Privacy Policy | Eisai Europe

To access the privacy statements of other Eisai Group entities within the EMEA region, please click on the relevant country or countries listed below.

Eisai privacy statement

Eisai Europe Limited and its UK registered subsidiaries (“Eisai” or “we”) are located at the EMEA Knowledge Centre, Mosquito Way, Hatfield, Herts, AL10 9SN.

This privacy statement is an important document which explains how we collect and use any personal data. Please select the relevant option from the list below to read the applicable privacy statement which will explain how we will use your personal data.

If you have any queries about how Eisai handles your personal data which are not covered by this privacy statement please contact Data_Protection_EMEA@Eisai.net

Eisai’s GDPR Representative pursuant to Article 27 of the GDPR is Eisai GmbH of Edmund-Rumpler-Straße 3, 60549 Frankfurt, Germany, who can be contacted at this address or by e-mail on datenschutz@eisai.net

1.1 I am applying for a job at Eisai

This section applies if you are applying for a job at Eisai.

1.1.1 When do we collect information about you?

We collect information about you when you:

Provide your contact details to us,
Send us your CV or you apply for a role,
Respond to a social media post/advertisement on new job opportunities,
Register to receive alerts on new job opportunities, or
You apply via a recruitment agency or an existing staff member refers you for a position.

We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies.

1.1.2 What information do we collect about you?

We only collect information that is relevant for recruitment purposes and this may include:

Home address, postcode, contact number(s) and email address
Work contact number(s) and email address
Date of birth
Work history of current and previous employers, job titles, job duties, dates of employment, reason for leaving previous employment
Academic qualifications and professional memberships
Passport and UK work permit and/or visa information
Photograph(s)
Current salary, current employment benefits and notice period
Your professional training history and training plans
Notes from our face-to-face, video or telephone interviews with you
Results from any tests undertaken as part of the recruitment process
Results from checks performed as part of the recruitment process, including criminal records checks, security checks and driving licence checks
Employment or character references
Driving licence details
National Insurance number
Disability and other health conditions you tell us about
Information about your visits to our website (please see ‘I am using Eisai websites’)

In addition, we may ask questions about race/ethnic origin, religious beliefs, sexual orientation, gender identity, social mobility, and disability status for the purpose of the monitoring and promotion of equality of opportunity at Eisai. This data is collected on a voluntary basis and will have no impact on your application.

If you do not want to provide any of the information we are requesting, please inform the recruitment agency or Eisai contact you are working with. Alternatively, please contact the Eisai Data Protection Officer and Eisai Data Protection Team by using the contact details given below.

1.1.3 How do we use your personal data?

The information we collect from you will only be used to consider your application, ascertain your suitability for the role you are applying for and, if requested, to send you job alerts. It will also be used to comply with relevant laws, such as the Equality Act 2010 for equal opportunity purposes and to monitor equal employment opportunity compliance. It may also be used to manage and administer an offer of employment or a contract.

The legal bases we rely on to process your personal data are compliance with a legal obligation and carrying out our legal obligations as an employer under applicable laws (such as under the Equality Act 2010 and making any reasonable adjustments to enable you to attend an interview), performance of a contract and the legitimate interests of Eisai, specifically, Eisai’s legitimate interest in recruiting staff for its business, monitoring and promoting equality of opportunity in Eisai and reviewing and improving usage of this website.

The legal bases we rely on to process any special categories of personal data, such as race/ethnic origin, gender, religious beliefs, sexual orientation, health or disability status are articles 9(2)(b) and 9(2)(g) of the UK GDPR and Schedule 1 of the Data Protection Act 2018 which relate to our obligations under employment laws and the monitoring and promotion of equal employment opportunity.

Please inform us if there is any reason why you are unable to provide certain information that is requested from you during the recruitment process.

Please note that it may not be possible to progress your application if you do not agree to provide certain information, including information required in connection with criminal records and security checks.

1.1.4 How long we keep your data

If you are applying for a specific role at Eisai, we will keep your personal data relating to that application for 15 months after the end of the financial year in which you applied (the Eisai financial year ends on 31st March). For example, if you applied for a role in May 2021, we will keep your personal data for 15 months from 1 April 2022.

Please note that your profile on the Eisai online recruitment platform and your access to this profile will remain active for 24 months from the last time you log in, and the personal data you enter in your profile will be kept for that period. For example, if you last logged in to your profile on 1 May 2021 your profile will be accessible, and the personal data in your profile will be kept, until 1 May 2023.

Equality monitoring data will be retained in the recruitment platform for 6 months.

If you are offered employment or a contract role we will keep your personal data in line with the privacy policy applicable for employees and other Eisai staff (which can be viewed by selecting the hyperlink above).

