1. Statement of intent
From time to time, you will be asked to submit personal information about yourself (e.g. name and email address etc) in order to receive or use services on our website. Such services include newsletters and competitions, live chats and message boards and personalised services.
By entering your details in the fields requested, you enable UCB Pharma and its service providers to provide you with the services you select. Whenever you provide such personal information, we will treat that information in accordance with this policy. Our services are designed to give you the information that you want to receive. UCB Pharma will act in accordance with current legislation and aim to meet current Internet best practice.
2. Information on visitors
Visitors to each of our Web sites can access the Web site's home page, and browse some areas of the site, without disclosing any personally identifiable information. We do track information provided to us by your browser, including the Web site you came from (known as the "referring URL"), the type of browser you use, the time and date of access, and other information that does not personally identify you. On some of our sites, you must register to access portions of the site.
3. Submitting personal information
When you supply any personal information to UCB Pharma (e.g. for competitions, chats or UCB Pharma's personalised services) we have legal obligations towards you in the way we deal with that data.
We must collect the information fairly, that is, we must explain how we will use it (see the notices on particular web pages that let you know why we are requesting the information) and tell you if we want to pass the information on to anyone else.
In general, any information you provide to UCB Pharma will only be used within the company. It will never be supplied to anyone outside UCB Pharma without first obtaining your consent, unless we are obliged by law to disclose it.
We will hold your personal information on our systems for as long as you use the service you have requested, and remove it in the event that the purpose has been met, or, in the case of a personalised service you no longer wish to continue your registration as a personalised user.
Where personal information is held for people who are not yet registered but have taken part in other UCB Pharma services (e.g. competitions), that information will be held only as long as necessary to ensure that the service is run smoothly. We will ensure that all personal information supplied is held securely, in accordance with the Data Protection Act 1998.
If you are notified on a UCB Pharma site that your information may be used to allow UCB Pharma to contact you for "service administration purposes", this means that UCB Pharma may contact you for a number of purposes related to the service you have signed up for. For example, we may wish to provide you with password reminders or notify you that the particular service has been suspended for maintenance.
We will not contact you for promotional purposes, such as notifying you of improvements to
the service or new services, unless you specifically agree to be contacted for such purposes at
the time you submit your information on the site, or at a later time if you sign up
specifically to receive such promotional information.
UCB Pharma collects personally identifiable information from Web site visitors only when it is voluntarily provided. On the registration screen, we clearly label which information is required for registration, and which information is optional. You will also be given a choice about whether or not you want to receive e-mail information.
We also collect information that you voluntarily provide to us through responses to surveys,
questionnaires and the like.
When UCB Pharma receives personally identifiable information, we may use it for reasonable business purposes, just as non-Internet businesses do. For example, we may use this information to contact you, via e-mail or regular mail, to provide you with information we believe may be of interest. It might also be used for compiling data and analyses to understand and serve our customers' needs.
When you are using a discussion or message board on our Web sites, you are posting a message and your user name, which is available for all registered users to see. You should not post any information you want to keep private to a discussion board or other public forum on our Web sites.
We may also ask you to provide additional information such as your email address if you want to obtain additional services or information, or to resolve complaints or concerns.
The 'information padlock' signpost
The 'information padlock' signpost has been devised by the Office of the Information Commissioner, for use by organisations that request personal information.
Wherever the signpost appears, UCB Pharma will provide an explanation of why the information is requested, or will give directions to where such an explanation is provided.
4. Sensitive Data
The collection and use of Sensitive Data carries with it special obligations and responsibilities in order to maintain the data's security, integrity and privacy.
UCB Pharma will ensure that collection and handling of any sensitive data is carried out with the explicit consent of the user and within the Data Protection Act (1998)
Sensitive Data will not made available for External Distribution outside of UCB Pharma
5. Combining Data
We may create combined data about all visitors to our Web sites for product development and improvement activities. We also use it for market analysis. We may provide information from our Web sites in combined form, with any personal identifying information removed, to third parties.
When combined health information is provided, we pool it from many individual records and strip it of any data that could be used to identify an individual before it is used.
Depending on our agreement with the third parties, we may or may not charge for this information
6. Third Parties
In addition to combining information, we may share some kinds of information with third parties as described below.
· Companies and People Who Work for Us: We sub-contract with other companies and individuals to help us provide services. If you are a healthcare professional, we may validate your professional credentials and other information against databases that list licensed healthcare professionals. These companies and individuals may have limited access to some of the personal information we maintain about our users.
Other companies may collect information on our behalf through their sites. This occasionally incorporates the use of frames on the site that will not show the URL you are visiting in the browser address window. We require all such companies to comply with the terms of our privacy policies, to limit their access to any personal information to the minimum necessary to perform their obligations, and not to use the information they may access for purposes other than fulfilling their responsibilities to us.
We use our best efforts to limit the use of other companies in areas where personally identifiable health care information may be involved. Where such third parties merely act as processors of such information on our behalf, we require that they comply with the sections of the Data Protection Act 1998 that apply to such processing.
· Legal Requirements: We may release information when we believe release is required to comply with law or regulation, or if the release may be necessary to prevent the death or serious injury of an individual.
We have put in place appropriate procedures to safeguard and help prevent unauthorised access, improper use, alteration, unlawful or accidental damage and accidental loss, and to maintain the security of the information we collect online.
8. Access to your personal information
You have the right to request a copy of the personal information UCB Pharma holds about you and to have any inaccuracies corrected. (We charge £10 for information requests.) Please address requests to the Data Protection Officer (email: email@example.com).
9. Users 16 and under
If you are aged 16 or under, please get your parent/guardian's permission beforehand whenever you provide personal information to the UCB Pharma's website. Users without this consent are not allowed to provide us with personal information.
UCB Pharma is not responsible for the data collection and use practices of other companies, entities or individuals to which our website may link.
Data Protection Officer