RB UK Commercial Limited, incorporated and registered in England and Wales, with registered company number 08784077, and whose registered office is at 103 – 105 Bath Road, Slough, Berkshire, SL1 3UH (hereinafter referred to as "we", “data controller” or "Reckitt") hereby informs you that we are processing your personal data.
Reckitt is committed to protecting the data privacy rights of all data subjects, in strict compliance with any applicable Data Protection Law in the UK, including the UK General Data Protection Regulation (hereinafter “UK GDPR”), Electronic Communications Regulations 2003 (PECR) and the Data Protection Act 2018 (hereinafter “Data Protection Laws”). Reckitt confirms that any personal data, processed in connection with this processing activity, will only be collected, stored or processed for the purposes specified below.
1. Purpose of processing: Reckitt and/or its partners on Reckitt´s behalf are processing personal data of you as a healthcare professional to maintain collaboration with you, to ensure distribution of promotional materials about Reckitt products and formulas, to invite you to healthcare events and conferences, and to enable sample distribution and reporting.
- Personal data have been collected from you directly (i.e. from our interactions with you) or from designated third parties.
2. Categories of personal data: Name, surname, title, salutation, address, email, institution, telephone, telefax number, profession/specialization, details about products, events and sampling initiatives.
3. Legal basis:
a. Legal basis for the processing of healthcare professional’s personal data to establish and maintain business relationship with representatives of Reckitt and its external business partners is Reckitt´s legitimate interest under Article 6 (1) (f) of UK GDPR. Reckitt believes that the data categories are absolutely necessary to identify the healthcare professional as potential Reckitt customer and to procure business relationship according to such customers specialization.
b. Legal basis for processing of healthcare professional’s data for sampling and reporting on procured sampling is Article 6 (1) (c) of UK GDPR as fulfillment of legal obligation defined in provision 298 of The Human Medicines Regulations 2012 No. 1916 covering obligations for sample distribution;
c. Legal basis for communication with customers via selected channels incl. email, telefax, web call, sms and messenger or similar services is consent as required under provisions 20, 21, 22 of PECR and in and in conjunction with Article 6 (1) (a) of UK GDPR (this includes provision of newsletter information, invites for events and conferences, distribution of information materials etc.).
4. Period of processing: Reckitt will only retain personal data as long as reasonably required for the purposes as set out in this information clause, specifically we will store the data until the withdrawal of your consent if the processing was based on consent; if the processing was bases on legitimate interest until fulfillment of purpose, i.e. existing collaboration with you; and if the processing was based on legal obligation the data are stored according to the legal requirements Reckitt is bound by.
5. Access of third parties: Your data are transferred to external third-party entities providing services to us, such as software as service, hosting, support, maintenance of the structure of our IT systems, on the basis of relevant agreements.
6. Transfer to other countries: Personal data are transferred outside the UK and the EU/EEA, as part of this processing activity by our external third-party business partners based on relevant safeguards (Standard Contractual Clauses and the UK Addendum as required by the UK Information Commissioner). Reckitt has further implemented contractual and other necessary organizational and security measures to ensure compliance with Data Protection Laws.
7. The protection of your personal data: Reckitt undertakes to implement appropriate technical and organizational measures in order to ensure a level of security corresponding to the personal data belonging to the participants. In assessing the appropriate level of security, account shall be taken in particular of the risks posed by the processing of personal data, caused in particular, by accident or illegally, by the destruction, loss, modification, unauthorised disclosure or unauthorised access to personal data transmitted, stored or processed.
8. Your rights: You have the right to (i) determine whether and what personal data we process about you and to receive a copy of such data, (ii) withdraw your consent without affecting the validity of the processing before its withdrawal (iii) request for updating and rectification of the data we process about you that you believe is incorrect or incomplete; (iv) request the erasure of your data (the right to "be forgotten"); (v) request restriction of data processing; (vi) object to processing due to special circumstances; (vii) request the transfer of data to another controller – called the "right of data portability"; (viii) lodge a complaint with the supervisory authority which is the Information Commissioner (ICO). Details of how to file a complaint can be found on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
Contact: If you have any questions or concerns about the processing of your personal data or wish to exercise your rights, please contact us. To exercise your rights and for more information, please contact PrivacyOffice@reckitt.com. You may opt-out from receiving all communications at any time by emailing us at PrivacyOffice@reckitt.com, by using the designated form or by contacting our Sales representative. You can also send a request to exercise the above-mentioned rights by letter to the Group Data Protection Officer at the following address: RB Global Privacy Office, Turner House, 103-105 Bath Road, Slough, United Kingdom, SL1 3UH.