Please click this link to read about your rights, sharing your data, changes to this privacy statement and how to contact us.

1.2 I am a healthcare professional (“HCP”)

This section applies if you are an HCP.

1.2.1 When do we collect information about you?

We collect information about you if you:

Interact with Eisai or our representatives;
Register your interest in, and/or participate in, events organised or sponsored by Eisai such as advisory boards, symposia and conferences;
Consent to receive promotional information from Eisai via electronic data communication methods (please also see section 1.2.3 A below);
Provide consultancy services to Eisai; interact with our social media posts;
Participate in clinical trials sponsored by Eisai;
Contact us to request medical information or to report potential safety or quality issues relating to any Eisai product;
Make a grant application for an investigator-initiated Study (IIS);
Take part in market research commissioned by Eisai; and/ or
Publish information, post or comment on any publicly available platforms (such as the Internet and social media platforms) which are relevant to any Eisai products and/ or therapeutic areas that Eisai is working in, or to any events organised by Eisai

We may also collect data from other sources such as official registers, hospital websites, healthcare provider directories, patient organisations and third parties providing data/information services.

1.2.2 What information do we collect about you?

We only collect information that is relevant for the purposes given in 1.2.1 and this may include:

Your name;
Your contact information such as your address, email or telephone number;
Your curriculum vitae and professional information such as areas of medical specialisation, presentations given, events attended, and publications produced;
Any significant financial relationship with Eisai as the Sponsor of a clinical trial;
Your past collaboration(s) with Eisai, and your participation in events organised or sponsored by Eisai such as your feedback and advice given at advisory boards;
Information you provide us with (e.g., about how you use and your experience of using Eisai products in your medical work/ practise with patients, or when making a medical information enquiry, dietary requirements when attending an Eisai event);
Dates and summary of your interactions with Eisai staff (such as sales representatives and medical staff);
Financial and banking information, but only if necessary to pay you for services provided to Eisai or to reimburse your agreed expenses incurred in providing services on Eisai’s behalf;
Only where you have agreed to receive promotional emails and to tracking of these promotional emails on an individual level, information about how you individually interact with these promotional emails (such as when you opened these emails) to assist Eisai to improve how it communicates with you. Otherwise, Eisai collects tracking information in aggregate form to improve how it communicates with healthcare professionals generally (please also see section 1.2.3 A below); and
Details of the information, post or comment made on any publicly available platforms relevant to any Eisai products and/ or therapeutic areas that Eisai is working in, or to any events organised by Eisai.

If you do not want to provide any of the information we are requesting, please inform the relevant Eisai contact you are working with or contact the Eisai Data Protection Officer and Eisai Data Protection Team by using the contact details given below.

1.2.3 How do we use your personal data?

The information we collect from you will only be used to:

Provide you with the information you have requested or to otherwise respond to your enquiry;
Comply with Eisai’s obligations under the Association of the British Pharmaceutical Industry (“ABPI”) Code of Practice / Irish Pharmaceutical Healthcare Association (“IPHA”) Code for the Pharmaceutical Industry and any other applicable pharmaceutical industry codes of practice, such as disclosing any payment or other transfer of value made to you;
Comply with Eisai’s legal obligations in relation to the reporting of safety and/ or quality issues relating to Eisai products;
To discuss the use of Eisai products on your patients;
Perform any contract with you, including to pay you any agreed consultancy service fee or honorarium and reimburse any agreed expenses, and book any required travel and accommodation;
To perform a clinical trial in which you are involved and to comply with Eisai’s obligations under clinical trial regulations, for example where investigator names are required for submissions of clinical trial results to regulators;
Inform our business development strategies and improve how Eisai communicates with you;
Identify opinion leaders in a therapeutic area that Eisai is working in;
Consider your IIS grant application;
Consider your potential involvement in Eisai’s future activities; and/or
To manage, invite you to and/ or seek your involvement in meetings or events organised or sponsored by Eisai that may be of interest to you.

The legal bases we rely on to process your personal data are, as applicable;

compliance with a legal obligation (including in relation to the reporting of safety and quality issues and to comply with Eisai’s obligations under clinical trial regulations),
performance of a contract (in relation to any contract that you have with Eisai),
any consents you have provided (such as for disclosing any transfer of value made to you for ABPI disclosure years prior to 2020 and for the IPHA disclosure years prior to 2021) and to receive any promotional materials by electronic data communication methods, and promotional email tracking),
the legitimate business interests of Eisai (such as to determine your potential involvement in future activities, to comply with Eisai’s obligations under the ABPI Code of Practice and IPHA Code of Practice (including to disclose to the ABPI any transfer of value made to you in ABPI disclosure year 2020 and onwards, and to IPHA for disclosure year 2021 and onwards), to inform Eisai’s business strategy, to conduct scientific research into the efficacy and safety of pharmaceutical products/ study drugs and to communicate with you in relation to relevant Eisai activities),
as is necessary for scientific research purposes (namely the use of your personal data in connection with the use, analysis and retention of patient personal data in the clinical trial) and
as is necessary for reasons of public interest in the area of public health (such as ensuring the high standards of quality and safety of medicinal products through reporting and monitoring drug safety and quality issues).

