Kowa Research Europe Limited and Kowa Pharmaceutical Europe Co. Ltd., (the ‘Companies’) Privacy Notice
This notice explains how information about you is used.
The Companies will be data controllers and can be contacted as follows:
By post: Data Protection Officer, Kowa Research Europe Limited, 105 Wharfedale Road, Winnersh Triangle, Wokingham, Berkshire, RG41 5RB.
By e-mail: firstname.lastname@example.org
By phone: +44 (0) 118 922 9003
The information we gather
The Companies gather certain information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and the Data Protection Act 2018 and we are responsible for that personal information for the purposes of those laws. Information about you is also used by our affiliated entities and group companies, including Kowa Company Limited, Kowa Pharmaceutical Europe AG, Kowa Holdings Europe AG, Kowa Pharmaceutical Europe Co. Ltd. German Branch and Kowa Pharmaceutical Europe GmbH (our ‘group companies’).
In this notice, references to ‘we’ or ‘us’ means the Companies and our group companies.
Information that we gather about you may include without limitation your name and contact details.
The provision of information by you is entirely voluntary and will only be used in accordance with our data protection policies.
We may also obtain information about you from third parties, such as our group companies, service providers and agents.
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
The legal basis for processing
Processing will take normally take place based on our legitimate interests. This is where we are carrying on or may carry on business with your employer. There is a limited privacy impact on you, and we think that you will expect that we will process your data in this way.
If you have entrusted us with any medical information about you, the processing will take place based on your informed consent. Where you have given consent to any data processing, you have the right to withdraw that consent at any time.
Processing may also take place where it is required for the performance of a contract between us.
Information about third parties
Information we process as described in this notice may also include information about third parties whose details you supply to us.
Systems used to process data
We gather information directly from you and also via our websites and other technical systems. These may include, for example, our:
• computer networks and connections
• communications systems
• email and instant messaging systems
• intranet and Internet facilities
• telephones, voicemail, mobile phone records
When you use our websites we may gather information about you through Internet access logs, cookies and other technical means. ‘Cookies’ are text files placed on your computer to collect Internet log information and user behaviour information. These are used to track website usage and monitor website activity and for other data processing reasons set out below.
Presently, we only use a functional cookie on our websites. This cookie is essential for parts of the website to operate as it is used to determine the language used by the website visitor to ensure appropriate content is provided. You may delete and block all cookies from the website, but this feature will not then work.
Reasons for processing
We process information about you for the following reasons:
• to provide our services and pharmaceutical work
• compliance with legal, regulatory and corporate governance obligations and good practice
• gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests
• ensuring business policies are adhered to
• operational reasons, such as recording transactions, training and quality control
• ensuring the confidentiality of commercially sensitive information
• security vetting, investigating claims, complaints and allegations of criminal offences
• statistical analysis
• preventing unauthorised access and modifications to systems
• marketing our business and those of our group
• analysing purchasing preferences and improving services
• providing customer services
Disclosures and exchange of information and transfers outside the EEA
We may disclose and exchange information with our group companies, credit reference agencies, service providers, representatives and agents, as well as with law enforcement agencies and regulatory bodies for the above reasons.
Information may be held at our offices and those of our group companies, service providers, representatives and agents as described above. Information may be transferred internationally to Japan and other countries around the world, including those without data protection laws equivalent to those in the UK, for the reasons described above. We have security measures in place to seek to ensure that there is appropriate security for information we hold including those measures detailed in our information security and data protection policies, which are available on request. International data transfers outside the European Economic Area are protected by Standard Contractual Clauses, as per GDPR Article 46(2).
If you would like further information please contact our Data Protection Officer (see above). We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Your data will be held in accordance with the Companies’ retention policy, which is available on request. There are a wide range of retention periods that may be relevant to you, but we will not retain data that is not accurate, relevant, up to date and actively useful to us.
You have a number of important rights, which can be exercised free of charge. You have the right to request:
• access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
• require us to correct any mistakes in your information which we hold
• require the erasure of personal information concerning you in certain situations
• receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• object at any time to processing of personal information concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• object in certain other situations to our continued processing of your personal information
• otherwise restrict our processing of your personal information in certain circumstances.
Where you have given consent to any data processing, you have the right to withdraw that consent at any time. We will not do anything with your data not outlined in this notice.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation. You can contact the Information Commissioner at ico.org.uk/concerns/ or by telephone: +44 (0) 303 123 1113 for further information about your rights and how to make a formal complaint.
If you would like to exercise any of these rights, please contact our Data Protection Officer in writing (see above), providing enough information to identify you and let us know which information to which your request relates.
If you are not satisfied with any complaint you have with us, you also have the right to make a complaint to the Information Commissioners Office, which is the supervising authority in the UK in relation to data processing.
We may change this privacy notice from time to time. The latest version will always be available on our websites.