Global Privacy Notice For Healthcare Professionals and Other Experts

‘Data Subject(s)’ means any identified or Identifiable Healthcare Professional whose Personal Data is being processed by Sanofi and to whom this Privacy Notice is dedicated.

'Healthcare Professional(s)’ or ‘HCP(s)’ means any medical professional who works in the field of health with roles in the diagnosis, treatment or prevention of diseases and any employees supporting such professional activity who is registered to practice, as well as any other expert to whom this Privacy Notice is intended for such as Key Opinion Leaders, Members of the Scientific Community and Scientific External Experts. For this Privacy Notice, HCPs are for example physicians, pharmacists, prescribing and non-prescribing nurses and other paramedical professionals.

‘Key Opinion Leader(s)’ or ‘KOL(s)’ means any professional, highly respected influencer such as academics, social network and digital platform influencers, medical or patient organization representatives, and any employees supporting such professional activity. For this Privacy Notice, KOLs are, for Global Privacy Notice for Healthcare Professionals and other experts example, speakers at medical conferences, professionals involved in guideline committees, editorial board members, professionals involved in clinical trials, research, steering and/or data safety committees, board members of national or international societies, patient advocacy group members, and professionals whose work is published with high scientific acceptance.

‘Member(s) of the Scientific Community’ or ‘MSC’ means any professional involved in medical research topics within their field of expertise and any employees supporting such professional activity.

‘Scientific External Expert(s)’ or ‘SEE(s)’ means any professional with broad expertise in a specific scientific or medical field and any employees supporting such professional activity. For this Privacy Notice, SEEs are speakers at scientific conferences, professionals involved in guideline committees, editorial board members, professionals involved in research, steering and/or data safety committee, board members of national or international societies, or professionals whose work is published with high scientific acceptance. Representatives of patient advocacy groups or patient associations are not considered SEEs.

‘Sanofi’ (and when referring to Sanofi, ‘we’, ‘us’, ‘our’) means the group of Sanofi companies.

‘Controller’ means Sanofi Winthrop Industrie (82 avenue Raspail, 94250 Gentilly, France; registered under RCS number 775 662 257) and the local Sanofi legal entity which has a relationship with you and which is subject to the obligations and responsibilities relating to a specific Processing Activity under Privacy Laws or another Sanofi legal entity which may process your Personal Data. If you want to know more about Sanofi legal entities that process your Personal Data, you can consult the Data Protection Contact page, where you can raise your questions.

‘Employee’ means any employee of Sanofi, whether full time or part time, temporary or trainee and any other employee category according to local regulation, as well as any complementary worker acting on behalf of Sanofi.

‘Personal Data’ means any information that relates to an identified or identifiable person (‘Data Subject’). It can be directly identifying (for example a name) or indirectly identifying through the combination of several pieces of data (for example the gender, date of birth and address).

‘Privacy Laws’ means the relevant regional and local law(s) and regulation(s) concerning the protection of Personal Data and/or privacy, applicable to Processing Activities.

‘Personal Data Transfer’ means any personal data disclosure, copy or move via a network (for example remote access to a database) or a tool regardless of the method or the recipient’s country.

‘Privacy Notice’ means this Global Privacy Notice for HCPs detailing the general information to be shared with HCPs, with regards to the processing of their Personal Data by Sanofi and its subcontractors. This Privacy Notice describes what Personal Data Sanofi collects, stores, uses, publishes, transmits, transfers, and generally processes.

‘Processing Activity’ means any operation or set of operations which is performed on personal data or sets of personal data, whether by automated means, such as collection, recording, organization, storage, adaptation, retrieval, consultation, use, disclosure by transmission or otherwise making available, alignment or combination, blocking, restriction, pseudonymization, anonymization, erasure or destruction.

‘Group Privacy Framework’ means the framework of policies, standards, processes and guidelines designed to manage and implement privacy requirements that have been adopted within Sanofi.

“Standard Contractual Clauses (SCCs)” means the contractual mechanisms set forth by Privacy Laws to ensure adequate safeguards for the transfer of Personal Data to third countries.

The personal data Sanofi processes about you may include, but is not limited to:

• Basic information: your name, surname (including prefix or title), alias, gender, age or date of birth, as well as your preferred language.
• Contact information: information that enables Sanofi to contact you, for example your personal or business email, mailing address, telephone numbers and profile ID on a social media platform.
• Professional information and experience: information related to your qualifications, areas of expertise, place of work, professional registration number and medical practitioner number.
• Financial information: such as your bank account name and number, credit or debit card number and other financial and compensation details.
• Circumstances which may create a conflict of interest, including whether you or a close family member are an officer or employee of a political party, candidate for public office or hold a position in government.
• Travel-related and other identification information, including your national ID number, passport number, airline membership, driving license number, tax identification number, next of kin and travel preferences.
• Professional biography and/or other information, including your CV or resume, photograph, academic information, your professional interests, preferences, insights or feedback.
• Product use: data related to your use of Sanofi products, your interactions with Sanofi, your preferred means of communications with Sanofi, and services you may use.
• Consent collection information about yourself.
• Technical and network activity information: information about your device and usage of Sanofi websites, applications and systems, including your IP address, device ID, hardware model and version, mobile network information, operating system and other online identifiers, type of browser, browsing history, search history, access time, pages viewed, URLs accessed, forms submitted, and physical location.