1.2.3A Your rights in respect of promotional information sent by electronic data communication methods, and right to object

Withdrawing or changing your consent – where you consent to being contacted for promotional purposes by electronic data communication methods (e.g. e-mail), you have the right to withdraw your consent to this. If you wish to withdraw or change any previous consent given to Eisai to contact you with promotional information via a certain electronic data communication method, please e-mail EMEA_Unsubscribe@eisai.net and please indicate by which electronic data communication method(s) you no longer consent to receive promotional information. Where you have agreed to promotional email tracking on an individual level and wish to withdraw your consent to this, or if you wish to stop email tracking at an aggregate level, please e-mail EMEA_Unsubscribe@eisai.net to request this.

Right to object – where Eisai processes your personal data on the basis of legitimate interests (such as for certain non-promotional purposes), you have the right to object. You also have the right to object to/opt out of any direct marketing communications. Please e-mail EMEA_Unsubscribe@eisai.net to opt out of receiving any such communications.

To object to Eisai processing your personal data on the basis of legitimate interests to disclose any payment or other transfer of value made to you to the ABPI/IPHA, please contact Eisai_UK_ROI_disclosure@eisai.net giving the reason(s) for your objection in order that these can be assessed and responded to by Eisai. Further information about your rights is given at the hyperlink at the end of this section 1.2

If you withdraw your consent to receiving promotional information by electronic means or otherwise object to communications from us, we may still need to send you important administrative messages, and other communications if we are required to do so by law.

1.2.4 How long we keep your data

If you are presenting in an event organised by Eisai, we will keep your data for the longer of the prescribed retention period given in the applicable law or code of practice covering transparency disclosure (for example 5 years in the UK) or the prescribed retention period given in the applicable financial legislation governing how long Eisai is required to retain financial records for tax purposes (for example 7 years in the UK). If you have been involved in a clinical trial sponsored by Eisai, we will keep your data for 25 years after the clinical trial has ended to comply with Eisai’s obligations under clinical trials legislation.
If you have made a grant application for an IIS, your data will be kept for 10 years and if Eisai made the grant, your data will be kept for 25 years after the study has ended.
If you contact us to request medical information, a copy of your request and Eisai’s response will be retained for 3 years from the date of your request.
If you contacted us about a medical or safety issue about an Eisai product we will keep your data for 15 years after any marketing authorisation for the product has lapsed as required by applicable laws.
If you operate in an Eisai therapeutic area and/or interact with Eisai team members, your data will be kept for 3 years from the last interaction with an Eisai team member such as a face-to-face meeting, telephone call or longer if you have consented to receive promotional information via electronic data communication methods.
Any information we obtained from sources such as official registers, hospital websites, healthcare provider directories, patient organisations and third parties providing data/information services, we will keep as long as you continue to operate in that therapeutic area or until you object to this processing.
Any information derived from other publicly available platforms such as social media channels, will be deleted 2 years after the date of collection.

Please click this link to read about your rights, sharing your data, changes to this privacy statement and how to contact us.

1.3 I am a supplier of goods or services to Eisai

This section applies if you are or your company is, offering to supply, will supply or are/is supplying, goods and / or services to Eisai.

1.3.1 When do we collect information about you?

We collect information about you when:

You contact us to offer to supply goods or services to Eisai;
We request you to supply goods or services to Eisai; or
You contact us to supply goods or services to Eisai.

1.3.2 What information do we collect about you?

We only collect data that is relevant for purposes given in 1.3.1 and this may include:

Your name and names of any staff working for you or your company;
Your contact information such as address, email or telephone number;
Background checks;
Your past contact with Eisai; and
Financial and banking information.

If you do not want to provide any of the information we are requesting, please inform the relevant Eisai contact you are working with, or contact the Eisai Data Protection Officer and Eisai Data Protection Team by using the contact details given below.

