Collaborations with healthcare professionals (HCPs) and healthcare organisations contribute significantly to our efforts to improve the quality of patient care, benefitting individuals and society at large.
HCPs should be fairly compensated for the expertise and services they provide to the industry. At the same time, Sanofi acknowledges concerns that such transactions should be transparent. For this reason, Sanofi believes that the publication of transfer of value data, particularly on a named basis, serves important legitimate interests because it serves to:
- protect and instil public confidence in the integrity of the relationship between the pharmaceutical industry and HCPs;
- represent a step towards fostering greater transparency and building greater trust between the pharmaceutical industry, the medical community and society;
- safeguard public health by promoting HCP’s accountability to patients for decisions about their treatment;
- demonstrate commitment to continual education and development of HCPs to provide better care to patients; and
- enable Sanofi to most fully comply with its disclosure obligations, for instance under the Irish Pharmaceutical Healthcare Association (IPHA) Code of Practice.
Under our obligations to the EFPIA Disclosure Code and the IPHA Code of Practice, all transfers of value (payments which can be direct, indirect or in kind) made by Sanofi to HCPs and healthcare organisations are published on the IPHA Transfers of Value website. If a HCP does not object to Sanofi processing and disclosing his/her personal data, then the total sum of all transfers of value made by Sanofi to that HCP will be disclosed on an individual named basis. However, if a HCP does object to Sanofi processing and disclosing his/her personal data, then Sanofi will aggregate their data with other transfer of value data, so that the disclosed data does not identify them as an individual.
Effective from 1 January 2020, Sanofi switched from relying on written consent from HCPs to legitimate interests as the legal basis of processing and disclosing transfer of value data under the applicable data protection legislation (the EU General Data Protection Regulation, as supplemented in Ireland by the Irish Data Protection Act 1988 and 2003).
To balance the legitimate interests described above against the interests, rights and freedoms of the relevant individual HCPs, Sanofi provides HCPs with information about how and why their personal data will be processed and disclosed, with specific instructions to contact GB-Transparency@sanofi.com if they wish to exercise their right to “opt out” of disclosure on an identifiable basis.
Our latest annual breakdown of transfers of value to patient associations is posted here.
Date of Preparation July 2021