Privacy Statement

ABPI Code and COCIR relevant contracts and forms

 

Bayer plc, 400 South Oak Way, Green Park, Reading RG2 6AD (hereinafter “us”, “our” and “we”), in its capacity as controller for the processing of your personal data, wishes to provide you with information on the processing of your personal data.

 

1 Purpose of processing and categories of personal data

 

We will process your personal data for some or all of the following purposes:

 

(i) Fulfilling ABPI/COCIR Code requirements

 

We will process the personal data that you provide to us on the ABPI/COCIR relevant contract or form to fulfill our regulatory reporting requirements under the ABPI Code of Practice/COCIR including disclosure of any “transfers of value” (i.e. payments, including any travel expenses and fees for service and hotel accommodation) that are made to you. We will not disclose such transfers of value on an individual basis unless you have provided your consent for us to do so.

 

(ii) Administering attendance at the event

 

We will use the personal data that you provide to us on the ABPI/COCIR contract or form to administer your attendance at the event for which you have registered, e.g. by creating materials relating to the event (badges, attendance lists etc.), organizing any appropriate accommodation, meals and processing travel expenses (if offered as part of the event). We will also use your personal data to send you information about the event (by email, text and other messaging system) including reminders about the event, logistics for registration, and post meeting follow up, which may include feedback forms and presentation slides.

 

(iii) Fulfilling our financial reporting requirements

 

We will use the personal data that you provide to us on the ABPI/COCIR relevant contract or form to fulfill our financial reporting requirements under relevant tax and accounting laws.

 

(iv) CRM systems

 

We maintain customer relationship management systems (CRM systems) where we store the contact information of all our customers. We will use this information in order to be able to better understand your interests, this includes profiling your personal data to provide targeted communications to you, and inform you about our products and services that might interest you as well. Furthermore, we are able to better provide you with support, if needed.

 

2 Special categories of personal data

 

Please note that we process the following special categories of personal data:

Special category Description
Your health status and/or your religious belief If you provide us with information regarding your choice of food in the context of an event for which you have registered (e.g. kosher meal or ingredients to which you are allergic)

3 Transfer of personal data

 

3.1 Commissioned processing

For the processing of your personal data, we will to some extent use specialized service contractors who act as our data processors. Such service contractors are carefully selected and regularly monitored by us. They will only process personal data in accordance with our instructions and on the basis of an appropriate data processing agreement.

 

3.2 Third parties

We share your personal data with the following third parties for the following purpose:

 

Third Party Scope and purpose of transfer
Events organisers Where we have instructed an events’ organiser to administer an event and you have registered an interest with Bayer to attend the event, we will provide your personal details to the event organiser.
Your health status and/or your religious belief Where we have offered and you have requested accommodation for the purpose of attending the event for which you have registered, we will provide your personal details to the hotel that we have arranged will provide accommodation for the event
Travel Providers Where we have offered to organise your travel, we will provide your personal details to third party travel providers.
 
4 Retention period

 

In order to fulfill Bayer’s financial reporting requirements your personal data will be stored for a period of seven (7) years following the year end

 

(i) in which the event, for which you are registered to attend, or

(ii) commencement of the activity or particular for which you have received financial support took place.

 

However, where no financial support has been made to you or your institution, your personal data will be stored for a period of five (5) years following the year end in which the event took place to fulfill Bayer’s ABPI Code obligations.

 

5 Legal basis for processing your personal data

 

 

Purpose Legal basis Explanation Provision of personal data required Consequences of failure to provide personal data
Administering the event Art. 6(1)(b) General Data Protection Regulation For personal data necessary for the performance of a contract with you. Yes You will not be able to attend the event or be provided with ancillary services (e.g. accommodation, expenses)
  Article 6(1)(a) General Data Protection Regulation Where you chose to provide special categories of personal data, we obtain your consent No We are not able to provide you with your choice of food (e.g. kosher meal or ingredients to which you are allergic)
ABPI requirements Article 6(1)(f) General Data Protection Regulation The fulfill ABPI reporting requirements Yes You will not be able to attend the event or receive the requested financial support
Financial reporting requirements Article 6(1)(f) General Data Protection Regulation To fulfill tax and accounting reporting requirements Yes You will not be able to claim travel expenses or financial support and we will not be able to contract with you
  Article 6(1)(c) To fulfil a legal and compliance obligation Yes You will not be able to attend the event or receive the requested financial support
CRM system Art. 6(1)(f) General Data Protection Regulation Manage our interactions with you and fulfill audit and compliance requirements Yes You will not be able to attend the meeting and we cannot send you customized information
 
6 Information regarding your rights

 

You have the right to request information from us about your personal data, access to and rectification or erasure of personal data or restriction of processing concerning your personal data or to object to processing as well as the right to data portability. You also have the right to lodge a complaint with the data protection supervisory authority. You may at any time withdraw any consent you have given without affecting the lawfulness of processing before the withdrawal.

 

For any questions you may have with respect to data privacy or if you wish to exercise your rights, please contact our company data protection officer:

 

Data Protection Officer

Legal and Compliance Department

Bayer plc

400 South Oak Way

Green Park

READING

Berkshire

RG2 6AD

Telephone: +44 (0)118 206 3000

dataprotection-uk-eire@bayer.com

 

This privacy statement was drafted: 25 February 2019 (version 2)