1.3.3 How do we use your personal data?

The information we collect from you will only be used to:

Evaluate your suitability to supply goods or services for Eisai;
To comply with our legal obligations, including obligations under the Modern Slavery Act 2015 and the Bribery Act 2010 and any other applicable laws;
To comply with Eisai’s commitments under international programmes such as the United Nations General Compact;
To make payments to you for the goods and/ or services provided in accordance with the contract you have with Eisai; and/or
To perform the contract we have with you for the goods and/ or services.

The legal bases we rely on to process your personal data are, as applicable, compliance with legal obligations, and performance of the contract we have with you (to assess your suitability in relation to goods or services offered, prior to entering into the contract, and to perform the contract, including to make payment for goods or services provided under the contract), and the legitimate business interests of Eisai (to assess your suitability for the provision of goods or services in relation to future business needs).

1.3.4 How long we keep your data

If you have supplied goods and/ or services to Eisai, we will retain your data for up to 10 years from the date of the last communication under the contract. If you have contacted Eisai for any other reason in connection with the provision of goods and/ or services, we will retain your data for up to 10 years from the date of the last contact. Details of any payments made to you by Eisai in connection with goods and /or services that you have supplied to Eisai will be kept for 15 years after the year end of the financial year in which the last payment of/ for those goods and/ or services was made, in order to meet Eisai’s legal obligations across the EMEA region for accounting purposes.

Please click this link to read about your rights, sharing your data, changes to this privacy statement and how to contact us.

1.4 I am using Eisai websites

This section applies if you are using Eisai websites.

1.4.1 When do we collect information about you?

We collect information about you when:

You access Eisai websites;
You contact us or provide information via Eisai websites.

1.4.2 What information do we collect about you?

We only collect data that is relevant for purposes given in 1.4.1 above and this may include:

Information about your visits to Eisai websites (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths); and
Any other information that you may provide when contacting us through Eisai websites which could include your name, contact details such as your email address.

1.4.3 Cookies

Eisai websites use cookies. A cookie is a small file of letters and numbers which is downloaded onto your computer when you access and use the website. The cookies used on our websites are ‘essential’, ‘functional’ and ‘statistical’ cookies.

The essential cookies are necessary to safeguard the functionality and reliability of the website. The functional cookies enable us to analyse the use of the website in order to measure and improve performance. The statistical or analytical cookies collect information from our website visitors to enable us to count the number of visitors and to see how visitors use our websites; this helps us to improve the way that our website works.

1.4.4 How do we use your personal data?

The information we collect from you will only be used to:

Count the number of visitors, see how visitors use websites and to help us to improve our websites; and
Provide you with the information you requested.

The legal bases we rely on to process your personal data are your consent (for functional and statistical cookies) and the legitimate interests (for essential cookies) of Eisai; specifically, Eisai’s legitimate interests in reviewing and improving usage of websites and responding to contacts made by website users.

1.4.5 How long we keep your data

Information about your visit and general enquiries will be retained for up to 1 year from the date of your visit or request. Information in any cookies will be retained for 14 months

For more information on managing and deleting cookies for popular browsers, please see the following links:

• Google Chrome
• Mozilla Firefox
• Microsoft Internet Explorer
• Microsoft Edge
• Apple Safari

Please click this link to read about your rights, sharing your data, changes to this privacy statement and how to contact us.

1.5 I work for Eisai

This section applies if you are employed by, or working for Eisai, including permanent and fixed term employees, contractors, consultants or agency workers.

1.5.1 When do we collect information about you?

We collect information about you when:

You are employed by Eisai as a permanent or fixed term employee; or
You have agreed to provide services to Eisai as a contractor, consultant or agency worker.

1.5.2 What information do we collect about you?

We only collect data that is relevant for employment purposes and may include:

Name, home address, postcode, contact number(s) and email address
Date and place of birth
Work history of current and previous employers, job titles, job duties, dates of employment
Academic qualifications and professional memberships
Passport and UK work visa information (including birth certificate in absence of passport)
Photograph(s)
Current salary, current employment benefits and notice period
Your professional training history and training plans
Notes from our face-to-face, video or telephone interviews with you
Results from any tests undertaken as part of the recruitment process
Results from checks performed as part of the recruitment process, including criminal records checks and security checks
Employment or character references
Driving licence details (depending on band or role type)
National Insurance number
Health conditions you or someone on your behalf tells us about
Marital status
Next of kin and dependents
Vehicle registration number(s)
CCTV images and details of your visits to Eisai building(s)
Bank account details
Business travel details
Records from internal investigations, disciplinary and grievance processes
Performance and appraisal information
Gender
Any other data that you or someone on your behalf provides

We may also collect data related to your attendance and/or assistance at Eisai events, including photographs of you at these events, and related to your work at Eisai.

