Protecting the Privacy of Personal Data

1. Introduction

In connection with your use of the Lundbeck UK LinkedIn page (https://www.linkedin.com/company/lundbeck-uk/), Lundbeck Limited (referred to as “Lundbeck”, “we”, “us”, “our”) may collect and hold personal data about you.

This policy explains how and why we collect personal data via the Lundbeck UK LinkedIn page as well as other legal information regarding our practices for this.

We have a separate privacy notice for users and visitors of our Lundbeck UK website, please see our Website Privacy Notice. Links to specific social media privacy notices can also be found on our website by clicking here: Privacy Notice: Instagram, or on our relevant social media pages or channels. Where we engage with you in your role as a healthcare professional, we may collect and process further information about you, please see our Privacy Notice: Healthcare Professionals for further information. If our website or these links are unavailable for any reason, please contact us using the details at the end of this notice and we can provide you with copies.

Lundbeck Limited (company number 01040798) is the data controller in relation to the processing activities described below. This means that we decide why and how your personal data is processed.

In processing your personal data, Lundbeck will always comply with applicable data protection legislation, including the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018.

The entity providing the LinkedIn platform / services to us is LinkedIn Corporation, located at 1000 W. Maude Avenue, Sunnyvale, CA 94085 USA (referred to as “LinkedIn”). LinkedIn will also be a data controller of any personal data collected via the LinkedIn platform. Please see the LinkedIn Privacy Policy for details and visit the LinkedIn Hub to review your privacy settings.

2. Personal data we collect and how we use it

The categories of personal data we may collect about you and the way in which we collect it are as follows:

Personal data you give to us: This is information that you voluntarily give to us via our Lundbeck UK LinkedIn page, including information provided when you visit our LinkedIn page, follow our LinkedIn page, by posting material or responding to posts, by contacting us in relation to our business or making an enquiry about our business, and/or engaging in correspondence with us by direct messaging or otherwise.

We may also ask you for information when you report a problem with our LinkedIn page. The categories of personal data that may be collected voluntarily includes: name, LinkedIn display name, email address, job title or status, location, address, contact telephone number, enquiry details, legal information relating to claims made by you, information relating to the sale of our products, or information contained in our correspondence or other communications with you about our business.

In case you report an adverse event, side-effect, or any product issue via our LinkedIn page, we will process your personal data in order to report to our Pharmacovigilance Department and the relevant health authorities as set out in applicable pharmacovigilance legislation. We will need to collect and process your name, location, health related information and contact information such as a phone number or email address. We will seek to anonymise any specific named users of our products when processing any sensitive personal data and always request your explicit consent before using any sensitive personal data about you. Please refer to our adverse event reporting policy.

Personal data we collect about you:

• We may collect any personal data which you allow to be shared that is part of your public profile and/or your own LinkedIn page (i.e. activities, age, gender, country, education, experience, skills and endorsements), type and version, time zone setting, browser plug-in types and versions, operating system and platform. 

• In addition to the above, LinkedIn page collects information on your interests and behaviour on LinkedIn via cookies. This personal data obtained via cookies may be used to provide targeted advertisements to you. If you would like to understand and control how LinkedIn uses data to show you advertisements, please see the LinkedIn Cookie Policy for details.

Your personal data may be converted into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from it. Aggregated data cannot be linked back to you as a natural person. We may use this data to use this data for analytical and research purposes.

Please see our Cookies Policy for more information.

3. How we use your personal data

The purposes for which we collect and use your personal data via our LinkedIn page and the legal basis under data protection laws on which we rely on do this are explained below.

Legitimate interests or that of a third party for the following purposes:

• to conduct data analysis to create and optimise our audience and targeting, to help us understand how our LinkedIn page is used and by whom, to research and understand demographics, preferences, interests, and behaviour, and to assist, enhance and personalise your user experience (including to make improvements to our LinkedIn page and related services by providing more relevant information and news);
• to correspond or communicate with you;
• for business administration, including statistical analysis;
• for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
• to comply with a request from you in connection with the exercise of your rights;
• to monitor the quality of our support to our LinkedIn page followers / connections and your communications with us, and to assess and improve our service where necessary;
• for the management of enquiries, queries, complaints, or claims;
• for prevention of fraud and other criminal activities; and
• for the establishment and defence of our legal rights.

