We collect personal data and other data from and about individuals who interact with us and use our Services. We collect certain data automatically through an individual’s use of our websites, we collect data that individuals voluntarily provide to us and we collect data about individuals from third-party sources. The data collected and how we use and share it depends on the manner in which individuals interact with us and our Services and the purpose for which it is being collected. We may combine the data we collect from individuals with data we receive from third-party sources.
Following are the categories of personal data, along with some examples of the types of data within each category, that we may collect across the range of ways that individuals interact with us or use our Services, including as healthcare professionals, individuals using or submitting data about our products or Services, clinical trial participants (who will also receive and be asked to consent to a much more detailed data consent document prior to their participation in a clinical trial), job applicants interested in a career with Seagen and website visitors.
Contact data: Email address, mailing address, telephone number, other data that enables us to contact an individual directly.
Identifiers: A real name, alias, unique personal identifier, online identifier, username, Internet Protocol address, account name, driver's license or other government-issued identification number, passport number.
Demographic data: Age, ancestry, national origin, citizenship, religion or creed, marital status, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions).
Health data: Medical conditions and treatment, health insurance data, physical characteristics or description, genetic data (including familial genetic data).
Biometric data: Activity patterns used to extract a template or other identifier, or identifying data, such as fingerprints, faceprints and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns and sleep, health, or exercise data, which allow or confirm the unique identification of an individual.
Content of communications: Data that individuals post on our website or social media pages and data provided through communications with us.
Professional or employment-related data: Current or past job history, salary, skills, curriculum vitae/resumes, educational records, identification documents, work permits.
Technical data and internet or other similar network activity: Device data, browser data, browsing history, search history, data on an individual’s interaction with a website, application, or advertisement.
Geolocation data, including precise geolocation data: Physical location.
Sensory data: Audio, visual, thermal, olfactory, or similar data.
Inferences drawn from other personal data: Profiles reflecting an individual’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities and aptitudes.
Click on the category of individual or type of activity below to learn more about the specific type of data we may collect and the purposes and legal bases for the collection of data related to such categories of individuals and activities.
Seagen will electronically process and store the following categories of personal data related to your professional activities in its CRM (Customer Relations Management) system and other systems: personal details (e.g. name, gender, professional registration number), contact details (e.g. email address, telephone number(s), country), professional qualifications, institute and other professional affiliations (e.g. department, function, speciality), data about your professional accomplishments and activities (e.g. publications, any research you may have conducted, whether you treat certain diseases and your treatment preferences), memberships (e.g. boards, committees), opinions about us, our products and services.
Seagen may also process data such as your area(s) of expertise, professional credentials, activities, skills, preferences and professional interests. Seagen may obtain this data from public sources or data brokers, such as IQVIA.
For more information about country-specific transparency notices, please visit this link.
Purpose for Collection and How We Use Your Data as a Healthcare Professional: We will process your data to assess your interest in our products and events, to share scientific data on therapeutic area(s) and products that may be of interest to you, to plan and invite you to scientific meetings and events based on the therapeutic area(s) of your interest, to keep record of our interactions with you, to create statistics and study trends. Depending on your role, we may be required to process your data to ensure treatment access is secured according to Institution-specific criteria.
Legal Basis for Processing Healthcare Professional Data: The processing of your personal data is based on our legitimate interest to contact you as described above, establish a relationship with you and keep track of our interactions with you. When necessary, we will also obtain your consent: for example, for certain direct marketing activities through email or phone. If you are a healthcare professional from Italy, we will obtain your consent for all purposes rather than for only marketing communications.
Data Retention for Healthcare Professional Data: Seagen will review the content of its databases periodically to make sure that data registered therein is up-to-date and still of interest. In most circumstances, your personal data as a healthcare professional will not be kept for longer than five years after our last interaction if we do not have any further interactions. In circumstances where we may have longer retention obligations due to legal or regulatory requirements, we will retain your personal data as set forth below in the general “Data Retention” section.
When a healthcare professional or other individual provides us information about our products that we are required to report pursuant to applicable laws and regulations, Seagen will electronically process and store the following categories of personal data in its systems: personal details (e.g. name, gender, date of birth), contact details (e.g. email address, telephone number(s), country), professional qualifications, institute and other professional affiliations (e.g. department, function, speciality). If you contact us to ask for information on our products or to report an adverse event, we may also collect data about the health or other sensitive data of the patient who is using our product.
Purpose for Collection and How We Use Your Data: This data is only processed when relevant and necessary to properly document a potential adverse reaction and for the purpose of meeting our pharmacovigilance, safety and any other legal requirements.
In case of a medical enquiry, your personal data may be used to answer your enquiry, follow up on said request, provide answers to your request, send requested material and maintain the data in a medical information database for reference.
In case of an adverse event reporting, we may use personal data to get in touch with people who contact us in order to follow up and, if needed, obtain further information, provide information to regulatory agencies and authorities and maintain the data in a medical information database for reference.
In case of communications about our products, the data will be used only for that purpose (e.g. evaluation, classification and assessment of the product complaint, to follow up on such requests, and to maintain the data in a product complaints database for reference).
Legal Basis of Processing: The processing of your personal data will be based on our intent and obligation to ensure high standards of quality and safety of medicinal products. The processing may also be based on your consent to said processing.
Data Sharing: Seagen may also need to share your data with service providers (e.g. medical information call centres). In cases when an adverse event is reported, we will share data with health authorities (such as the European Medicines Agency) to allow them to evaluate adverse events and make efforts to prevent similar events from happening in the future. We may also share data as set forth below in the “Sharing or Disclosing Your Data” section.