In addition, we may collect information about race/ethnic origin, religious beliefs, sexual orientation, gender identity, social mobility, and disability status for the purpose of the monitoring and promotion of equality of opportunity or treatment within Eisai. This data is collected on a voluntary basis and will have no impact on your employment with Eisai.

1.5.3 How do we use your personal data?

The information we collect from you will be used to comply with relevant laws, such as the Equality Act 2010, the Health and Safety at Work Act 1974 and to monitor and promote equality of opportunity or treatment. It may also be used to manage, facilitate and administer staff employment contacts and business operations at Eisai. It may also be used to promote Eisai (through social media and other media channels) and for internal communications.

The legal bases we rely on to process your personal data is to comply with our legal obligations (including our legal obligations as an employer under employment laws), to perform your employment contract, in connection with assessments of the working capacity of employees, with your consent in connection with mental health first aid, optional employment related benefits and promotional matters, and the legitimate interest of Eisai; specifically, Eisai’s legitimate interest in administering and managing its workforce.

The legal bases we rely on to process any special categories of personal data, such as race/ethnic origin, gender, religious belief, sexual orientation, health or disability status are articles 9(2)(b) and 9(2)(g) of the UK GDPR and Schedule 1 of the Data Protection Act 2018 which relates to our obligations under employment laws and the monitoring and promotion of equal employment opportunity or treatment.

1.5.4 How long we keep your data

All data held by the People Team will be kept for a period of 6 years after the end of the financial year (the Eisai financial year ends on 31st March) following termination of employment / engagement. You can delete your equality monitoring data from the employee management platform at any time.

If you are a member of the clinical trials team, your CV, job description and training record will be kept for 25 years after the end of the financial year following the termination of your employment / engagement to ensure compliance with clinical trial legislation. If you have undergone a health surveillance programme, that information will be held for 40 years or 6 years after the end of the financial year following termination of employment, whichever is longer.

Please click this link to read about your rights, sharing your data, changes to this privacy statement and how to contact us.

1.6 I am visiting Eisai premises

This section applies if you are visiting Eisai premises.

1.6.1 When do we collect information about you?

We collect information about you when you visit or invited to visit and when you connect to Eisai’s Wi-Fi network whilst at Eisai’s premises.

1.6.2 What information do we collect about you?

We only collect data that is relevant for the purpose give in 1.6.1 above and this data may include:

Name, address, contact number(s) and email address
Company you represent
Date and time of your visit
Purpose of your visit
Photograph(s)
Vehicle registration number(s)
When you connect to Eisai’s Wi-Fi network, your device name, IP address, MAC addresses, data/time of access, traffic types and data usage
CCTV images and details of your visits to Eisai building(s)
Any other data that you provide e.g. requests for disabled parking bay.

1.6.3 How do we use your personal data?

The information we collect from you will only be used to facilitate your visit to Eisai premises and to comply with legal obligations such as the Health and Safety at Work Act 1974.

The legal bases we rely on to process your personal data are to comply with our legal obligations, (where obtained) with your explicit consent, and the legitimate interest of Eisai; specifically, Eisai’s legitimate interest in ensuring effective, safe and secure access to its premises.

1.6.4 How long we keep your data

We will retain your data for 1 year after your visit to facilitate any further visits you may make within that time period and if you connect to Eisai’s Wi-Fi network your details will be held for 14 months. If you do not visit Eisai premises again and wish your data to be removed early, please let your host know or contact Eisai’s Data Protection Officer and Data Protection Team using the contact details given below.

Please click this link to read about your rights, sharing your data, changes to this privacy statement and how to contact us.

1.7 I am a patient in an Eisai sponsored clinical study

This section applies if you are a patient in an Eisai sponsored clinical study. You will also be provided detailed information in an Informed Consent Form/ Patient Information Sheet (ICF), which you should sign before you participate in a clinical study.

1.7.1 When do we collect information about you?

We collect information about you when you participate in an Eisai sponsored clinical study.

1.7.2 What information do we collect about you?

We only collect information that is relevant to the Eisai sponsored clinical study. The investigator site (hospital/clinic) conducting the clinical study may collect the following on Eisai’s behalf:

Name, address, contact number(s) and email address
Gender
Date of birth (if permitted in your country) and age
Ethnic origin
Health conditions
Height and weight
Medical history, procedures, test results, and other health data collected about your taking part in the study

To ensure privacy and the scientific integrity of the clinical study, your name and address will not be disclosed outside the clinic/hospital and you will only be identified by a code. This code will be attached to records or samples released to Eisai (sponsor of the study) and the service providers associated with the clinical study. Only the study doctor and authorised persons will be able to connect this code to your name by means of a list.

1.7.3 How do we use your personal data?

The information we collect from you will be used for clinical study purposes and for further scientific research. These uses will be explained to you in detail in the ICF.

