Santen Pharma Malaysia Sdn. Bhd. (“SANTEN”) collects personal data to support its learning, marketing and advertising, research, administration, personal development, to process applications for employment with SANTEN and for other functions such as performing distribution, general wholesale trade, research, development, sales, and marketing of pharmaceuticals and medical devices.
SANTEN’s Personal Data Protection Policy (“Policy”) discloses how SANTEN collects, uses, access, stores, transfers and handles your personal data, in accordance with the Malaysian Personal Data Protection Act 2010 (“Act”). By providing your personal data to SANTEN, you are consenting to this Policy and the collection, use, access, storage, transfer and processing of your personal information by SANTEN and its respective representatives and/or agents as described in this Policy
This Data Protection Policy supplements but does not supersede nor replace any consent you may have previously provided to SANTEN in respect of your Personal Data, and your consents are in addition to any rights which to any SANTEN and/or its respective representatives and/or agents may have at law to collect, use or disclose your Personal Data with or without your consent
1. Personal Data
“Personal data” means any information in respect of commercial transactions, which—
- (a) is being processed wholly or partly by means of equipment operating automatically in response to instructions given for that purpose;
- (b) is recorded with the intention that it should wholly or partly be processed by means of such equipment; or
- (c) is recorded as part of a relevant filing system or with the intention that it should form part of a relevant filing system
that relates directly or indirectly to a data subject, who is identified or identifiable from that information or from that and other information in the possession of a data user, including any sensitive personal data and expression of opinion about the data subject; but does not include any information that is processed for the purpose of a credit reporting business carried on by a credit reporting agency under the Credit Reporting Agencies Act 2010;
Such Personal Data includes, but is not limited to, your name, gender, date of birth, passport or other identification number, telephone number(s), residential mailing address, personal email address, photographs or CCTV footage from which you can be identified, and any other personal information or details that you provide to SANTEN .
2. Purposes for the Collection, Use and Disclosure of Personal Data
Such Personal Data will be collected, used, disclosed, transferred and/or processed by SANTEN for the following purposes: –
- (a) Processing, administering and/or managing your contractual relationship with SANTEN;
- (b) To provide you with general health information (such as information on certain health conditions) as well as information about our products and services;
- (c) If you apply for a job with us or to consider you for employment;
- (d) For our research and development efforts and to identify investigators for, clinical trials (including clinical trials run by a related body corporate of Santen);
- (e) For product safety, such as adverse event reporting or to communicate product safety information to you and maintaining a record of inquiries, complaints and adverse event reports relating to Santen’s medical devices or products ;
- (f) When you transmit geo-location information to us via your smart phone or other location- aware devices
- (g) For your use of any online services available at any of SANTEN’s or its aliates’ or related corporations’ websites and/or through other telecommunication channels;
- (h) Facilitating or managing any business transaction(s) with you
- (i) When you interact with ourofficers, employees, authorised agents and/or sales or marketing representatives via telephone calls, mail, in-person meetings, email and any other forms of communication;
- (j) For SANTEN or its respectiveofficers, employees, sub-contractors, assigns, aliates, successors, service providers and/or agents to conduct research, clinical trials or the relevant obtain regulatory approvals or licences for its products devices and services from the relevant authorities.
- (k) For identification and verification purposes in connection with any of the services or products that may be supplied to you by SANTEN or its aliates or related corporation;
- (l) Carrying out due diligence or other screening activities in accordance with the law or regulatory requirements or risk management procedures that may have been put in place by SANTEN, including conducting background checks or obtaining of references and/or other information about applicants from previous employers;
- (m) Responding to any of your enquiries;
- (n) To disclose to our agents, aliates or related corporations for the purposes of managing or delivering training programmes;
- (o) Investigating fraud, misconduct, any unlawful action or omissions and whether or not there is any suspicions of the aforementioned;
- (p) Responding to requests for information from the Government, public agencies, ministries, statutory boards or other similar authorities from time to time;
- (q) Carrying out market-related or similar research and analysis for SANTEN’s operational strategy and policy planning purposes;
- (r) Organising educational conferences events for healthcare professionals or patients and to provide medical educational materials or information to such persons;
- (s) For legal purposes (including but not limited to obtaining external legal advice and dispute resolution proceedings);
- (t) With consent, sending you marketing, advertising, and promotional information, including materials and information on courses in SANTEN or its Aliates or related corporations and/or other events via postal mail, email, SMS, fax, voice calls or other forms of communication;
- (u) Any other additional purpose that is consistent with the original purpose for which consent was given; and
- (v) When you submit your Personal Data to us for any other reasons.