This list of personal data is not exhaustive. Additional categories and/or types of personal data can be processed by Sanofi. In any case, Sanofi will provide you with clear information regarding the type of personal data it processes while interacting with you, through specific privacy notices.

Sanofi collects your Personal Data directly from you, for example when you:

• Create an account or profile in or navigate through Sanofi websites or applications. 

• Share or use your social media profile ID to contact Sanofi.

• Sign up to receive communications, promotional material, etc.

• Interact with Employees such as sales representatives, medical science liaisons, commercial managers, customer experience leads, medical engagement managers, research and development staff, therapeutic area managers and customers.

• Attend an online event such as a webinar or a congress.

• Share adverse events, medical information enquiries, stock related queries, or product quality.

• Attend meetings such as advisory boards or conferences.

This list is not exhaustive, and Sanofi may use additional methods of collecting your personal data. In any case, Sanofi will provide you with relevant privacy information when collecting your Personal Data.

Sanofi collects your personal data indirectly from other sources such as third parties that are acting under their own privacy framework, such as:

• Data companies providing information services in the healthcare sector.
• Joint venture partners.
• Marketing services providers.
• Healthcare provider directories.
• Your patients when they inform Sanofi that you are their healthcare provider
• Patient organizations.
• Events management agencies.
• Travel agents.
• Social media platforms when you use a professional social media account.
• Publicly accessible sources.

Personal Data which is processed during your relationship with Sanofi can be re-used for any purpose described in this Privacy Notice.

Sanofi generates personal data by associating information from various sources. Sanofi assesses and analyzes your professional interests, preferences, insights, feedback and other activities, as well as your relationship with Sanofi as described further in 4.1. Sanofi's objective is to improve your customer experience by anticipating your expectations and personalizing future interactions.

This creation of personal data does not imply automated decision making which is likely to have an impact on your relationship with Sanofi, nor on your rights and freedoms.

If Sanofi were to resort to automated decision-making mechanisms impacting your rights and freedoms in order to pursue the purposes described in this Privacy Notice, Sanofi will comply with Privacy Laws. In this case, you will be duly informed by Sanofi by means of a specific privacy notice.

This purpose involves Sanofi processing your personal data to:

• Develop a collaboration, communicate, engage, conduct business, ensure awareness, and educate about diseases, contents, products, solutions, digital platforms and services.
• Ask, collect, analyze and understand your professional interests, preferences, insights, feedback, trends, digital background (for example: browsing experience, cookies/tags/pixels history, social media audience listening) and other activities in connection with diseases, people (for example: other HCPs, representatives of health or public authorities, Employees) and Sanofi’s content, products, solutions, digital platforms, services, and communications.
• Track scientific contributions (for example: publications, posters, presentations at congresses) any public data on engagement with competitors, and sentiments on competition and landscape.
• Build profiles based on your characteristics, to adapt and personalize Sanofi’s contents, products, solutions, digital platforms, services, and communications to your profile, as well as to identify and connect with similar profiles.
• Perform medical and commercial tiering, targeting and segmentation activities.
• Document and keep track of Sanofi’s interactions for administration purposes.

This purpose involves Sanofi processing your personal data to:

• Engage with you
  - To conduct pre-clinical research and foster the discovery of innovative medicines.
  - To conduct clinical research activities including clinical studies, manage, and validate recruitment and participation.
  - To perform Research & Development activities, such as Research & Development advisory boards, publications, steering committees, data monitoring committees, etc.
  - To facilitate the preparation, submission and approval of applications for health authorities, including interactions and participation in meetings.
  - To conduct real-world evidence trials and research.
   
• Meet Sanofi's post-trial access commitments to patients.

This purpose involves Sanofi processing your personal data to:

• Engage with you
  - Regarding medical activities (for example: medical advisory boards, publications).
  - To identify scientific insights on the disease states Sanofi works within, current and emerging treatments, and insighsts into the changing healthcare landscape.
  - To understand interest in and to carry out pre/post approval clinical research activities including clinical studies, registries, and post authorization safety and efficacy studies, and to manage and validate recruitment and participation.

• Conduct visits to provide medical or non-promotional information.

• Send general and/or personalized medical communications and initiate specific campaigns regarding Sanofi’s products, solutions, digital platforms, services, and other content.

• Adapt the interactions you have with Sanofi based on your requests, characteristics, and profiles.

• Answer your medical information requests through any of Sanofi’s communication channels (for example: face-to-face, phone, SMS, instant messaging, email, websites, social media).

• Communicate with you and ensure the proper and safe administration and prescription of products, solutions, and services within the framework of medical and clinical studies when you are acting as a study investigator.

