovigilance monitoring activities, incidents, or other post-market surveillance obligations. In some cases, Otsuka may be required to send you specific communications related to these topics. |
Compliance with a legal obligation (Art. 6 (1) c) and Art. 9 (2) i) GDPR). Performance of a task carried out in the public interest (Art. 6 (1) e) GDPR). Otsuka has a legitimate interest to process personal data to respond to inquiries and to comply with documentation and record-keeping obligations (Art. 6 (1) f) GDPR and Art. 9 (2) i) GDPR). |
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To investigate and defend us against potential or actual legal claims. |
In some cases and some jurisdictions this processing is conditional on you having provided your prior consent (Art. 6 (1) a) GDPR). We have a legitimate interest in protecting our or third-party rights (Art. 6 (1) f) GDPR). |
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Otsuka also might process personal data to prepare, complete and implement any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of the business, assets or stock (including in connection with any bankruptcy or similar proceedings). |
In some cases and some jurisdictions this processing is conditional on you having provided your prior consent (Art. 6 (1) a) GDPR). We have a legitimate business interest in supporting such activities (Art. 6 (1) f) GDPR). |
Moreover, Otsuka may also offer mobile apps, provide access to websites, special programs, activities, events or promotions or may sponsor clinical trials or post authorisation safety studies (“Initiatives”) that may have unique or additional specific terms, Notices and/or consent forms that explain how any information you provide will be processed in connection with the Initiatives.
Where we have entered into an agreement with you, or where we have a legal and/or regulatory reporting obligation, the provision of your personal data is mandatory. If your personal data is not provided we cannot interact with you.
We disclose your personal data to the following categories of recipients:
- to our group companies and affiliates for purposes provided in this Notice. This may include the Otsuka headquarters and all of its current and future subsidiaries, branch offices, affiliates, entities and other companies that are part of, owned or controlled by, Otsuka. When sharing data internally, we implement appropriate arrangements and mechanisms to cover any transfer of your personal data within our corporate structure;
- to third party suppliers, vendors and services providers who provide data processing services to us, or who otherwise process personal information for purposes that are described in this Notice or notified to you when we collect your personal data, especially for the purpose of outsourcing specific business activities and to request external support and resources: IT services (infrastructure, system management and maintenance, system security and improvement, development, testing and technical support), database and software service providers, web analytics service providers, advertising/marketing service providers and sales services, healthcare service providers (e.g. medial communication agencies), market research services, clinical trials and studies support, to include HCPs in Otsuka’s surveys or other scientific opportunities to obtain insight about HCPs’ experience with Otsuka’s products or services and/or disease areas, talent acquisition, auditors, consultants and law firms/lawyers, and third party service providers engaged directly or indirectly in the organization of events of Otsuka, such as event agencies, hotels, transportation companies (airlines, trains, etc.), event planning and organizers, other media service providers that support Otsuka in arranging virtual or live events;
- to business partners (distributors, external partners, alliance partners and other members of the healthcare and pharmaceutical industry) to review and assist with healthcare compliance activities and institutions and other organisations with whom Otsuka collaborates to support clinical or commercial activities (clinical studies, post authorisation safety studies and patient support programs, etc.);
- to any competent law enforcement body, competent medical supervisory authorities, regulatory, trade association, government agency, court or other third parties where we believe disclosure is necessary (i) as a matter of applicable law or regulation [(i.e. disclosure reporting)], court order or government request, (ii) to exercise, establish or defend our legal rights (on the basis of our interest in the defence of our rights), or (iii) to protect your vital interests or those of any other person;
- to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Notice (on the legal basis of our legitimate interest in ensuring the business operation);
- to any other person with your consent to the disclosure.
These recipients of your personal data may be acting on our behalf, as joint controllers with us or as data controllers in their own right.
We have implemented privacy and security measures, technologies and use appropriate technical and organisational measures to protect the personal data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the categories of personal data processed. In addition, we put in place data protection, privacy and security policies and guidelines intending to ensure the security of your personal data. When interacting with partners, service providers and third parties, we make sure they comply with data protection and privacy laws and obligations agreed and promised on in the data processing and data sharing agreements.
We may transfer your personal data to other Otsuka group companies, service providers and partners located outside of the United Kingdom (“UK”), European Union (“EU”) and the European Economic Area (“EEA”), for example in the USA or Japan. Please note that some countries outside of the UK/EU/EEA may not provide the same level of protection for your personal data as within the UK/EU/EEA. Where we transfer your personal data outside of the UK/EU/EEA to such countries, we ensure that appropriate safeguards are put in place and that all transfers of your personal data comply with applicable data protection laws.
The appropriate safeguards that Otsuka uses are based on the model clauses approved by the Information Commissioner’s Office and the European Commission. You can request a copy of such safeguard and find out more about how we safeguard your information in relation to data transfers outside the UK/EU/EEA, using the contact details in the ‘How to contact us?’ section below.
We retain and process personal data we collect about you only for as long as necessary and permitted by the data processing purposes, especially where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal data, we will either delete, or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will isolate it from any further processing until deletion is possible.
Depending on the jurisdiction of processing and under consideration of local laws, Otsuka will retain your personal data for the duration of any active, legal and/or contractual relationship, for the retention time specified in your consent, until you withdraw your consent1, or you object to the processing under certain circumstances. Beyond that, we will retain your personal data until both the periods for which (i) the applicable laws (e.g. commercial and tax laws) require the data to be kept and (ii) the statutes of limitation of any actions for which such data or the documents containing them may be relevant, have elapsed, i.e. until the end of any legal or litigation hold for official/legal proceedings (e.g. the enforcement of applicable statutes of limitation, litigation or regulatory investigations, to establish, exercise, or defend a claim).
1 Withdrawal of consent does not affect the lawfulness of the processing we have carried out prior to withdrawal.
You have a number of rights, which apply to our use of your personal data. The availability of these rights depends upon our lawful basis for processing your personal data and your rights may also be subject to certain conditions and restrictions. These rights are:
- Right to withdraw consent
- Right to information
- Right of access
- Right to rectification
- Right to erasure (also ‘right to be forgotten’)
- Right to restriction of data processing
- Right to data portability
- Right to object
To exercise these rights (for more information, please visit https://privacy.otsuka.co.uk/data-subject-rights please contact us as indicated below (‘How to contact us?’).
Under the GDPR, you also have the right to complain to a data protection authority about our collection and use of personal data. For more information, please contact your local data protection authority. A list of data protection authorities in the European Economic Area is available here
Should you have any questions in regards to the protection of your personal data, the respective roles and relationships of the joint controllers towards you or if you wish to exercise your legal rights, submit your query
Last Updated: May 2025