Any of your medical records and the data collected for the clinical study may be looked at by:

Authorised persons from the study sponsor and/or the company organising the research and/or their associated companies; and/or
Monitors, auditors, representatives from laboratories, and other legitimate third-party contractors or consultants who are helping the study sponsor; and/or
Representatives from health/regulatory authorities such as the United States Food and Drug Administration (FDA); and/or
Ethics committees to check that the study is being carried out correctly.

The legal basis or bases we rely on to process your personal data will depend upon the country in which the clinic/hospital through which you would be participating in the study is located. The legal basis or bases will be one or more of the following:

consent from you;
Eisai’s legitimate interests (to conduct scientific research into the efficacy and safety of pharmaceutical products/ study drugs);
compliance with a legal obligation (under clinical trial regulations and in relation to the reporting of safety and quality issues);
necessary for reasons of public interest in the area of public health such as ensuring the high standards of quality and safety of medicinal products (in relation to the reporting of safety and quality issues);
scientific research.

1.7.4 How long we keep your data

All personal data collected about you during this study (other than samples) will be stored for at least 25 years to meet the requirements of clinical trial legislation, or longer where it is either used for further scientific research or where his is required by applicable laws. Samples may be stored for testing for up to 15 years after the completion of the study, or until the sample is gone (if before).

Please click this link to read about your rights, sharing your data, changes to this privacy statement and how to contact us.

1.8 I am interested in participating in an Eisai sponsored clinical study

This section applies if you are interested in participating in an Eisai sponsored clinical study and involved in Eisai’s patient recruitment activities.

1.8.1 When do we collect information about you?

We collect information about you in the context of Eisai’s clinical study patient recruitment activities.

1.8.2 What information do we collect about you?

We only collect information that is relevant to the clinical patient recruitment activities. The recruitment vendor or investigator site (hospital/clinic) performing the patient recruitment activities may collect the following on Eisai’s behalf:

Name, address, contact number(s) and email address
Gender
Date of birth (if permitted in your country) and age
Ethnic origin
Health conditions
Height and weight, medical history, procedures, test results, and other health data that may be relevant for the purposes of patient recruitment.

1.8.3 How do we use your personal data?

The information we collect from you will only be used for the patient recruitment activities and may be looked at by:

The company organising the patient recruitment activities (who is acting as Eisai’s data processor), and/or their associated companies; and/or
Hospital/clinic to connect you with the study site closest to where you live; and /or
Monitors, auditors, representatives from legitimate third-party contractors or consultants who are helping the study sponsor; and/or
Representatives from health/regulatory authorities such as the United States Food and Drug Administration (FDA); and/or
Ethics committees to check that the patient recruitment activities are being carried out correctly.

The legal basis or bases we rely on to process your personal data will depend upon the country in which you would be participating in the study is located. The legal bases or bases will be one or more of the following:

consent from you;
Eisai’s legitimate interests (to conduct scientific research into the efficacy and safety of pharmaceutical products/ study drugs);
necessary for reasons of public interest in the area of public health such as ensuring the high standards of quality and safety of medicinal products (in relation to the reporting of safety and quality issues).
scientific research.

1.8.4 How long we keep your data

We will not store or retain your personal data any longer than is necessary for the purposes for which the personal data is processed. The company organising the patient recruitment activities will retain your personal data until the clinical trial recruitment is completed. If you are successfully referred for a clinical study, you will be separately informed about how long we will be processing your data for the purpose of the clinical study. Please see ‘I am a patient in an Eisai sponsored clinical study’ section for more information.

Please click this link to read about your rights, sharing your data, changes to this privacy statement and how to contact us.

1.9 I am contacting you about a volunteering activity (hhc activity)

This section applies if you are contacting Eisai for any hhc activity in connection with Eisai’s human healthcare (hhc) mission.

1.9.1 When do we collect information about you?

We collect information about you when you contact us, when we contact you in relation to an hhc activity or when you participate in any hhc activity organised by us.

1.9.2 What information do we collect about you?

We only collect information that is relevant for the purposes of the hhc activity and this may include:

Name, address, contact number(s) and email address
Date of contact
Details of the requests
Details of the hhc activity and any photos taken
Any other information necessary to run or consider the hhc activity, and any contract we have for the hhc activity

1.9.3 How do we use your personal data?

The information we collect from you will be used to enable our employees to engage in the hhc activity and to keep a record of the hhc activities that we have carried out.

The legal bases we rely on to process your personal data are consent to perform any contract with you and for the purposes of the legitimate interest of Eisai; specifically, Eisai’s legitimate interest in administering its hhc projects and compliance with Eisai’s obligations under applicable pharmaceutical codes of practice (such as for disclosing any transfer of value made to you).

