Privacy Policy

About this notice 

This website is operated by Otsuka Pharmaceutical Europe Ltd. (“Otsuka”), Gallions, Wexham Springs, Framewood Road, Wexham, Slough, SL3 6PJ.   For the purposes of this notice, Otsuka will be the controller, meaning Otsuka determines how and to what extent your personal data will be processed (the controller is also referred to in this notice as “Otsuka”, “we”, “our” and “us”). This notice explains how and why we use your personal data, e.g. when we provide you with information you have requested from us, within the framework of any agreement pursuant to which you provide services to Otsuka, or when you simply use our websites and other digital platforms. In all cases, Otsuka understands and respects your privacy and acknowledges that in particular the information about an individual’s health and healthcare is confidential and sensitive. In this notice, when we talk about personal data we mean any information that relates to an identifiable natural person – in this case, you. You should read this notice, so you know what personal data we collect about you, what we do with it and how you can exercise your rights in connection with it. You should also read any other privacy notices that we give you, that might apply to our use of your personal data in specific circumstances from time to time. If you have any questions about this notice, you can contact Otsuka’s Data Protection Officer, by writing to the “Legal & Compliance Department” at the address for Otsuka provided above, or by submitting your query to our web form.

In summary…

  • We use your personal data within the framework of any agreement pursuant to which you provide services to Otsuka, when you use our websites and other digital platforms, to provide you with information, where you have requested them, manage our business, recruit new staff, comply with our legal obligations, and improve and monitor the performance of our digital platforms
  • We have measures in place to safeguard your personal data when we transfer it outside the European Union
  • We take steps to minimise the amount of personal data we hold about you and to keep it secure
  • We delete your personal data when we no longer need it, and we have policies in place to govern when that is
  • You have a number of rights in relation to your personal data
  • We are happy to answer your questions about any of the above – please just submit them to our web form.

Who are you?
We process personal data for different purposes, depending on who you are. To find out for what specific purposes we process your personal data, you may choose from the below. I am…

Quickly find what you’re looking for by clicking the links below:

  1. Our data protection responsibilities
  2. What types of personal data do we collect and where do we get it from?
  3. What do we do with your personal data, and why?
  4. Who do we share your personal data with, and why?
  5. Where is your personal data transferred to?
  6. How do we keep your personal data secure?
  7. How long do we keep your personal data for?
  8. What are your privacy rights and how can you exercise them?

1. Our data protection responsibilities

Otsuka is a "controller" in relation to its use of your personal data. This is a legal term – it means that we make decisions about how and why we use your personal data and, because of this, we are responsible for making sure it is used in accordance with applicable data protection laws. We are required by law to give you the information in this notice.

2. What types of personal data do we collect and where do we get it from?

2.1. The personal information we process about you broadly falls into four main categories: (i) Contact Information; (ii) Agreement Information; (iii) Candidate Information and (iii) Browsing Information. 2.2. We collect your personal information from limited sources. The table below sets out the different types of personal information that we collect and the sources we collect it from.
Category Type of personal data Collected from
Contact Information
  • Name
  • Address
  • Telephone number
  • Organisation details (eg your place of work, practice, professional area, job title and organisation contact information)
  • You
 Agreement Information
  • Contact Information (see above)
  • Details relating to the services you provide to us, including service related communications with you
  • Information about other people (eg your customers and/or staff) that you share with us in connection with your services or when ordering products from us
  • Information you provide us when you interact with Otsuka (eg for a product order, conference, patient cohort)
  • Billing and payment information
  • You/your organisation’s banking details
  •  You
 Candidate Information
  • Contact Information (see above)
  • Details you include in your application, eg CV, references, certificates
  •  You
  • Publically available resources, such as LinkedIn if you have given your consent to it (for Finland)
2.3. Please note that if you do not provide us with your Contact Information we will not be able to provide you with any information you request, and if you do not provide us with your Contact Information, Agreement Information or Candidate Information, we will not be able to interact or contract with you.

