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Ensuring data protection in the implementation of the EFPIA disclosure code: key challenges and how pharmaceutical companies are addressing them


27 February 2015

​The EFPIA Disclosure Code will, from 2016, require pharmaceutical companies to disclose details of payments and transfers of value made to healthcare professionals and healthcare organisations. The Code aims to promote, through transparency, greater trust in the relationships between pharmaceutical companies on the one hand and healthcare professionals and organisations on the other.


Compliance with the Code, because it involves the disclosure to the public of personal data, presents challenges to compliance with data protection laws. Pharmaceutical companies must have a lawful basis for disclosures under data protection law, which for most companies will involve ensuring transparency (i.e. making HCPs/HCOs aware of the purposes and nature of processing, as well as the legitimate basis for disclosures) and obtaining a form of consent (i.e. as a minimum, giving HCP/HCOs the opportunity to opt-out of disclosures). Achieving compliance with these and other requirements presents many challenges.
This article examines some of the issues and contains the results of a small benchmarking exercise we carried out, which looked at the approach that a number of pharmaceutical companies are taking to address these challenges.


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