1.9.4 How long we keep your data

We will keep your information as part of the record of hhc activities we have carried out for 10 years from the date of request.

Please click this link to read about your rights, sharing your data, changes to this privacy statement and how to contact us.

1.10 I am a patient or other member of the public or follow Eisai social media channels

This section applies if you are a patient, a patient participating in a managed access programme (e.g. compassionate use), or other member of the public who requests medical information about, reports safety or quality issues or comments on any Eisai product in a public forum or therapeutic area in which Eisai has an interest or follows Eisai social media channels. If you are a healthcare professional, please also see I am a healthcare professional (“HCP”) section.

1.10.1 When do we collect information about you?

We collect information about you if:

your HCP applies on your behalf to include you in an Eisai managed access programmes or
you contact us to request medical information, or to report potential safety or quality issues, relating to any Eisai product or
you follow Eisai on social media or interact with our social media posts or
you comment in a public forum on any Eisai product or a therapeutic area in which Eisai has an interest.

Please note that Eisai cannot provide medical advice to members of the public and we will direct you to your HCP for medical advice and guidance. Medical Information can provide factual information that is available in the Patient Information Leaflet (“PIL”) to members of the public if this is relevant to your question.

1.10.2 What information do we collect about you?

We only collect information that is relevant for purposes given in 1.10.1 and this may include:

For managed access programmes, your initials, age, gender, health conditions;
Your name, social media handle;
Your contact information such as your address, email or telephone number;
Details of your request for medical information about an Eisai product;
Details of the potential safety or quality issue about an Eisai product that you are reporting;
Information about you or the other person who has taken the product (if reporting a potential safety issue), including age, sex, health condition, and the contact details of the healthcare professional who prescribed the product;
Details of your social media activity such as likes, click rates, re-shares, impressions etc, relating to Eisai social media posts, Eisai products or a therapeutic area in which Eisai has an interest.

1.10.3 How do we use your personal data?

The information we collect from you will only be used to:

Administer the managed access programme;
Respond to your request for medical advice by directing you to contact your HCP;
Respond to your request for medical information by providing factual information that is available in the PIL if this is relevant to your question;
Comply with Eisai’s legal obligations in relation to the reporting of safety or quality issues relating to Eisai products;
Inform our communications in respect of therapeutic area in which Eisai has an interest.

The legal bases we rely on to process your personal data are, as applicable, your consent to participate in the managed access programme, the legitimate business interests of Eisai (in relation to monitoring social media activity in respect of Eisai social media posts, responding to requests for medical information and informing how we communicate in respect of therapeutic areas in which Eisai has an interest), data that is manifestly made public, compliance with a legal obligation and reasons of public interest in the area of public health (in relation to the reporting of safety and quality issues).

1.10.4 How long we keep your data

If you participate in a managed access programme, your data will be retained for up for 25 years after the end of the programme. If you contact us to request medical information, a copy of your request and Eisai’s response will be retained for 3 years from the date of your request. If you contact us about a medical or safety issue about an Eisai product or your request for medical information contains a safety issue, we will keep your data for 15 years after any marketing authorisation for the product has lapsed as required by applicable laws. Any data obtained from a public forum about any Eisai product or a therapeutic area in which Eisai has an interest will be held for 3 years from the time we collected the data or longer if it is relating to a safety issue.

Please click this link to read about your rights, sharing your data, changes to this privacy statement and how to contact us.

1.11 I am a patient speaker or have been invited to speak at an Eisai event or am participating in an Eisai video

This section applies if you are a patient speaker or have been invited to speak at an Eisai event or are participating in an Eisai video.

1.11.1 When do we collect information about you?

We collect information about you if you:

Interact with Eisai staff members or our representatives;
Interact with our social media post;
Register your interest in, and/or participate in, events organised or sponsored by Eisai;
Are a patient speaker who shares your experience and your condition at an Eisai organised event such as an hhc event;
Agree to speak at an Eisai organised event such as employee benefit fair;
Participate in an Eisai video or any other material.

1.11.2 What information do we collect about you?

We only collect information that is relevant for purposes given in 1.11.1 and this may include:

Your name;
Your contact information such as your address, email or telephone number;
Details of your health, family members or any other information that you voluntarily share or make available to Eisai.

1.11.3 How do we use your personal data?

The information we collect from you will only be used to:

Facilitate your visit and access to the Eisai event and assist you with giving your presentation;
Facilitate the recording of a video that you are participating in;
Facilitate the production of materials in relation to the event that you are participating in (e.g. by taking photographs).

