Who are we?

The website www.eurosfordocs.eu is created and published by the french association “Euros For Docs” (“association loi 1901”). Our address is:
Euros for Docs,
Cabinet d’avocat Me Alibert
30 avenue du Maine
75015 Paris

You can best contact us per email: [email protected]
The objective of our association is to carry out projects related to transparency in the health sector.

What is eurosfordocs.eu? 

The objective of the eurosfordocs.eu project is to increase the transparency about transfers of values in the health sector, by gathering data from different public sources about these transfers of values, and to make this data available in a single database. To achieve this, we have to process two very distinct kind of personal data:

• the data contained in the disclosure documents, related to Health Care Practitioners who receive transfers of value (see part “Health Care Practitioners’ data”)
• the data collected to manage the user access to the database itself and generally on the eurosfordocs.eu website (see part “Users’ data”)

Health Care Practitioners’ data

Here are the sources of the data that we process to create eurosfordocs.eu database:

Country	Source(s) used
France	Base Transparence Santé (public register)
Portugal	Infarmed (public register)
Denmark	Danish Medicines Agency (public register)
Belgium	beTransparent (public register)
Romania	ANM (public register)
United Kingdom	Disclosure UK, made by the ABPI (trade association)
Ireland	transferofvalue.ie, made by the IPHA (trade association)
Sweden	Documents disclosed by each company: see list
Germany	Documents disclosed by each company: see list
Spain	Documents disclosed by each company: see list
Italy	Documents disclosed by each company: see list
Switzerland	Documents disclosed by each company: see list

The data from these different sources was obtained in different contexts: in some countries (France, Portugal, Denmark, Belgium, Romania) there is a law stating that this data should be disclosed by the pharmaceutical companies to a national authority, which then publishes this data. In this case the data is public, and no consent is required to reutilise it, as long as we stick to the purpose described in the law (basically, increase transparency in the health sector)

In the other countries the data comes from the EFPIA Disclosure initiative ^[1]See https://efpia.eu/relationships-code/, sometimes centralized on a national platform (UK, Ireland), sometimes directly from the disclosure documents published on the company websites (Germany, Sweden, Switzerland, Italy, Spain). In such cases, the consent of the individuals named in the disclosure documents was obtained by each company. 

The spanish agency for data protection (AEPD) has ruled in 2016 ^[2]Read the decision (in spanish): https://www.aepd.es/es/documento/2016-0172.pdf that the goal of increasing transparency about transfer of value in the health sector constitutes a legitimate interest to publish the name of the recipients of such transfer of values, which in this case overtakes their right to consent. 

The goal of increasing transparency about the transfers of value in the health sector constitutes a legitimate interest to process the personal data contained in these public disclosure documents. 

What data processing is done?

The processing of the data contained in the different sources has the only goal to harmonize its format so that it can be stored in a unique database. The information about each transfer of value is not altered in any way (names, values, categories). Each transfer of value in the final database is linked to the source in which it was first published. The personal informations that we have to process are related to Health Care Practitioners (HCP):

• The name of HCPs
• City and work address of HCPs
• Eventually, a unique ID identifying the HCPs in a national or in a company system.

What can this database be used for?

Our goal is to increase the transparency about transfer of values in the health sector, any use of the data that share this goal is possible. This includes but is not limited to: 

• Research projects
• Journalistic projects

This excludes any project that is not sharing this objective, such as: 

• Selling this data to any third party
• Building a commercial service on top of this data

Who can access this database?

The access to this database is managed by the association Euros For Docs. We only give full access to the database on an individual basis, after ensuring that the person or organisation wants to make a use of the data that respects the previous section. 

An anonymised version of the data is accessible publicly. This version contain none of the personal data mentioned above. The data can also be explored using the open source tool “Metabase”, after creating a free account. Users only see by default the anonymised data, if they want to access the version of the data containing the names of HCPs, they should contact us by email.

How long is the data kept?

The data is kept for 5 years.

Users’ data

To allow users to explore the eurosfordocs.eu database, we use an opensource tool called Metabase ^[3]metabase.com. No personal data is collected until you create a Metbase account. When you create an account, we collect the following data:

• If you use the Google sign-in, we access and store your email, your first and last name. Google is informed of the connections.
• If you create an account without the Google sign-in, we collect your email address, optionally your first and last name, and a password. Passwords are stored salted and hashed. We encourage our users to use unique passwords.

This data is collected with the only purpose of managing the access to Metabase, to analyse its usage and eventually to contact the users. It is not shared with any third party other than legal obligations. The collection of this personal data constitutes a contractual necessity to give you access to Metabase.

All users have a right to access, rectify or delete their personal data. You can use these rights by contacting us: [email protected]

How to contact us

If you have any questions about Euros for Docs’s privacy policy, please do not hesitate to contact us via email at [email protected]

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that Euros For Docs has not addressed your concern in a satisfactory manner, you may contact the french national authority, the CNIL: https://www.cnil.fr/