Astellas and its affiliates globally are fully committed to increased transparency within the pharmaceutical industry and to strengthening the public trust in the relationships between pharmaceutical companies, healthcare professionals (HCPs) and healthcare organizations (HCOs).
Astellas will publicly disclose all transfers of value (ToVs) and/or collaborations with HCPs and will make any disclosure of such to relevant governmental bodies and/or industry associations in accordance with the transparency rules applicable to the country of HCPs’ principal place of practice which may include national legal or regulatory requirements, requirements from regional Codes of Practice for the pharmaceutical industry and/or from applicable local industry codes (Applicable Rules).
For countries that are members of the European Federation of Pharmaceutical Industries and Associations (EFPIA), further information on the Applicable Rules is available on the EFPIA’s Transparency website and on the websites of EFPIA relevant member associations from your country of residence. List of EFPIA member associations is available on https://www.efpia.eu/about-us/membership/.
For each country where Astellas has an obligation to disclose ToV, such disclosures will typically include the following (if relevant): (a) personal identifiers such as names and surnames and personal contact details of the HCPs concerned; (b) the scope of such disclosures (i.e. the type of individuals covered as well as the type of ToVs disclosed); (c) the legal basis of the underlying processing of personal data for such disclosures; (d) the country of disclosure; (e) the currency; (f) the timing; (g) the calculation of amounts disclosed.
Such disclosures of transfers of value and the associated processing of personal data will typically take place in accordance with one of the following legal bases, depending on which one of them applies in the HCP’s principal place of practice:
- the prior consent of the HCP;
- a legal requirement to provide such mandatory disclosures;
- Astellas’ legitimate interest to establish transparent relationships with healthcare professionals.
The second column in the table below specifies which one of the above legal bases applies in the country of a given HCP’s principal place of practice.
For countries that are members of EFPIA, information relating to ToV that Astellas has made to HCPs will be made publicly available for a minimum period of 3 years from the date of its publication, unless otherwise required by the Applicable Rules. Astellas will retain the information for a minimum of 5 years after the end of the calendar year to which the disclosure relates.
HCPs can exercise their data protection rights at any time including, where applicable, withdrawing any consent granted or objecting to any further processing by clicking here. If consent is withdrawn, personal information will be removed from the publication on Astellas’ webpage and/or other platforms as soon as reasonably practicable from the date such decision is communicated to Astellas.
Further information about how Astellas processes the personal information of HCPs is also available in Astellas HCP Privacy Notice.
| Country | Legal basis for disclosures of ToVs and/or collaboration with HCPs |
|---|---|
Australia |
Mandatory due to legal requirements |
Austria |
Consent |
Belgium |
Mandatory due to legal requirements |
Bosnia & Herzegovina |
Consent |
Brazil |
Mandatory due to legal requirements in one state |
Bulgaria |
Consent |
Chile |
Consent |
Colombia |
Consent |
Croatia |
Consent |
Cyprus |
Consent |
Czech Republic |
Consent |
Denmark |
Mandatory due to legal requirements |
Estonia* |
Mandatory due to legal requirements |
Finland |
Consent |
France |
Mandatory due to legal requirements |
Germany |
Consent |
Greece |
Consent |
Hungary |
Consent |
Iceland |
Consent |
Indonesia |
Mandatory due to legal requirements |
Ireland |
Legitimate Interest |
Israel |
Mandatory due to legal requirements |
Italy |
Consent |
Japan |
Mandatory due to legal requirements |
Latvia* |
Mandatory due to legal requirements |
Lithuania* |
Mandatory due to legal requirements |
Luxembourg |
Consent |
Malta |
Consent |
Mexico |
Consent |
Netherlands |
Mandatory due to legal requirements |
North Macedonia |
Consent |
Norway |
Legitimate Interest |
Philippines |
Mandatory due to legal requirements |
Poland |
Consent |
Portugal |
Mandatory due to legal requirements |
Romania |
Mandatory due to legal requirements |
Serbia |
Consent |
Slovakia |
Mandatory due to legal requirements |
Slovenia |
Consent |
South Korea |
Mandatory due to legal requirements |
Spain |
Legitimate Interest |
Sweden |
Consent |
Switzerland |
Consent |
Turkey |
Consent |
U.K. |
Legitimate Interest |
Ukraine |
Consent |
USA |
Mandatory due to legal requirements |