Disclosure of Transfers of Value
Er-Kim, which operates at a global level in the health sector, is committed to securing and preserving transparent collaboration with the totality of Healthcare Professionals (HCPs), Healthcare Organizations (HCOs) and Patient Organizations (POs).
In order to achieve the aforementioned, the disclosure of the specific collaborations, via which it is safeguarded that such kind of collaborations does not affect any decisions of HCPs and POs, constitutes a decisive factor, given that all transactions become fully transparent. Also, through the said disclosure the patients' right to be aware of the pharmaceutical companies’ relationship with the scientific community is being protected.
Within the above context, by virtue of paragraph 7(a) of article 66 of Law 4316/2014, it has been introduced the obligation of pharmaceutical companies in Greece to disclose any transfers of value, either on an individual or on an aggregate, granted to Healthcare Professionals (HCPs), Healthcare Organizations (HCOs) and Patient Organizations (POs), in accordance with the applicable regulatory regime.
In compliance with the above obligation, the present disclosure report includes all transfers of value granted during the previous calendar year by Er-Kim Greece to Healthcare Organizations (HCOs) and Healthcare Professionals (HCPs), and it has been formed in harmonization with Opinions no. 5/2016 and 2/2017 of the Personal Data Protection Authority and the pertinent Announcements of the National Organization for Medicines with regard to the application of the above legislative provision of Law 4316/2014.
More particularly, in relation to HCPs, in accordance with the restrictions and exceptions set out in the above opinion no. 5/2016 of the Personal Data Protection Authority, the disclosure of transfers of value is being made by name for those who have given and have not revoked their relevant consent, or for whom the relevant consent is not required. In the remaining cases, the disclosure of the transfers of value to the HCPs for the respective period of time is being done in an aggregate way.
It is noted that the National Organization for Medicines (EOF) publishes at its own responsibility the data of HCPs based on the reports submitted by the pharmaceutical companies, while the pharmaceutical companies publish on their websites the data of HCPs based on their respective methodological note. As a consequence, Er-Kim does not incur and in any case deprives of any liability for the disclosure of HCPs data on the relevant publication platform of EOF website, for which EOF is solely responsible.
In addition, the purported purpose of article 66 para. 7 of Law 4316/2014 pertains to transparency and as a result the published data must not be used for purposes other than the purpose of transparency. Consequently, the disclosure does not grant a blanket license, nor does it grant a relevant right, to those who visit the website of Er-Kim, as well as the relevant publication platform of EOF, to proceed with further processing of data of HCPs, such as, indicatively, cross-referencing of data with information published on the websites of other pharmaceutical companies.
More specific information relating to the disclosed transfers of value are included in our relevant Methodological Note.