3. What do we do with your personal data, and why? 

3.1. We use your personal data for a number of different purposes. We must always have a “lawful basis” (ie a reason, prescribed by law) for processing your personal data. The table below sets out the purposes for which we process the different categories of your personal data and the corresponding lawful basis for that processing. For some processing activities, we consider that more than one lawful basis may be relevant – depending on the circumstances. 3.2. Website visitors 
Category of information Purposes of processing Lawful basis
Contact Information Responding to your enquiries To perform a contract with you Legitimate interests (It’s important that we can respond to your enquiries)
Browsing Information Monitoring and producing statistical information regarding the use of our platforms, and analysing and improving their functionality Legitimate interests (We need to perform this limited routine monitoring to make sure our platforms work properly)
3.3. Healthcare professional 
Category of information Purposes of processing Lawful basis
Contact Information Responding to your enquiries and orders for products To perform a contract with you Legitimate interests (It’s important that we can respond to your enquiries)
Agreement Information To be able to keep accurate records of Otsuka’s communications with you. In addition, we may need the information you provide to comply with our regulatory monitoring and reporting obligations. To perform a contract with you To comply with a legal obligation
Agreement Information Disclosure of payments according to regulatory requirements Consent
Agreement Information To understand how our products impact your patients, to track and respond to safety concerns and to further develop and improve our products and services. For example, we may create a record about you to decide whether to invite you to participate in various programs, panels of experts or surveys about our products or services. Legitimate interests or in certain circumstances based on your consent to use certain personal data for our business development strategies; we have a legitimate interest in making sure that we are continuously improving our product offering)
Agreement Information Compliance with our legal obligations where data related to safety or pharmacovigilance is concerned, including those related to adverse events, product complaints and patient safety. To comply with a legal obligation
3.4. Job applicants 
Category of information Purposes of processing Lawful basis
Candidate Information Processing of this personal data is required to enable Otsuka to administer the recruiting process, including the set-up of an electronic job applicant HR file, managing your application, organizing interviews – in short, the processing is necessary for us to entering into a contract with you. Legitimate need to perform a contract with you
Candidate Information We may also share your personal data with other Otsuka group companies to consider you for future job openings and will retain your data for a limited period of time beyond an unsuccessful application for this purpose. Consent must be given for retention of information for potential future recruitment
3.5. Website visitors, healthcare professionals and job applicants
Category of information Purposes of processing Lawful basis
All Information Establishing and enforcing our legal rights and obligations and monitoring to identify and record fraudulent activity; Complying with instructions from law enforcement agencies, any court or otherwise as required by law; resolving any complaints from or disputes with you. Legitimate interest and compliance with legal obligations
3.6. Cookies and similar technologies For more information regarding how we use cookies and similar technologies in connection with your use of our website, please read our Cookie Policy.

4. Who do we share your personal data with, and why? 

4.1. Sometimes we share your personal data with third parties, including the following: 4.1.1. other Otsuka companies where necessary for the purposes described above and where you have consented to such disclosure, if your consent is required. 4.1.2. courts, where we are asked to respond to a court order or other binding requests; 4.1.3. regulatory authorities and law enforcement agencies, where necessary for any investigations or to respond to enquiries in relation to our compliance with applicable law or regulations; and 4.1.4. professional advisors (such as lawyers and accountants). These organisations will use your personal data as a “data controller” – they will have their own privacy notices  - and will have their own responsibilities to ensure that their processing comply with applicable data protection laws. 4.2. We also ask third party service providers to carry out certain business functions for us. These include: 4.2.1. IT support, cloud platform and data hosting providers who help us with the operation of our websites, mobile applications, document and workflow management systems and other systems and applications; 4.2.2. Service providers assisting us in the organisation of events, arranging travel logistics and bookings; 4.2.3. Third parties assisting on the collection and disclosure of transfer of value information to the public; 4.2.4. Communication service providers, including companies who send out surveys and communications on our behalf; and 4.2.5. Survey providers who help collate feedback for us. We will have in place an agreement with our service providers which will restrict how they are able to process your personal data and impose appropriate security standards on them.

