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 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.
For each country where Astellas has an obligation to disclose, we shall include the following (if relevant): (a) the scope of such disclosures (i.e. the type of individuals covered as well as the type of ToVs disclosed); (b) the legal basis of the underlying processing of personal data for such disclosures; (c) the country of disclosure; (c) the currency; (d) the timing; (e) 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 three legal bases applies in the country of a given HCP’s principal place of practice.
Healthcare Professionals 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.
| 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 |
|
Croatia
|
Consent |
|
Colombia
|
Consent |
|
Cyprus
|
Consent |
|
Czech Republic
|
Consent |
|
Denmark
|
Mandatory due to legal requirements |
|
Estonia*
|
Mandatory due to legal requirements |
|
Finland (Finnish)
|
Consent |
|
Finland (English)
|
Consent |
|
France
|
Mandatory due to legal requirements |
|
Germany
|
Consent |
|
Greece
|
Consent |
|
Hungary
|
Consent |
|
Iceland
|
Consent |
|
Ireland
|
Legitimate Interest
|
|
Indonesia
|
Consent |
|
Israel
|
Mandatory due to legal requirements |
|
Italy
|
Mandatory due to legal requirements |
|
Japan
|
Mandatory due to legal requirements |
|
Latvia*
|
Mandatory due to legal requirements |
|
Lithuania*
|
Mandatory due to legal requirements |
|
Luxembourg
|
Consent |
|
Malta
|
Consent |
|
Netherlands (Non R&D)
|
Mandatory due to legal requirements |
|
Netherlands (R&D)
|
Mandatory due to legal requirements |
|
North Macedonia
|
Consent |
|
Norway (Norwegian)
|
Legitimate Interest |
|
Norway (English)
|
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 |
|
Spain
|
Legitimate Interest |
|
Sweden (Swedish)
|
Consent |
|
Sweden (English)
|
Consent |
|
Switzerland (English)
|
Consent |
|
U.K.
|
Legitimate Interest |
|
USA
|
Mandatory due to legal requirements |
