Toujeo Coach Privacy Statement

This Privacy Statement provides information on how we will collect and process your personal data as part of providing the Toujeo COACH programme (“Programme”). The Programme is developed and owned by Aventis Pharma Limited trading as Sanofi of 410 Thames Valley Park Dr, Earley, Reading, RG6 1PT (“Sanofi”) and run by Ashfield Healthcare Limited (“Ashfield”) on behalf of Sanofi. Except for the limited circumstances described in “How your data is shared” below, your personal data will not be shared with Sanofi. However, as Sanofi is responsible for the Programme, Sanofi are the controllers responsible for your personal data. The NHS or an NHS body may also be a controller of your personal data – please refer to their privacy policy for more information on this.

The data collected about you

For the purposes of providing the Programme, Ashfield will collect and process personal data relating to patients and their referring healthcare professional (if provided) such as: (i) basic identification and contact data supplied as part of patient registration or otherwise in connection with the provision of the Programme; (ii) health data such as information about the patient’s health and any other medical information that may be provided or collected for the purposes of providing the Programme (including data collected as part of questionnaires conducted over the phone during the coaching calls); (iii) usage data relating to the uptake and use of the Programme; and (iv) safety data reported during the Programme as detailed further below. Phone calls with Ashfield are also recorded for training and monitoring purposes – your agreement to this will be sought on each call. However, Ashfield may not be able to proceed with the call if you do not agree to this.

How your data is used

Your personal data will only be used for the purposes described below. We have also identified the legal grounds we rely on to use your data in this manner.

 Purpose  Type of data  Legal ground for processing

To provide the Programme, which may include contacting you by telephone to obtain your feedback on the Programme

  • Basic identification and contact data
  • Health data
  • Processing is necessary for Sanofi’s legitimate interests in providing the Programme
  • Processing is necessary for the provision of health or social care or treatment

To administer and monitor the uptake and performance of the Programme

  • Basic identification and contact data
  • Health data
  • Usage data
  • Processing is necessary for Sanofi’s legitimate interests in providing the Programme and monitoring the uptake of the Programme, delivery patterns and performance
  • Processing is necessary for the provision of health or social care or treatment
To comply with legal obligations to monitor the safety of Sanofi’s medicines
  • Safety data
  • Processing is necessary for compliance with Sanofi’s legal obligations to collect and report such information to regulatory authorities
  • Processing is necessary for reasons of public interest in the area of public health

 

How your data is shared

Other than as described below, Ashfield will not share your personal data with Sanofi or any other third parties, unless: (i) you have granted specific permission to do so; (ii) when this is required by law; or (iii) in response to a court order or request from a regulator, government body or law enforcement agency.

Ashfield may share your personal data with the following parties, but only for the purposes described in the table above:

  • its group companies involved in the provision of the Programme;
  • certain external service providers who assist Ashfield in providing the Programme, such as IT service providers;
  • where patients agree, with their referring healthcare professional for the purpose of providing information on their progress through the Programme; and
  • if you (or any other person) report that you (or someone else) have experienced a side effect while taking a Sanofi product, Ashfield may share this safety-related information along with any relevant personal data, which will be in a pseudonymised form (see below for more information on what this means) unless you agree otherwise (referred to as “Safety Data”), to the product safety monitoring team at Sanofi. Sanofi will use this Safety Data for the sole purpose of evaluating the safety of its products, which may include: (i) contacting the patient, their GP or their referring healthcare professional to discuss the data; (ii) sharing the data with Sanofi’s contractors who assist Sanofi in evaluating the safety of its products; and/or (iii) sharing the data with national and international health authorities and regulatory bodies (in an anonymised form wherever practical).

So that Sanofi can administer and monitor the uptake and performance of the Programme, Ashfield will also provide Sanofi with reports containing pseudonymised data relating to patients (“Performance Reports”). Where data has been pseudonymised, it means that Sanofi will not be able to identify you directly from the data/reports as information that identifies you (such as names, dates of birth etc.) will be removed or replaced with a reference number. Sanofi may share data from Performance Reports with its group companies and/or external third parties.

Some recipients of Safety Data and Performance Reports may be located in countries outside the European Economic Area (“EEA”) which do not ensure the same level of personal data protection as the country where you are located. Whenever Sanofi transfers data outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring safeguards are implemented, such as standard contractual clauses that have been approved by the European Commission. For more information about international transfers or how Sanofi uses the data in Performance Reports, see our Privacy Policy available at www.sanofi.co.uk/en/privacy-policy.

How your data is stored

Your personal data will only be retained for as long as is necessary to fulfil the purposes for which it was collected, as detailed above, including to satisfy our legal obligations. If you complete the Programme, the Programme ends or you decide to withdraw from the Programme, Ashfield (and any other parties who receive your personal data as part of the Programme) will cease all use of your personal data (with the exception of Safety Data and Performance Reports, which may be used for longer periods) as soon as reasonably possible but in any event within one month. However, Ashfield will retain a copy of your personal data for eight years and may keep it for longer periods where required by law, e.g. due to product safety requirements. For more information about how long Sanofi retains Safety Data and other pseudonymised data it receives, please see our Privacy Policy available at www.sanofi.co.uk/en/privacy-policy.

If Ashfield ceases providing the Programme on behalf of Sanofi, Ashfield may, on agreement with the NHS: (i) transfer your personal data to a new provider appointed by Sanofi; and/or (ii) continue to hold your personal data in its databases until the Programme is fully transferred and operational. If such a transfer does not take place within 12 months, Ashfield will delete your personal data as soon as reasonably possible unless required by law to retain it for longer. In case a transfer should occur, Sanofi will ensure that the new provider (i.e. a company who takes over from Ashfield) will be bound and operate according to the same strict standards for data protection as applied to Ashfield.

Further information

If you are looking for more information about Sanofi’s approach to international transfers, security measures, data retention periods or your rights under data protection laws, please see these sections in our Privacy Policy available at www.sanofi.co.uk/en/privacy-policy.

If you have any questions about this Privacy Statement or our data protection practices, including to exercise your rights under data protections laws (including to request access to your personal data), please contact Ashfield using the following details:

Email: Qualitydepartment@ashfieldhealthcare.com
Post: Quality Department, Ashfield House, Resolution Road, Ashby de la Zouch, Leicestershire, LE65 1HW

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