Notice of Personal Data Processing Relating to Safety Information and Customer Care Enquiries 

 

This Privacy Notice is addressed to: 

  • Healthcare Professionals
  • Patients
  • Members of the public

Novo Nordisk A/S and Novo Nordisk Limited are required by law to register your enquiries, collect complaints and safety information concerning our products and whilst doing so to also protect your personal data. This Notice explains how we process (e.g. collect, use, store, and share) your personal data. We will process any personal data about you in accordance with this Notice and with applicable law.

In Novo Nordisk we collect all customer enquiry and safety information on our products into a database. We analyse the data on a regular basis to determine if there is any new information about our products that we need to share with authorities, doctors and patients. This is all done with the purpose of securing the safety of our products and patients.

 

1.   WHO ARE WE?

The companies responsible for processing your personal data is/are:

Novo Nordisk A/S                     
Novo Alle 1
DK-2880 Bagsvaerd
Denmark

Novo Nordisk Limited
3 City Place, Beehive Ring Road
Gatwick, West Sussex
RH6 0PA
United Kingdom
Registration number 1118740

 You can always contact the local Data Protection Officer or UK Data Protection Officer/Responsible at Novo Nordisk Limited at privacyuk@novonordisk.com or the Global Novo Nordisk Data Privacy Officer at privacy@novonordisk.com with questions or concerns about how we process your personal data.

 

2.   HOW DO WE COLLECT PERSONAL DATA ABOUT YOU?

We get your personal data from the following sources: 

  • From you directly
  • From Health Care Professionals such as your nurse, a pharmacist or doctor
  • From publicly available publications, websites, or social media

 

 

3.   WHY DO WE PROCESS YOUR PERSONAL DATA?

We always process your personal data for a specific purpose and only process the personal data which is relevant to achieve that purpose. In particular, we process your personal data for the following purposes:   

  • To address your general enquiries and concerns in regards to our products
  • To perform a scientific evaluation of any complaint or side effect potentially related to a Novo Nordisk medicinal product
  • To file side effects in our global safety database, which is regularly analysed for overall patterns
  • To assess patterns associated with complaints, including side effects

 
4.   WHAT PERSONAL DATA DO WE PROCESS ABOUT YOU?

For the purposes described above in Section 3, we may process the following types of personal data: 

  • Contact information (name, address, telephone number, email address)
  • Data revealing racial or ethnic origin
  • Data concerning health and medicinal products you are using 

  5.   WHY ARE WE ALLOWED BY LAW TO PROCESS YOUR PERSONAL DATA? 

Personal data are collected only to the extent required. Under no circumstances are the collected data sold on to third parties for any reason. Our processing of your personal data requires a legal basis. We will not process your personal data if we do not have a proper justification foreseen in the law for that purpose. Therefore, we will only process your personal data if: 

  • The processing is necessary for our compliance with the legal safety obligation

 6.   HOW DO WE SHARE YOUR PERSONAL DATA? 

We may share your personal data with: 

  • Health authorities
  • Other Novo Nordisk entities (e.g., Novo Nordisk affiliates in other countries)
  • Partner companies that assist our company (e.g. licence partners, consultants, IT service providers)

 

7.   WHEN DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE THE EU/EEA?

For the purposes described above in Section 3, we transfer your personal data to countries outside the European Economic Area (EEA). The level of data protection in certain countries outside the EEA does not conform to the level of data protection for personal data currently applied and enforced within the EEA.

We therefore use the following safeguards, as required by law, to protect your personal data in case of such transfers:

  • The transfer is to a Novo Nordisk entity covered by Novo Nordisk’s Binding Corporate Rules, available at https://www.novonordisk.com/about-novo-nordisk/corporate-governance/personal-data-protection.html.
  • The destination countries are deemed by the EU Commission to have an adequate level of protection of personal data.
  • We have entered into Standard Contractual Clauses for the Transfer of Personal Data to Third Countries. You can get a copy of the Clauses by contacting us as described in Section 1.

 

8.   HOW LONG WILL WE KEEP YOUR PERSONAL DATA? 

We will keep your personal data for the following period of time:

  • 12 years for data relating to technical complaints
  • Permanently for data relating to side effects
  • Up to 5 years for all other enquiries
     

9. WHAT ARE YOUR RIGHTS? 

In general, you have the following rights:  

  • You can get an overview of what personal data we have about you
  • You can get a copy of your personal data in a structured, commonly used and machine-readable format
  • You can get an update or correction to your personal data
  • You can have your personal data deleted or destroyed
  • You can submit a complaint about how we process your personal data to a Data Protection Authority.

 Under applicable law, there may be limits on these rights depending on the specific circumstances of the processing activity.  Contact us as described in Section 1 with questions or requests relating to these rights.

 

 

November 2020