Compliance with a legal obligation. We will use your personal information to comply with our legal or regulatory obligations: (i) to assist any public authority or criminal investigation body; (ii) to identify you when you contact us; and/or (iii) to verify the accuracy of data we hold about you.

4. Others who may receive or have access to your personal data

We may disclose your information to the following third parties:

• Group companies. We may share your personal data with other companies within the Lundbeck group. They may use your personal data in the ways set out in How we use your personal data, in connection with data analysis and to understand how our LinkedIn page is used.
• Health Authorities. In case you report an adverse event, side-effect, or any product issue via our LinkedIn page, we will share your personal data in order to report to our Pharmacovigilance Department and the relevant health authorities as set out in applicable pharmacovigilance legislation. We will seek to anonymise any specific named users of our products when processing any sensitive personal data and request your explicit consent before using any sensitive personal data about you. Please refer to our adverse event reporting policy.
• Our suppliers and service providers. We may disclose your information to our third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud service providers (such as hosting and email management), IT providers, professional advisors (including accountants and lawyers), advertising and marketing agencies, communication fulfilment service providers, and administrative service providers. When we use third party service providers, we only disclose to them any personal data that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
• Business sale or restructure. We may transfer your personal data to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. It also includes in the event of any liquidation, dissolution, or administration.
  
• Legal obligation. We may also transfer your personal data if we're under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers.

 
When disclosing your personal information to third parties, we will always take steps with the aim of ensuring that your privacy rights continue to be protected.

5. Storage of your personal data

All personal data you provide to us is stored on our secure servers which are located within the United Kingdom and/or the European Economic Area (EEA).

If at any time we transfer your personal data to, or store it in, countries located outside of the United Kingdom or the EEA (for example, if our hosting services provider changes) we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. This is because some countries do not have adequate data protection laws equivalent to those in the United Kingdom and EEA.

If your personal data is transferred to other companies in the Lundbeck group, the transfer will be based on the Lundbeck Intra Group Agreement as applicable from time to time. The current agreement is based on the EU standard contractual clauses.

6. Retention of your personal data

If we collect your personal data, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. Lundbeck will keep your personal data in an identifiable format for as long as reasonably necessary for the purposes for which it was collected or received unless we believe that the law requires us to preserve it.

If you have made a complaint, enquiry or contacted us via our LinkedIn page, we will store your personal data for as long as is reasonably required to deal with your enquiry or to resolve your complaint. We review the information submitted to us via the direct message function on our LinkedIn page on an annual basis and delete any personal data that is no longer necessary for us to retain.
When it is no longer necessary to retain your personal data, we will delete the personal data that we hold about you from our systems. After that time, we may aggregate the data (from which you cannot be identified) and retain it for analytical purposes.

The exceptions to the above are where:

• we need your personal data to establish, bring or defend legal claims or to comply with a legal or regulatory requirement;
• the law requires us to hold your personal information for a longer period, or delete it sooner;
• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law, or you exercise your right to require us to retain your personal information for a period longer than our stated retention period (see Erasing your personal data or restricting its processing below); or
• in limited cases, the law permits us to keep your personal data indefinitely provided we put certain protections in place.

7. Security and links to other sites

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our LinkedIn page and any transmission is at your own risk. Once we have received your personal data, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.

Our LinkedIn page and/or our posts may contain links to other websites run by other organisations. This policy does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our LinkedIn page from a third party website, we cannot be responsible for the privacy policies and practices of the operators of that third party website and recommend that you check the policy of that third party website.

8. Your rights

In the UK and EEA, you have certain rights in relation to your personal data under data protection law and these are described below. Please note that we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal data.