This purpose involves Sanofi processing your personal data to:

• Engage with you regarding sales, marketing, and other commercial activities.
• Conduct visits to provide promotional and non-promotional information.
• Send general and/or personalized commercial communications and initiate specific campaigns regarding Sanofi’s products, solutions, digital platforms, services and other content.
• Adapt interactions you have with Sanofi based on your requests, characteristics, and profiles.
• Answer your non-medical requests through any of Sanofi’s communication channels (for example: face-to-face, phone, SMS, instant messaging, email, websites, social media).

This purpose involves Sanofi processing your Personal Data to address safety concerns during the management of an adverse event which may have been reported, or for any pharmacovigilance activities that are required to be performed.

This purpose involves Sanofi processing your personal data to:

• Enter into and to manage contracts, and inform you about changes to Sanofi’s terms, conditions, and policies.
• Manage finance, accounting activities, and fight fraud: Sanofi processes Personal Data to authenticate you, to process payments and to verify your financial information and facilitate payments.
• Comply with Sanofi’s legal reporting duties: when Sanofi needs to confirm financial information or verify licensure. Sanofialso receives Personal Data from third parties authorized to share it with Sanofi.

This purpose involves Sanofi processing your personal data to:

• Comply with obligations under applicable laws, regulations, guidelines, standards and codes, and to respond to legal requests from regulatory or judicial authorities, to comply with a subpoena, a required registration, or a legal process.
• Protect Sanofi’s rights, interests, privacy, safety, or property.
• Protect the health, safety, and security of Employees and premises and/or maintain the security of Sanofi’s services and operations.
• Manage claims including insurance claims.
• Conduct internal audits, manage assets, system and other business controls.
• Manage business administration (for example: finance and accounting, fraud monitoring and prevention).
• Enable Sanofi to pursue available remedies and limit risks, concerns, and issues that Sanofi may incur, as necessary.
• Protect Sanofi against possible fraudulent action.
• Exercise or defend Sanofi against potential, threatened, or actual litigation.
• Investigate and act against any illegal or harmful behavior.

In the context of Ethics and Transparency, Sanofi can also use your Personal Data to ensure that there is no ethical or business integrity concern related to Sanofi’s collaboration and relationship with you and to disclose transfers of value according to applicable laws (for example: payment for services, consultancy, travel, accommodation, meals, indemnity and registration fees).

This purpose involves Sanofi processing your personal data to:

• Conduct market or consumer research and studies for which you can be contacted to take part as willing participants.
• Provide patient support, healthcare support and engagement programs regarding Sanofi's products, solutions, digital platforms, services, and other content.
• Participate and interact with Sanofi's services regarding specific initiatives related to patient support programs, compassionate use of Sanofi's products, etc.
• Perform non-interventional studies to demonstrate the efficacy and safety of Sanofi's products.
• Provide donations and sponsorships for public health purposes, in case of collaboration with patient organizations, for funding specific projects or initiatives which improve the health of patients.
• Participate in scientific exchange activities, share information with entities collaborating with Sanofi (including research partners or other organizations including in the context of clinical trials) and provide information to regulatory authorities or other third parties for the purpose of product registration.

This purpose involves Sanofi processing your personal data to:

• Manage the data for registration at an in person and/or online event forum, seminar, or congress that Sanofi organizes, sponsors, funds, or promotes, as well as to maintain, manage and control your participation, and facilitate your access to the event.
• Manage and analyze your feedback, opinions, or suggestions related to these events, webinars, or congresses through the channels and tools made available to you.
• Notify you of your registration confirmation and send you reminders and calendar appointments related to the event, online seminar, or congress through the selected contact channels.
• Manage electronic communications with information regarding content, products, solutions, digital platforms, and services.
• Take photos and/or record videos or audio where attendees and speakers may appear. These recordings may be used to broadcast the event and to provide graphic support, podcasts, interviews, media activities, etc. for coverage in the media, social media, and internally within Sanofi.
• Address your questions raised to Sanofi.
• Comply with the obligation to publish the payments and transfers of value made to healthcare professionals for their collaboration/participation in scientific and professional meetings and/or provision of services, as required by relevant authorities.

This purpose involves Sanofi processing your personal data to:

• Develop, manage, and improve its tools (for example: networks, applications, devices, portals) and processes.
• Ensure the security information systems (for example: to enable Sanofi to identify or authenticate you, to provide or verify your credentials including via passwords, password hints, security information and questions, government-issued IDs, healthcare professional numbers, driver’s license data, passport data).
• Improve services, support, and collaboration with Sanofi's workforce and assets.

Should Sanofi pursue specific Processing Activities for purposes, either complementary or contrary to those described in this Privacy Notice, or if Sanofi is required to abide by specific provisions under locally binding Privacy Laws:

• You will be specifically informed by Sanofi of this processing of Personal Data, by means of a dedicated privacy notice.
• The stipulations of such a privacy notice may complement and/or replace this Privacy Notice, depending on the specific provisions set forth.

Sanofi may revise this Privacy Notice from time to time. Any changes to this Privacy Notice will be reflected on this page with immediate effect.

It is recommended to review this Privacy Notice regularly to be informed of any changes.

If changes are significant, Sanofi will provide a specific notification to inform you of such changes.