Last update: 4 March 2021
We (Galapagos NV, “Galapagos”, “we,” or “us”) are committed to ensure the protection of personal data of all individuals who are currently collaborating with us, including Health Care Professionals (“HCPs” or “you”). Your personal data are handled and protected with the utmost care, in accordance with the requirements imposed by European and local data protection laws.
In this privacy notice we explain the principles that we apply, in our capacity as a controller, when we process HCPs personal data (“Privacy Notice”). It applies to all personal data that is collected and processed in any format, whether electronic or paper.
1. Our purposes, the personal data we collect and how long we keep it
We process your personal data for different purposes, all in the context of the professional relationship we have with you or we aim at having.
We usually collect personal data directly from you but we may obtain personal data such as your contact details from other sources such as IQVIA, public databases, social media platforms and other third parties.
We take adequate measures to ensure your personal data are not stored for longer than necessary to meet the below-mentioned purposes or as necessary in the context of a contract or a legal obligation.
For each purpose, we list here the legal basis, the categories of personal data concerned and the retention period of the personal data:
|Purpose and legal basis||Categories of personal data concerned||Retention period|
➡️ Based on our legitimate interest to start and/or maintain a professional relationship with you
||As long as there exists a professional relationship between us|
Direct Marketing Communications
➡️ Based on your consent.
|Identification data and contact details||As long as there exists a professional relationship between us (unless you withdraw your consent). You may unsubscribe from our emails at any time by using the unsubscribe link provided in each communication we send you.|
Administration of invoices:
➡️ Necessary to comply with accounting legal obligations
|Identification data and contact details;
||As long as it is required by legal accounting obligations.|
Organization of your attendance to fairs and events:
➡️ Based on our legitimate interest to organize your attendance to fair and events
||1 month after the event took place, except when applicable legislation obliges us to keep this data longer, then the retention period stated in the law.|
Transfers of Value:
➡️ Necessary to comply with national legal obligations or;
➡️ Based on your consent. This depends on the legislation in your country of residence. If consent is required, your consent will be obtained accordingly.
As long as it is required by national laws (e.g. the Belgian sunshine act requires to keep personal data for transfer of value purposes for 10 years).
If the period is not defined by a national legal obligation, as long as necessary for us to comply with the EFPIA Code of Practice (unless you withdraw your consent).
➡️ Necessary to ensure compliance with a legal obligation to keep clinical trial related data
||We will keep your information for 25 years after the end of the clinical trial as provided by the Clinical Trial Regulation.|
Market Research and other activities:
➡️ Necessary to ensure compliance with pharmacovigilance laws or;
➡️ Based our legitimate interest to collect information about the commercialization of our products.
|Identification data and contact details;
||As long as it is required by pharmacovigilance laws.
If the period is not defined by a national legal obligation, we will try to de-identify your data if possible.
➡️ Based on our legitimate interest to invest in the research
||As long as it is necessary for us to assess the possibility to fund the research|
We believe that the above-mentioned purposes for processing your personal data are within anyone’s reasonable expectations. However, for all of the personal data we have collected in the aforementioned circumstances, we wish to make it clear that we will also process your personal data to: (a) comply with legal obligations or to comply, insofar we are legally allowed to do so, with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities; (b) inform a third party in the context of a possible merger with, acquisition from/by or demerger by that third party, even if that third party is located outside the EU, in which case we rely on our legitimate interest to engage in corporate transactions.
We take all appropriate steps to ensure that personal data are accurate, up to date and reliable for the purposes intended. Please be aware that you are partly responsible for the accuracy of your personal data. Should certain information we hold about you change, please notify us promptly.
3. Disclosure to third parties
We may obtain assistance or use third parties for the abovementioned purposes. These third parties will be required to process your personal data only in accordance with our instructions and to maintain reasonable security of such personal data. These third parties may include but are not limited to, as the case may be: payroll organization, social secretariat, health insurance provider, group insurance provider, HR-system provider or another software supplier, cloud service solution provider, banking institution and an authorized medical entity. In addition, personal data may be disclosed to authorized persons dealing with claims and investigations, law enforcement authorities, legal advisors and public authorities if needed to comply with a request or for the establishment, exercise or defense of legal claims.
It may occur that data about you is shared within the Galapagos group of companies if this is necessary to achieve specific purposes. We take appropriate measures to ensure that all the entities of the Galapagos group are submitted to the same or equivalent data protection rules. If the entity is located outside the EEA we will take the necessary measures to ensure the equivalent protection as within the EEA.
As a general rule, the data that we collect from you is not transferred outside the EEA. If we, in exceptional circumstances, do transfer data outside the EEA, we will ensure it is protected employing the following safeguards:
4. Security of processing
We acknowledge our responsibility to ensure an appropriate level of security with regard to your personal data. Therefore, we have implemented appropriate technical and organizational measures in order to protect the personal data against loss, alteration, accidental or unlawful destruction, unauthorized disclosure of, or access to the personal data.
5. Your rights
When we collect and use your personal data, you can exercise the following rights:
Unless specified otherwise above, you can exercise those rights by sending a request to email@example.com. After verifying your identity and applicability criteria, we will as a general rule, provide you with information on action taken within one month of receipt of the request.
6. Changes to the privacy notice
Changes to this Privacy Notice can be made from time to time, in accordance with European and local data protection laws. When we change the content of this Privacy Notice, we will change the date and version number of the ‘last update’ of this Privacy Notice.
If you have any questions or comments with regard to the contents of this Privacy Notice or if you want to exercise one of your rights in relation to the data processed by us, you can contact our Data Protection Office by sending an email to firstname.lastname@example.org.