Privacy Policy

 

Who we are

In this privacy policy (“Privacy Policy”), references to "we", "us" and "our" are to Otsuka Pharmaceutical U.K Ltd, 2 Windsor Dials, Arthur Road, Windsor SL4 1RS (“Otsuka”). References to "our Website" or "the Website" in this Privacy Policy are to https://jinarctraining.co.uk

 

Purpose of the Privacy Policy

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. In this notice, when we talk about personal data we mean any information that relates to an identifiable natural person – in this case, you. We are committed to collecting, maintaining, and securing personal data, personal data about you in accordance with this Privacy Policy, as well as applicable laws, rules and regulations.

 

Collection and Processing of your Personal Data

Any personal data we collect from you on this Website will be processed in accordance with the UK GDPR and other applicable laws, such as the Data Protection Act 2018 with 2021 amendments.

 

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

We collect personal data i.e. information from which you can be identified, such as name, address and e-mail address. The table below sets out the different types of personal data that we collect and the sources we collect it from:

Category Type of personal data Collected from
Enrolment Information
  • Name
  • Title
  • Speciality
  • E-Mail address
  • Organisation details (eg your place of work and organisation contact information)
 You and through your use of the Jinarc portal

 

What do we do with your personal data and why?

We use the Enrolment Information to keep you informed about any updates to the additional Risk Minimisation Materials (aRMM) for tolvaptan and to respond to requests you submit over the Website. We record your personal data on the Database, which is administered by us or on our behalf by a third party (the “Database”). Your personal data may also be used to contact you in relation to the administration or updating of the Database or in relation to any licence or regulatory requirement, such as pharmacovigilance activities. As agreed with your local country regulatory agency, a register of prescribers who have completed the training on the safety aspects of JINARC® is being maintained. Processing your data for these purposes is required to provide you with a reminder of when training is due, any updates to the aRMM and to comply with our legal obligations (UKGDPR).

 

Disclosure of Your Personal data

Sometimes we share your personal data with third parties, including the following:

 

  • We may need to pass the information we collect from you to other companies, including those within the Otsuka Group, for the limited purposes described above (see What do we do with your personal data and why?).
  • We may need to share certain information with courts, where we are asked to respond to a court order or other binding requests;
  • We may need to share information with 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
  • We may share information with professional advisors (such as lawyers and accountants).

These organisations will also use your personal data as a “controller” – they will have their own privacy notices which you should read, and they have their own responsibilities to comply with applicable data protection laws.

 

We also use a limited number of trusted service providers to carry out the activities described above (see What do we do with your personal data, and why?) on our behalf, i.e. maintaining the Database and for IT support. 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.

 

Where is your personal data transferred to?

Since Otsuka is part of a global company, we will sometimes need to transfer your personal data outside the UK and/or European Union, in particular to the US and our headquarters in Japan. We will only make that transfer if:

 

  • that country ensures an adequate level of protection for your personal data;
  • 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;
  • 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; or
  • the transfer is permitted by applicable laws.

If you would like to see a copy of any relevant provisions, please contact us at the address above or privacy@otsuka.co.uk

 

How long do we store your data?

We will keep your personal data for as long as we need it to fulfil the purposes for which it was collected (see above) and in order to comply with legal and regulatory requirements. This may mean that some information is held for longer than other information.

 

How do we keep your personal data secure?

We 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.

 

Your Rights

You have the right to request access to, correction, or deletion of your personal data and to ask for data portability. You are also entitled to object to the processing of your personal data in certain instances. When we process your personal data based on your consent, you may withdraw it for the future at any time.

To make a data subject request, please either write to privacy@otsuka.co.uk or submit your request here.

If you also have the right to lodge a complaint with the competent data protection authority. If you reside in the UK, you can raise the complaint directly with the ICO in a number of ways listed on their website https://ico.org.uk/.

If you would like further information about your data protection rights, please submit your request for information here