TRANSPARENCY OF TRANSFERS OF VALUE
In Europe, Pharmaceutical Companies adhering to EFPIA (European Federation of Pharmaceutical Industries and Associations) are required to document and make public the economic transfers made directly or indirectly (through third parties) to natural and legal persons connected to the Health sector.
IBSA will publish annually on their website (www.ibsagroup.com), unencrypted and for each Healthcare Professional and Healthcare Organisation, the economic transfers of the previous year relating to
- Costs of participation in conferences and congresses relating to registration, travel and hospitality fees (excluding meals and drinks);
- Expenses for consultancy activities and professional services, resulting from a specific contract with the IBSA Group;
In some countries, due to local regulations, the economic transfers are declared and/or publiched on the following websites
- Italy -> https://www.ibsa.it/trasparenza.html
- USA -> http://go.cms.gov/openpayments
- Belgium -> https://www.betransparent.be
- Turkey -> https://www.medispend.com/turkey-transparency-reporting
The on-line and unencrypted publication of economic transfers on an individual basis, namely for each Healthcare Professional, necessarily requires the express consent to the processing of personal data by the natural person concerned (Healthcare Professional), in compliance with the applicable legislation on the processing of personal data (L. Decree 196/2003 and EU Regulation 2016/679).
Explicit consent to the processing of personal data for the purpose of publishing the relative economic transfers on an individual basis (both directly or indirectly) will be required though our Pharmaceutical Representative upon conferment of each professional assignment entered into with the IBSA Group or when participating in a conference event at the Company’s invitation. Each Healthcare Professional is invited to sign a specific form which also envisages the possibility of denying consent: in the latter case, economic transfers can be published exclusively anonymously on an aggregated basis. IBSA will keep for a period of at least 3 years specific documentation showing that the Professional's consent to the publication of the data has been requested.
Transparency? Yes, thank you!
Pharmaceutical companies are called to the "maximum possible effort" to obtain the consent of each Healthcare Professional to the publication, on an individual basis, of the financial payments received in the previous year, as required by the EFPIA Code.
The publication of the economic transfers on an aggregate basis must be a wholly exceptional circumstance.
GOOD TO KNOW
The information will remain in the public domain for at least three years.
The accounting and administrative documentation supporting the published data (e.g. invoices, receipts, etc.) will be kept by IBSA for at least five years and may be made available in detail on request by the Healthcare Professional.
The data will be published online in compliance with the following measures* suitable for impeding:
- massive data duplication operations: in order to avoid the risks of reproduction and reuse of files containing personal data, IT warning systems that allow to recognise and report access anomalies in order to implement adequate countermeasures will be put in place;
- their availability through external search engines: access to transfers of value published on the website www.ibsa.it by external search engines (for example, Google, Bing etc.) will not be allowed. This is to avoid arbitrary extrapolation of data and any risk of manipulation.
* Guidelines on the processing of personal data also contained in administrative acts and documents, carried out by public entities for the purpose of publication and dissemination on the web (OJ No 64 of 19 March 2011).
Publication of Transfer of Value 2020 Ibsa Institut Biochimique SA