At Novo Nordisk, we are committed to being transparent about our use of your personal data and how we protect it. This Privacy Notice explains which category of personal information we collect, why we collect it, and how we process (e.g., collect, use, store, and share) your personal data during your participation in clinical trials sponsored by Novo Nordisk. We will process any personal data about you in accordance with this Privacy Notice and our obligations under applicable law.

The company responsible for processing your personal data is: 

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

We collect your personal data from the following sources:  

  • From you directly or from your family members or care givers on your behalf;
  • From Health Care Professionals (HCPs) such as your nurse, a pharmacist or doctor.

Health and care research should serve in the public interest, which means that we have to demonstrate that our research serves the interests of society as a whole.

 We do this by following the UK-policy-framework-health-social-care-research and Data protection and information governance - Health Research Authority

We process personal data about you for the following purposes: 

  • We use  your information to conduct research to improve health and care. This means that we will use your data, collected in the course of a research study, in the ways needed to conduct and analyse the research study. 

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)
  • Emergency contact (e.g., name and telephone of family members)
  • Data revealing racial or ethnic origin;
  • Data concerning health;
  • Genetic data, biometric data for the purpose uniquely identifying a natural person;
  • Data concerning sex life or sexual orientation.

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: 

  • we have obtained your prior consent;
  • the processing is necessary to perform our contractual obligations towards you or to take pre-contractual steps at your request;
  • the processing is necessary to comply with our legal or regulatory obligations; or
  • the processing is necessary for our legitimate interests and does not unduly affect your interests or fundamental rights and freedoms. 

 

Please note that, when processing your personal data on this last basis, we always seek to maintain a balance between our legitimate interests and your privacy. Examples of such ‘legitimate interests’ are data processing activities performed: 

  • to develop a transparent and professional relationship with health care professionals;
  • to promote Novo Nordisk innovation in the pharmaceutical field;
  • to manage Novo Nordisk human and financial resources and optimise interactions with health care professionals;
  • to ensure that the right medicine according to a well-informed health care professional technical and professional opinion reaches the patient.
  • to benefit from cost-effective services (e.g. we may opt to use certain platforms offered by suppliers to process data);
  • to offer our products and services to our customers;
  • to prevent fraud or criminal activity, misuses of our products or services as well as the security of our IT systems, architecture and networks;
  • to sell any part of our business or its assets or to enable the acquisition of all or part of our business or assets by a third party; and
  • to meet our corporate and social responsibility objectives.
  • As a pharmaceutical company we have a legitimate interest in using information relating to your health and care for research studies, when you agree to take part in a research study. 

We may share your personal data with: 

  • Novo Nordisk staff and consultants, and other Novo Nordisk entities (e.g., Novo Nordisk affiliates in other countries)
  • IT-suppliers,
  • Laboratories working for Novo Nordisk
  • Research organisations or suppliers supporting Novo Nordisk with the conduct of the research study
  • Other researchers who are not part of the study,
  • Patient search agency
  • Suppliers or vendors that assist our company (e.g., consultants, IT service providers, financial institutions, law firms, license partners) for the conduct of the clinical research

The above third parties are contractually obliged to protect the confidentiality and security of your personal data, in compliance with applicable law. 

Your personal data can also be accessed by or transferred to any national and/or international regulatory, enforcement, public body or court, where we are required to do so by applicable law or regulation or at their request.

 

We have safeguards in place to secure your personal data when transferred outside of the United Kingdom (UK). The level of data protection in certain countries outside the UK does not conform to the level of data protection for personal data currently applied and enforced within the UK. We therefore use the following safeguards, as required by law, to protect your personal data in case of such transfers:

  • Data is transferred from Novo Nordisk entity in UK to Novo Nordisk entity outside UK. The transfer is to a Novo Nordisk entity covered by Novo Nordisk’s Binding Corporate Rules, available here
  • The destination countries are deemed by the Information Commissioner’s Office (ICO) to have an adequate level of protection of personal data.
  • We have entered into International Data Transfer Agreement 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.

We will only retain your personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal or regulatory requirements.

You are entitled to know whether we hold personal data about you and, if we do, obtain insight to that data and require the data to be corrected, if inaccurate.

You are also entitled to know the purpose(s) and you may object to Novo Nordisk’s use of your personal data and require such data erased. please contact us via our privacy mailbox privacyuk@novonordisk.com if you wish to obtain insight in your personal data or if you have any concerns in this regard.

Your rights to access, change or move your information are limited, as we need to manage your information in specific ways in order for the research to be reliable and accurate. If you withdraw from the study, we will keep the information about you that we have already obtained. To safeguard your rights, we will use the minimum personally identifiable information possible. 

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.

If you are not satisfied with our response or believe we are processing your personal data in a way that is not lawful you can complain to the Information Commissioner’s Office (ICO) at https://ico.org.uk/concerns/.

If you have any questions about this privacy policy, if you want to obtain insight in any personal data held about you, or if you have any concerns regarding Novo Nordisk’s use of your personal data you may contact us via privacyuk@novonordisk.com

April 2025