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Full Privacy Policy HCP

​1. Introduction

 Welcome to the Privacy Policy of Force. Force provides outsourced engagement and communication services to pharmaceutical companies, including contacting General Practitioners (GPs) and other healthcare professionals (HCPs) on behalf of our clients.

We are committed to protecting the privacy and personal data of all individuals whose information we process. This Privacy Policy explains what personal data we collect, how we use it, how we protect it, and the rights available to you under the General Data Protection Regulation (GDPR).

 This Privacy Policy applies to:

  • GPs and healthcare professionals contacted by Force

  • Business contacts and client representatives

  •  Visitors to our website

  •  Individuals whose personal data is processed as part of our services

 This website is not intended for children.

 

2. Who We Are

 Force Recruitment and Outsourcing

Bellview Offices,

Dublin Road,

Mullingar,

Co. Westmeath,

N91 NW64

Force provides professional engagement services to pharmaceutical companies. In most cases, we act as a Data Processor, processing personal data strictly under the instructions of our clients (who act as Data Controllers).

For any questions about this Privacy Policy, please contact us at: info@forcerecruitment.com

3. Role in Data Processing

 Force processes personal data in two ways:

 A. As a Data Processor (most common)

 For GP-engagement activities and client-directed programmes, Force acts only as a Data Processor, meaning:

 ·         We do not decide how GP data is used.

 ·         We follow the written instructions of the pharmaceutical company (the Data Controller).

 ·         We do not use GP data for our own purposes.

 B. As a Data Controller

For certain business functions (e.g., website use, client enquiries), Force may act as a Data Controller. This Policy covers both roles.

 

4. Personal Data We Process

We only collect the minimum personal data necessary for our activities.

 

4.1 GP and Healthcare Professional Data (Call Team)

 When contacting GPs on behalf of pharmaceutical clients, Force processes the following limited data:

 ·         GP name

 ·         Practice address

 ·         Date of interaction

 ·         Factual, non-sensitive call notes

 

Force does not collect:

 ·         GP email addresses (unless provided by the GP Practice )

·         GP phone numbers (unless provided by the GP Practice)

·         Medical Council numbers

·         Patient information

·         Special-category or sensitive personal data

·         Personal opinions or irrelevant details

 

This ensures compliance with GDPR’s data minimisation principle.

 

4.2 Website & Business Contact Data

 We may collect:

 ·         Name, job title, and company

·         Work email address or phone number (if voluntarily submitted)

 ·         IP address, browser type, device information

 ·         Website usage statistics (via cookies – see section 10)

 

5. How We Collect Personal Data

 We collect personal data through:

 

Direct interactions

·         When communicating with GPs

·         Through our call-handling systems

·         When you contact us through the website

 

Client systems

 ·         GP details provided by pharmaceutical clients (Controllers)

 

Automated website technologies

 ·         Cookies and analytics tools (see section 10)

 

6. Purpose of Processing

6.1 GP & Healthcare Professional Data

 Processed only to:

 ·         Log professional interactions with GPs

·         Provide information as instructed by pharmaceutical clients

·         Record follow-up actions

·         Support medical information and compliance reporting

·         Provide interaction summaries to the pharmaceutical client

·         We do not use GP data for Force marketing or profiling.

 

6.2 Business and Website Purposes

 ·         Responding to enquiries

·         Maintaining our website

·         Improving user experience

·         Ensuring network and information security

 

7. Legal Basis for Processing

7.1 GP Data (Processor Role)

 Legal basis is determined by the pharmaceutical client (Controller).

This is typically:

 Legitimate Interests (GDPR Article 6(1)(f))

Pharmaceutical companies have a legitimate interest in engaging with qualified healthcare professionals about medicinal products.

 

Force processes GP data strictly under client instructions.

 

7.2 Website & Business Operations

 When Force acts as Controller, the legal bases may include:

 

·         Legitimate Interests (business operations, website security)

·         Contractual necessity (responding to enquiries)

·         Consent (cookies or marketing opt-ins)

 

8. Sharing of Personal Data

 Force may share personal data with:

 

·         The relevant pharmaceutical client (Data Controller)

·         IT system providers and CRM platforms

·         Approved sub-processors providing secure hosting or analytics

·         Regulators (where legally required)

 Force does not sell personal data or share it with unrelated third parties.

 All sharing is controlled by contracts and GDPR-compliant agreements.

 

9. International Transfers

 If personal data is transferred outside the EU/EEA/UK, we ensure it is protected using:

 ·         EU Standard Contractual Clauses (SCCs), or

·         An adequacy decision, or

·         Other lawful transfer mechanisms

 

10. Cookies & Website Tracking

 Our wesite uses cookies to:

 ·         Improve functionality

·         Understand how visitors use the site

·         Enhance user experience

 Users can manage cookie preferences at any time.

 A full cookie policy will be provided on-site.

 

11. Data Security

 Force uses technical and organisational measures to protect personal data, including:

 ·         Secure, access-controlled CRM systems

·         Role-based access

·         Staff GDPR training

·         Encryption and secure transmission

·         Monitoring and audit processes

 

We do not export or print GP data without authorisation.

 

12. Data Retention

12.1 GP Contact Data

Retained for 2–5 years, depending on client contract requirements.

Securely deleted afterwards.

 

12.2 Website and Business Data

 Retained only as long as reasonably necessary for the purposes collected, unless required by law.

 

13. GP Call Notes Policy

 Force requires all staff to record call notes in a:

 

·         Factual

·         Professional

·         Minimal

·         Non-sensitive manner.

 

Staff are strictly prohibited from recording:

 ·         Patient information

·         Sensitive GP information

·         Opinions or subjective comments

·         Irrelevant or excessive details

 This ensures accuracy and minimisation under GDPR.

 14. Your Rights

 Depending on whether Force acts as Controller or Processor, you may request:

 ·        Access to your personal data

·         Correction of inaccurate information

·         Deletion (“right to be forgotten”)

·         Restriction of processing

·         Objection to processing

·         Data portability

·         Withdrawal of consent (when applicable)

 

For GP data, please contact the pharmaceutical company (Controller).

 Force will assist them as required.

 

15. Contact Us

 For any privacy-related questions, please contact: Shirley Kiernan shirley.kiernan@forcerecruitment.com