• Right of access. You have the right to request access to the personal data Lundbeck processes about you. We may not be able to provide you with a copy of your personal data if this concerns other individuals or we have another lawful reason to withhold that information.
• Right to rectification. You have the right to rectification of inaccurate personal data concerning you, including completion of incomplete personal data. If you discover that any of the other information we hold is inaccurate or out of date, please let us know.
• Right to erasure or restriction of processing. Under certain circumstances, you may ask for your personal data to be removed from our systems. Unless there is a reason that the law allows us to use your personal data for longer, we will make reasonable efforts to comply with your request. You may also ask us to restrict processing your personal data where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations, we may only process your personal data whilst its processing is restricted if we have your consent or are legally permitted to do so, for example, for storage purposes or in connection with legal proceedings.
• Right to data portability. Where processing is based on a consent or a contract and the processing is carried out by automated means, you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format. You have the right to ask us to transmit this personal data to a third party and we will do so if technically possible. We may not provide you with a copy of your personal data if this concerns other individuals or we have another lawful reason to withhold that information.
• Right to object. Where we rely on your legitimate business interests as the legal basis for processing your personal data for any purpose(s), you may object to us using your personal data for these purposes. Except for the purposes for which we are sure we can continue to process your personal data, we will temporarily stop processing your personal data in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
• Withdrawing your consent. Where we rely on your consent as the legal basis for processing your personal data, you may withdraw your consent at any time. If you withdraw your consent, our use of your personal data before you withdraw is still lawful.
• Automated decisions. In certain circumstances, you may contest a decision made about you based on automated processing.
  If you want to exercise any of your rights as described above, please email or write to us using the contact details at the end of this policy. 

9. Complaints

If you wish to file a complaint regarding Lundbeck's processing of your personal data, you can email or write to us using the contact details at the end of this policy.

You also have the right to complain to the relevant data protection authority, which in the UK is the Information Commissioner's Office (ICO), if you are concerned about the way that we have processed your personal data.

Information Commissioner's Office,
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone Number: 0303 123 1113
Website: https://ico.org.uk/

10. Changes

We may review this policy from time to time and any changes will be notified to you by posting an updated version or updated link on our LinkedIn page. Any changes will take effect 7 days after the date on which we post the modified terms / link on our LinkedIn page. We recommend you regularly check for changes and review this policy whenever you visit our LinkedIn page. If you do not agree with any aspect of the updated policy, you must immediately notify us and cease using our services / LinkedIn page.

This policy was last updated on [18 June 2021].

11. Contact

If you have any questions regarding this privacy policy or Lundbeck’s processing of your personal data, please contact our Data Protection Officer using the details below.

• Email: Our email address for data protection queries is dataprivacy@lundbeck.com.
• Post: If you wish to write to us, please write us at Iveco House, Station Road, Watford, Hertfordshire, England, UK WD17 1ET.
• Phone: If you would prefer to speak to us by phone, please call 01908 649 966.

12. Disclaimer

• Any information on diseases and treatments available on our LinkedIn page is intended for general guidance only and must never be considered a substitute for advice provided by a doctor or other qualified healthcare professional.
• Always seek the advice of your physician or other qualified health care professional with questions you may have regarding your medical condition.
• Although Lundbeck takes all reasonable care to ensure that the content of its LinkedIn page is accurate and up-to-date, please note that all information contained on it is provided on an ‘as is’ basis.
• Lundbeck makes no warranties or representations of any kind concerning the accuracy or suitability of the information contained on its LinkedIn page.
• Lundbeck may at any time and at its sole discretion change or replace the information available on its LinkedIn page.
• To the extent permitted by applicable laws, Lundbeck shall not be liable for any direct, incidental, consequential, indirect or punitive damages arising out of access to or use of any content available on its LinkedIn page, regardless of the accuracy or completeness of any such content.
• Lundbeck disclaims any control over, relationship with, or endorsement of views expressed by other LinkedIn users.
• Any links to other third-party websites are provided only as a convenience and Lundbeck encourages you to read the privacy statements of any third-party websites.
• All comments will be regularly reviewed and monitoring by Lundbeck and may be deleted if deemed inappropriate. Comments which are off-topic, offensive or promotional will be removed.
• Any comments/posts from members of the public do not necessarily reflect the views of Lundbeck.