Privacy Statement

Data protection

We would like you to feel comfortable visiting our website. It is very important to us to protect your privacy when your personal data is processed.  In our privacy statement we describe how we collect, use and disclose your personal data when you visit our website www.tcp.ie (hereafter: “Website”).

1. Controller

The Controller pursuant to data protection law is:

Temperature Controlled Pharmaceutical
a McKesson company

2-3 Westland House, Westland Business Park,
Willow Road, Clondalkin,
D12 EA03, Dublin, Ireland.
Telephone: +353 1 215 8800
Data.Protection@tcp.ie

2. Data Protection Officer
Our Data Protection Officer will be happy to assist you with any concerns regarding data protection.

Corné Purcell – Data Protection Officer
McKesson Ireland
Unite Drug House, Magna Drive,
Magna Business Park, Citywest Road,
D24 XKE5, Dublin, Ireland.
Telephone: +353 1 215 8800
Data.Protection@tcp.ie

3. Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is a data subject who can be identified, directly or indirectly, in particular by reference to an identifier. Identifiers can include, for example, a name, an identification number, location data, an online identifier, an IP address or one or more factors specific to the physical, physiological, genetic, psychological , economic, cultural or social identity of that natural person (hereafter referred to jointly as “data”).

4. Purposes and legal bases of data processing

4.1 General
We process your data in accordance with the provisions of the General Data Protection Regulation, the Irish Data Protection Acts and other applicable data protection provisions. Data are processed only insofar as is necessary and permitted under data protection law, for example to enable a visit to the website, to fulfil contractual purposes or to the extent that you consent to data processing.
4.1.1 Enquiries

4.1.1.1 Scope of processing and purpose
To enable us to process and respond to your enquiries to us, e.g. via the contact form or to our email address, we will process the data you provide to us. The data include your name, your age and your email address and any additional information you send to us in your communication.

4.1.1.2 Legal basis
We process your data in order to respond to your enquiries on the following legal basis:

• If you contact us in connection with a contract to which you are a party, or in order to take steps prior to entering into a contract, the legal basis is Art. 6, para. 1(b) GDPR.
• For the purposes of pursuing our legitimate interests pursuant to Art. 6, para. 1(f) GDPR; we have a legitimate interest in responding appropriately to customer enquiries.

5. Recipients of the data
Your data will only be shared with the internal departments or organisational units and other companies affiliated with us under company law which have need of it, in order to fulfil our contractual and legal obligations or to the extent that we require the data in order to process and implement our legitimate interests.

Your data will be passed on to external recipients in order to process contracts if we are obliged by legal requirements to:

• provide information,
• report or share data or you have given us your consent to your data being shared with third parties, or
• to external service providers who are acting as processors on our behalf or who perform functions for us (e.g. IT service providers, data centres, companies that destroy data or courier services).

6. Transfers to third countries
We do not otherwise transfer your personal data to countries outside the EU or the EEA or to international organisations.

7. Your rights as a data subject
You may assert your rights listed below against the entity named in Section 1 at any time.

7.1 Right of access
You are entitled, pursuant to Art. 15 GDPR, to obtain following information from us at any time and free of charge: your data we process, the purposes of the processing, the categories of recipients, the envisaged period for which the data will be stored or, in the case of transfer to a third country, the appropriate safeguards. You are also entitled to obtain a copy of your data.

7.2 Right to rectification, erasure, restriction of processing
Should the data we process of you be inaccurate or incomplete or if their processing is unlawful, you can request that we rectify, supplement or restrict the processing of your data or erase the data to the extent permitted by law, Art. 16, 17 and 18 GDPR.

There is no right to erasure if the processing of the personal data is necessary (i) for the exercise of the right of freedom of expression and information, (ii) for compliance with a legal obligation to which we are subject (e.g. statutory retention periods) or (iii) for the establishment, exercise or defence of legal claims.

7.3 Right to data portability
If you have provided us with your data on the basis of your consent or as part of an existing contractual relationship with us, we will, at your request, make the data available to you in a structured, commonly used and machine-readable format or, where technically feasible, will transmit them to a third party named by you.

7.4 Right to object
If we process your data in order to pursue a legitimate interest, you may object to this processing on grounds relating to your particular situation, Art. 21 GDPR. The right to object may be exercised only within the confines of Art. 21 GDPR. Moreover, our interests may override the cessation of processing, meaning that, despite your objection, we are entitled to process your personal data.

7.5 Right to lodge a complaint
You are welcome to contact our Data Protection Officer named in Section 2 with questions, suggestions and criticisms.

You are also entitled, subject to Art. 77 GDPR, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR. The right to lodge a complaint applies regardless of any other administrative or judicial remedies.

The supervisory authority responsible for us is:

Office of the Data Protection Commissioner.
Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland
Phone +353 (0761) 104 800
LoCall 1890 25 22 31
Fax +353 57 868 4757
Email: info@dataprotection.ie

8. Consent/rights of withdrawal
In the event that you give or have given us your consent to the collection, processing or use of your data, you can withdraw this consent at any time by notifying the entity named in Section 1. An email is sufficient, but you can reach us via any a preferred method..

You also have the right, on grounds relating to your particular situation, to object to the processing of data concerning you on the basis of Art. 6, para. 1(e) (performance of a task carried out in the public interest) or Art. 6, para. 1(f) GDPR (legitimate interests pursued by the controller); the same applies to profiling pursuant to those provisions. In this event, we will no longer process the data concerning you, unless we can demonstrate compelling and legitimate grounds for the processing that override your interests, rights and freedoms, or the processing serves the assertion, exercise or defence of legal claims.

If the data concerning you are processed in order to engage in direct marketing, you have the right to object at any time to the processing of this data for the purposes of such marketing. If you object to the processing for direct marketing purposes, the data will no longer be processed for those purposes.

Please send notification of withdrawal to the address indicated in Section 1.

9. Amendments
We reserve the right to amend this privacy statement at any time. Any changes will be announced by the publication of the revised privacy statement on our website. Unless specified to the contrary, such amendments take effect immediately. Please therefore regularly check this privacy statement to make sure you are aware of the latest version.

Last updated in May 2018