ViiV Healthcare Tackle HIV Privacy Notice
Your trust is important to us. We are committed to treating your personal information with care and integrity. ViiV Healthcare UK Limited (“ViiV”) is the controller of your personal information. All personal information collected is held by Advocate Marketing Communications LTD (“Advocate”) on behalf of ViiV. Advocate manages the Tackle HIV campaign on ViiV’s behalf. This Notice explains how ViiV through Advocate acting on ViiV’s behalf (“we“, “us” and “our“) collect, use, store, and disclose the personal information relating to you as part of your interactions with the Tackle HIV Campaign
The personal information that we process may include:
- your basic information – such as name (including prefix or title), gender, age or date of birth,
- your contact information – such as personal or business email, mailing address, telephone number and social media username;
- your professional details – occupation/position/role, employer, medical registration/license, specialism;
- circumstances which may create a conflict of interest – including whether you or a close family member are an officer or employee of a political party, candidate for public office, or hold a position in government;
- your image – the photograph(s), video(s), voice recordings and/or live streamed event(s) featuring you
- sexual behaviour, sexual orientation, gender identity or expression or HIV status.
- information you choose to share when contacting us
We collect your personal information through:
- our direct interaction with you, and where you provide information to usto comply with legal, regulatory and other requirements, such as record-keeping and reporting obligations; conducting audits and complying with internal policies
- responding to and dealing with your queries or requests;
- We may combine information that we have about you from various sources, including information that you provide to us and which is collected during your engagement with you.
We use your personal information for the following purposes:
- responding to and dealing with your queries or requests;
- to comply with legal, regulatory and other requirements, such as record-keeping and reporting obligations; conducting audits and complying with internal policies on anti-bribery and conflict of interest;
- For external and internal marketing, social media and digital campaigns, training and to raise awareness of VH and GSK
On what basis do we use your personal information?
We use your personal information on the following basis:
- To respond to your queries.
- for legitimate business purposes – using personal information helps us to operate, plan and improve our business activities. It allows us to check for circumstances that could give rise to a potential conflict of interest for either you or VH. It also helps us to determine whether we may pay you for a service based on applicable law, industry codes and practice, and our policies;
- to comply with legal, regulatory and other compliance obligations – compliance with laws, regulations, rules, codes and guidance is important to us, and we would want to be able to comply with these;
- because you have given your consent – at times we may ask for your consent to allow us to use your personal information for one or more purposes. See “Your rights” for information about the rights that you may have if we process your information on the basis of your consent.
How long will we keep your personal information?
We will always keep your personal information for the period required by law. We will also keep your personal information where we need to do so in connection with legal action or an investigation involving VH. We keep personal information for normally no longer than seven years unless we are required to keep for longer due to any legal or regulatory retention requirements.
With whom do we share your personal information?
We share certain elements of your personal information with members of the GSK group of companies which ViiV Healthcare is a part of and trusted third parties, in particular, authorised employees of:
- Terrence Higgins Trust, BEAT Media and other event and media management/logistics suppliers of ViiV and GSK
See “Protecting your personal information” for information on how we keep your personal information secure when sharing it with others.
Transfers of your personal information outside of your home country
Your personal information may be processed by ViiV, its affiliated companies and trusted third party suppliers anywhere in the world, including in countries where data privacy laws may not be equivalent to, or as protective as, the laws in your home country.
We will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred outside of your home country, in accordance with applicable data protection and privacy laws. These measures include data transfer agreements implementing standard data protection clauses. Law enforcement agencies, regulatory agencies, security authorities or courts in the countries we transfer your personal information to may have the right to see your personal information.
Protecting your personal information
We will use a variety of security measures and technologies to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction, consistent with applicable privacy and data security laws. For example, when we retain a third-party service provider, that provider will be carefully selected in accordance with our policies and procedures and which commits the third-party service provider to use appropriate safeguards in relation to the handling of your personal information (including in relation to maintaining confidentiality of your personal information and implementing appropriate technical and organisational security measures).
You may be entitled to:
- ask ViiV about the processing of your personal information, including to be provided with a copy of your personal information
- request the correction and/or deletion of your personal information
- request the restriction of the processing of your personal information, or object to that processing
- withdraw your consent to the processing of your personal information (where we are processing your personal information based on your consent)
- request receipt or transmission to another organisation, in a machine-readable form, of the personal information that you have provided to us; and
- complain to your local supervisory authority if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your personal information.
If you have questions or requests regarding this Privacy Notice, or if you would like to exercise your rights, please contact Laura Stansfield([email protected]) who will facilitate contact with us.
Data controller and Data Protection Officer
ViiV Healthcare UK Limited is the controller of your personal information. You can contact ViiV’s EU Data Protection Officer by emailing [email protected]. Please note that ViiV’s EU Data Protection Officer is also GlaxoSmithKline’s.