Data Retention for Data from Medical Information Enquiries and Product Safety Reports: For adverse reporting, in accordance with law, pharmaceutical companies, as market authorisation holders of products, must retain all product-related documents for at least the time period of the market authorisation, plus ten years following its expiry. Therefore, personal data related to the safety of our products will be retained for this time period.
For medical information enquiries and product complaints, personal data will usually be retained for a maximum of five years from the moment of collection. In circumstances where we may have longer retention obligations due to other legal or regulatory obligations, we will retain personal data as set forth below in the general “Data Retention” section.
Seagen will process the personal data that you have submitted in reply to a job application or spontaneously to evaluate your eligibility for roles within our organisation. This data may include your curriculum vitae or resume, address, identification documents, work permits, educational records, experience, skills and work history. If you are short-listed as a candidate, we may be required to process more detailed personal data. We will notify you accordingly and comply with applicable laws with respect to such data.
Legal Basis for Processing. We have a legitimate interest in processing your personal data in order to assess your eligibility and suitability for roles in our organisation.
Data Retention of Job Applicant Personal Data. Seagen will review the content of its databases periodically to make sure that the data registered therein are up-to-date and still of interest. In most cases your personal data will not be kept for longer than 60 months after our last interaction if we do not have any further interactions. In circumstances where we may have longer retention obligations due to legal or regulatory requirements, we will retain your personal data as set forth below in the general “Data Retention” section.
We collect data voluntarily provided by individuals when they interact with us (such as in person, by phone and through the Services). For example, we collect data provided by:
Depending on the interaction or potential interaction that we may have with you, we may obtain different types of data about you from a variety of sources, including:
Here are some examples of how and why we might obtain personal data from third-party sources:
We use personal data in a variety of ways to conduct our business and pursue our business interests. We use the personal data we collect to:
In addition to the specific legal bases set forth in the specialised sections of this Policy, the applicable legal bases we rely on to process your personal data for the specific purposes listed in the “Purpose for Collection” section, above, include the following:
We may share or disclose personal data to conduct our business and pursue our business interests (see “How We Use Your Data” above). For example:
Seagen and its service providers process your personal data in Europe. In addition, Seagen is part of a multinational corporation and, like most other global corporations, will transmit your personal data to our affiliates and service providers located in many countries around the world, including Switzerland, the United Kingdom and elsewhere outside of Europe, where your personal data will be subsequently processed. We may also transfer your personal data to our parent company in the United States, where it will also be processed. Some of the countries to which your personal data is disclosed have not been deemed by the European Commission (“EC”) to provide an adequate level of protection for personal data. When we transfer personal data out of Europe to countries that the EC does not deem adequate, we will implement one or more of the safeguards the EC deems to provide appropriate safeguards, which may include EU Standard Contractual Clauses, transfers to organisations that protect personal data under binding corporate rules, or transfers to organisations that operate under an approved code of conduct or certification mechanism.
When your data is transferred to the U.S., the U.S. (similar to most other countries) has laws that would permit the government to request and obtain access to your data. However, based on historical practice and the nature of the data we maintain, we do not anticipate such requests for your data or the data of other users of our Services.
Regardless of where your personal data is collected or processed, Seagen maintains and requires its service providers to maintain appropriate administrative, technical and physical safeguards to protect data about you.
Our products, this web site and our other Services are intended for use by individuals who are legally considered to be adults in their jurisdiction of residence. We do not knowingly collect any personal data directly from individuals who have not reached the age of majority (minors).
Some of our websites or interactive features may contain links to third-party websites or services that are not under our control or ownership. Such links do not constitute an endorsement of those third parties or the content displayed therein and you agree that Seagen is not responsible for the content of such websites. We are not responsible for how these sites operate or treat your data. You acknowledge that we provide these links to you only as a convenience and you understand that your data will be used as described by the third parties in their privacy policies.
We implement reasonable technical and organisational security measures that are designed to help protect personal data from accidental or unauthorised access, use, loss, destruction, disclosure, or modification when transmitting or storing personal data. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
We retain data collected for as long as necessary to fulfil the purposes for which the data is collected, as required or permitted by applicable laws, or for other legitimate purposes such as disaster recovery, resolving disputes and enforcing our agreements. In some cases, we anonymise or de-identify personal data so that it can no longer be associated with an individual. In such cases, we may use the anonymised or de-identified data without further notice. The data retention criteria we use for personal data includes considering:
You have certain rights with respect to your personal data, subject to the legal obligations and rights of Seagen, including the right to:
You may exercise your rights by emailing us. We will always endeavour to fulfil your request to exercise these rights, but we may have legal grounds or obligations to reject your request or the inability to fulfil your request, including, for instance, where we do not have direct identifiers, such as with clinical trial data we may process.
We will respond within 30 days after we have verified that you are the data subject or are authorised to make the request on behalf of the data subject. If necessary, we may extend our response time by an additional 60 days to respond properly, but we will notify you if that is the case. If we decide not to fulfil your request, we will tell you the reasons why.
If you disagree with our response to your request, you have the right to lodge a complaint with a data protection regulator in Europe. The contact details of your local supervisory authority can be located here. Should you have any concerns, we request that you contact us first so we can investigate and hopefully resolve, your concerns.
Seagen Data Protection Officer
c/o Lucid Privacy Group
1050 Page Street, San Francisco, CA 94117, United States
Seagen Data Protection Representative
Evert van de Beekstraat 1-104
Phone: +31 20 238 2497