The legal bases we rely on to process your personal data are consent, to perform any contract with you and for the purposes of the legitimate interest of Eisai; specifically, Eisai’s legitimate interest in administering its hhc programme.

1.11.4 How long we keep your data?

We will keep your information for 2 years from the date you give your presentation. If you participate in an Eisai video or other material, we will keep this information for 6 years from the date of publication or any other time that we agree with you.

Please click this link to read about your rights, sharing your data, changes to this privacy statement and how to contact us.

2 Rights, sharing your data, changes to this privacy statement and how to contact us

2.1 What are your rights?

In respect of the personal data that we have collected about you, you have the right, in certain circumstances, to:

Request access to this personal data,
Request the correction of this personal data,
Request the erasure of this personal data,
Request that we restrict how we process this personal data,
Object to how we process this personal data, and
Request a copy of the personal data you have provided to Eisai in an electronic format.

We will consider any such request made in accordance with applicable data protection laws. However, please note that there may be a legal or other valid reason why Eisai may not be able to process your request in whole or in part.

Where you have requested that we delete your personal data, we will either delete or anonymise this personal data. Where it is not possible for us to delete or anonymise your personal data we will take steps to put the personal data beyond use where it will be securely stored until such time as we are able to delete or anonymise it.

You can also withdraw your consent to the processing of your personal data at any time but this will not affect the lawfulness of the processing before that time.

You have a right to complain to the Information Commissioner’s Office (ICO) if you are not satisfied with the way we are handling your data. You can write, email or call the ICO by visiting their “contact us” page via this link:

https://ico.org.uk/global/contact-us/

If you would like to make a request to access, correct or delete the personal data we have collected about you, please send an email to Data_Protection_EMEA@Eisai.net.

2.2 Who do we share your data with?

We may share your data with:

Authorised teams and individuals within Eisai;
Other entities in the Eisai group (also see 2.3 below);
Third-party suppliers or potential suppliers who provide related services or business systems used by to Eisai to securely process your data;
Our regulators and/ or any other competent authority who have powers to request disclosure of personal information we hold;
the Association of the British Pharmaceutical Industry (“ABPI”), the Irish Pharmaceutical Healthcare Association (“IPHA”) or another relevant Pharmaceutical Industry body when disclosing any payment or other transfer of value made to a healthcare professional;
Professional advisors;
Pharmaceutical companies with whom Eisai have a co-promotion/ co-marketing relationship;
A purchaser or potential purchaser of any business or asset that we are selling (or are contemplating selling); and/or
Third parties where required by law (for example HMRC, UK Border Agency).

2.3 Sharing your data outside the United Kingdom

Personal data we collect from you may be transferred to countries outside the UK where Eisai has operations. As an international organisation Eisai operates in a number of countries including in the European Economic Area (EEA), Japan and USA. The list of countries where the various Eisai Group entities are located is available here: https://www.eisai.com/company/profile/group/index.html

We also use third party suppliers to provide a number of business tools, including the tools that we use for recruitment, human resource management, procurement, finance, clinical trial service providers and we share your personal data with these third-party service providers. Some of these providers may be outside the UK.

The UK has recognised that the data protection laws of (i) countries in the EEA and (ii) those countries that the European Commission has determined ensure an adequate level of protection for personal data, all provide the same level of protection for your personal data as required by UK laws, and therefore do not require any specific authorisation.

Some countries outside the UK and EEA may not have a data protection supervisory authority and/ or data processing principles and/ or data subject rights might not be provided for in that country, so you might not be able to enforce your rights in the same way, and recipient organisations may not be legally required to secure your data to UK and EEA standards. Eisai shall take all necessary steps to ensure that your personal data is protected in such circumstances.

We maintain processes to ensure that any third party we are using and who will process your data, including other Eisai entities, will comply with same standards to protect your data as in the UK. This includes carrying out necessary due diligence on such third parties (for example, the security measures they have in place for protecting data), and entering into contracts which contain adequate contractual measures to protect data, which can include contracting on standard contractual clauses which have been approved by UK and EU authorities as providing adequate protection for your personal data.

Eisai may where applicable transfer personal data to competent public authorities in third countries where required to obtain product approvals and for purposes of safety reporting on the basis that the transfer is necessary for important reasons of public interest as those interests are recognised by law.

2.4 Changes to this privacy statement

This privacy statement may be updated by Eisai from time to time; please visit the www.eisai.eu website at any time to view the latest version.

This privacy statement was last updated in October 2024.

2.5 How to contact us

You can contact Eisai’s Data Protection Officer and Data Protection Team by using the email address Data_Protection_EMEA@Eisai.net or by writing to the address given above.