Such Personal Data may be disclosed by SANTEN to our Aliates or related corporations, third party service providers or agents (whether in Singapore or elsewhere in the world or service providers are sited) for one or more of the above purposes, as such third party service providers or agents, if engaged by SANTEN, would be processing your Personal Data for SANTEN, for one or more of the above purposes
Santen may collect your personal data directly from you in a number of ways including over the telephone, through a form or online portal, or by email. Santen may also collect your personal data from third parties such as organisations engaged by Santen to carry out functions on behalf of Santen including administrators of patient support/supply programs, event management organisations. If you are a healthcare professional, Santen may also collect your personal data from online directories which we subscribe to. If you choose not to provide the personal data requested of you to Santen we may be unable to provide you with the products and services you require or contact you to perform the functions and activities described in this policy
3. Withdrawal of Consent
If you would like to withdraw your consent to any use of your Personal Data as set out in this Policy, please contact the Data Protection officer.
Please note that when you withdraw your consent to any use of your Personal Data as set out in this Policy, it may afect the services provided by SANTEN or the Aliates or related corporations when such consent is regarded as a condition of providing services from SANTEN or its Aliates or related corporations
If you would like to access your Personal Data which we collect, use, disclose and/or process, please contact the Data Protection officer.
Access to personal data may be refused if access to such information could reasonably be expected to cause harm to an individual’s safety; reveal the identity of another individual who has provided the personal data but has not consented to the disclosure of his or her identity; or be contrary to national interest.
5. Accuracy and Correction
SANTEN makes reasonable efforts to ensure that the Personal Data it collects is accurate and complete. To assist SANTEN in keeping its records up-to-date, it is important that you inform SANTEN of any changes to your Personal Data in writing. If you would like to correct any inaccuracies of your Personal Data, please contact the Data Protection officer.
6. Security of Personal Data
SANTEN has reasonable security arrangements in place to protect the Personal Data that it possesses to prevent unauthorized access, collection, use, disclosure or similar risks. Please take note that no computer, electronic or data storage system is immune from intrusion and therefore, we cannot guarantee the absolute security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter SANTEN’s websites (for example viruses, bugs, trojan horses, spyware or adware). You are advised to take note of the risks and implement the necessary precautions.
7. Transfer of Personal Data
SANTEN has in place reasonable measures to ensure that transfer of Personal Data out of the jurisdiction is protected and in compliance with the Personal Data Protection Act.
8. Retention of Personal Data
SANTEN will retain your Personal Data for a reasonable period for the purposes for which it was processed or until you request for SANTEN to delete the Personal Data, or as required by law
9. Personal Data Protection Ofcer
Should you have any questions, feedback or concerns relating to SANTEN’s Personal Data Protection policies or wish to access, correct or withdraw any consent relating to your personal data, please contact our Data Protection Officer :-
Santen Pharma Malaysia Sdn Bhd
Unit #23-A-10, Q Sentral 2,
Kuala Lumpur Sentral,
50470 Kuala Lumpur, MALAYSIA
Please include the following information for verification purposes:-
- (a) Your full name and personal identification or Passport number;
- (b) A clear photocopy of your personal identification or Passport;
- (c) Your contact details;
- (d) Name of the officer, employee and his or her division by whom your personal data was collected; and
- (e) Details of your request
By providing to us with complete information, we will be able to provide you access to, update or correct your personal data as soon as reasonably possible. Alternatively, you may submit your request in person at SANTEN’s registered address.
It is our intention to use our best endeavours to resolve any complaint to your satisfaction. However, if you are unhappy with our response you may contact the office of the Malaysian Personal Data Protection Commissioner who may investigate your complaint further. Further information about the application of the Malaysian Personal Data Protection Act 2010 can be found at www.pdp.gov.my