Messaging Apps Supplement
GSK has enabled messaging apps in Italy as an authorized corporate channel to expand the communication channels, to keep a close relationship with our HCPs and keep you informed and in contact with GSK, in an easier and friendly way. In making possible the operation of the messaging apps, we require to process the personal information that you have provided us before, in accordance with this Supplement, that explains what personal information we require and how we process it for using Messaging Apps.
What personal information do we collect/process about you when using Messaging App?
To operate a Messaging app as an official corporate communication platform, GSK requires to process:
- Your name (first name, last name);
- Mobile phone number;
- Business details and specialty;
- Your comments or reactions to the content or conversations, when you communicate with our Representatives using Instant Messaging app.
How do we obtain your personal information?
Directly from you when activating and using the instant messaging app, in particular when: (i) You created an account in GSKPro; or (ii) When you were visited by one of our Representatives and you accepted to share your information with us; or (iii) when you shared your contact details in our registration and engagements forms.
How do we use your personal information?
We use your personal information for the following purposes:
- Keeping interactions and managing the relationship between you and GSK, like coordinating face to face visits from our Representatives, or virtual interactions (visits/calls).
- Directing communications based on your specialty and interest.
- Monitoring the interactions between you and our Representatives for compliance purposes, in order to keep our communications and interactions with you under the limit of our principles and values (quality), and the regulatory obligations.
- Any other purpose set in the GSK HCP privacy notice, that is compatible with these purposes and achievable using a messaging app.
- Responding to and dealing with your queries or requests.
- Complying with any legal obligations, including the exercise and defence of GSK in case of a legal action or an investigation involving GSK.
- Creating and maintaining backups and copies of the information generated using the messaging app in the interactions with have with you, for preservation, compliance, internal management and security purposes.
On what basis do we use your personal information?
GSK uses your personal information on the basis of your consent. By using this instant messaging app to communicate or receive communications with us, you expressly ratify your consent to process your personal information for the purposes described above, including any transfer of your personal information outside of your country, as described below.
How long will we keep your personal information?
We will keep your personal information, no longer than required to fulfil the purposes described above. Communications will be retained, generally, no longer than 30 days.
With whom do we share your personal information?
We share your personal information, following the administrative and technical controls set by GSK, with the following third parties: (i) Our tech providers in charge of providing the technical infrastructure that help us to manage the messaging app channel. It includes our tech provider of the platform that supports the retention and monitoring of the conversations between you and our Representative, for compliance and regulatory purposes, and the messaging app by itself; (ii) our professional advisors and auditors, when required by a business necessity or in compliance with internal procedures (including audits) or regulations applicable to GSK; and (iii) regulators, governments and law enforcement authorities, when required.
Your rights in relation to the messaging app channel
For exercising your rights, including the withdrawal of your consent to be contacted by GSK using the messaging app, please let us know by sending a message in the messaging app to our Representative.
Messaging Apps: WhatsApp