5. Where is your personal data transferred to? 

5.1 Since Otsuka is part of a global group, we will sometimes need to transfer your personal data outside the European Union, in particular to the US and our headquarters in Japan. We will only make that transfer if: 5.1.1. that country ensures an adequate level of protection for your personal data; 5.1.2. the recipient or recipient country is subject to an approved certification mechanism or code of conduct with binding and enforceable commitments which amount to appropriate safeguards for your personal data – this includes for example, the EU-US Privacy Shield which enables the secure transfer of personal data to the United States; 5.1.3. we have put in place appropriate safeguards to protect your personal data, such as a contract with the person or entity receiving your personal data which incorporates specific provisions as directed by the European Commission. 5.1.4. the transfer is permitted by applicable laws; or 5.1.5. you explicitly consent to the transfer. 5.2. We are still responsible for the security of the data as a Data controller, even if we transfer your data to other parties within our global group of companies or third parties. If you would like to see a copy of any relevant provisions, please contact us at the address above or submit your request to our web form.

6. How do we keep your personal data secure? 

6.1. We will put in place appropriate security measures to protect your personal data from unlawful or unauthorised processing and accidental loss, destruction or damage. 6.2. However please note that, in relation to any personal data you submit to us online, we cannot guarantee the security of data sent to us in this way. Transmission of data over the internet is at your own risk.

7. How long do we keep your personal data for? 

7.1 We will only retain your personal data for a limited period of time, and for no longer than is necessary for the purposes for which we are processing it for. This will depend on a number of factors, including: 7.1.1. any laws or regulations that we are required to follow; 7.1.2. whether we are in a legal or other type of dispute with each other or any third party; 7.1.3. the type of information that we hold about you;  7.1.4. whether we are asked by you or a regulatory authority to keep your personal data for a valid reason; and 7.1.5. any collected personnel data will be assess on a regular bases and deleted when not relevant for its initial purposes

8. What are your privacy rights and how can you exercise them? 

8.1. Where our processing of your personal data is based on your consent (see table at paragraph 3 above), you have the right to withdraw your consent at any time. If you do decide to withdraw your consent you can contact the Data Protection Officer at our web form and we will stop processing your personal data for that purpose, unless fulfilment of a contract or to honour a legal obligation after a withdrawal of consent in which case, we will let you know. 8.2. Where our processing of your personal data is based on the legitimate interests (see table at paragraph 3 above), you can object to this processing at any time. If you do this, we will need to show either a compelling reason why our processing should continue, which overrides your interests, rights and freedoms or that the processing is necessary for us to establish, exercise or defend a legal claim. 8.3. You have the right to (subject to certain limitations): 8.3.1. access your personal data and to be provided with certain information in relation to it, such as the purpose for which it is processed, the persons to whom it is disclosed and the period for which it will be stored; 8.3.2. require us to correct any inaccuracies in your personal data without undue delay; 8.3.3. require us to erase your personal data; 8.3.4. require us to restrict processing of your personal data; 8.3.5. receive the personal data which you have provided to us, in a machine readable format or ask us to transmit the information to another data controller, where we are processing it on the basis of your consent or because it is necessary for your contract with us (see table at paragraph 3 above) and where the processing is automated; and 8.3.6. object to a decision that we make which is based solely on automated processing of your personal data if that is necessary for us to fulfil a contract or legal requirements you have given your consent to. 8.4. Please contact us at our web form if you would like to exercise any of your privacy rights. 8.5. We also encourage you to let us know if you have any concern about how we are processing your personal data so we can try to resolve your concerns. However, if you consider that we are in breach of our obligations under data protection laws, you are always entitled to submit a complaint with the competent supervisory authority in the EU member state where you have your habitual residence or where the alleged infringement of the EU Data Protection Regulation occurred. 8.6. We may decide to change this notice. If the change is fundamental or may significantly affect you, we will provide you with the updated notice in advance of the change actually taking effect. We encourage you to review the content of this notice regularly.

Date of preparation: May 2018

Reference OPDK/1017/COMS/1094

)