Privacy Policy

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, ABS Pierre-Alain Jachiet, 154 rue de la Roquette, 75011 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? 

Sources used in the project

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. These disclosures of transfers of values contain personal data, which we have to process to create this unique database. 

CountrySource(s) used
FranceBase Transparence Santé (public register)
PortugalInfarmed (public register)
DenmarkDanish Medicines Agency (public register)
United KingdomDisclosure UK, made by the ABPI (trade association)
Irelandtransferofvalue.ie, made by the IPHA (trade association)
SwedenDocuments disclosed by each company: see list
GermanyDocuments disclosed by each company: see list
SpainDocuments disclosed by each company: see list
ItalyDocuments disclosed by each company: see list
SwitzerlandDocuments disclosed by each company: see list

The data from these different sources was obtained and published in different contexts: in some countries (France, Portugal, Denmark) 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 an 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. 

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 give 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. 

How long is the data kept?

The data is kept for 5 years. We have data from 2017 on.

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/