BD is advancing the world of health by improving medical discovery, diagnostics and the delivery of care. In doing so, we collect, process and use large quantities of personal information. We collect and use information from customers, healthcare professionals, patients, business partners and other external parties with whom we interact. BD* takes data privacy seriously and believes that carrying out our business activities in compliance with applicable data protection laws and in accordance with sustainable corporate governance is fundamental to our business success.
This Data Protection Notice for BD* Customers – Europe (“Notice”) explains our practices as the responsible controller in relation to the collection, processing and use of personal data of individuals at BD’s customers and prospective customers who are located in the European Economic Area or Switzerland (or to whom EU data protection law otherwise applies). Such individuals may include healthcare professionals, procurement staff, technical or support staff and other staff members, as well as business contacts at hospitals, companies, institutions, purchasing organizations, distributors, wholesalers, agents and other intermediaries. If you fall into one of those categories, this Notice will help you understand what data BD may collect about you, how BD uses and safeguards that data, and with whom we may share it.
* In this Notice, BD or “we” means Becton, Dickinson and Company and all its worldwide subsidiaries and affiliates, including C.R. Bard and affiliates, each of which is referred to in this Notice as a BD Affiliate.
We may change this Notice periodically, so we encourage you to review it from time to time.
What categories of personal data does BD collect about me and why?
BD will collect, process and use your personal data for a range of different purposes. For example:
What is personal data
It’s important to know that BD does not collect any sensitive personal data about you.
Who might BD share my personal data with?
BD may share your personal data within BD, our service providers and business partners, and, in accordance with applicable law, governmental authorities, courts, external advisors, and similar third parties
How long will BD keep my personal data for?
Your personal data is stored for as long as necessary to achieve the purposes for which the personal data is collected, in accordance with applicable data protection laws.
What rights do I have in respect of my personal data?
You have a number of rights in relation to your data. These include a right to access, correct and erase your data, to object to certain types of processing activities as well as more technical rights to restrict the way we process it, and to transmit your data as part of data portability. Your rights are important, and we’ve set them out in detail.
Who can I contact if I have questions?
If you have concerns or questions regarding your personal data, please let us know. Our contact details are at the bottom of this Notice.
BD may collect, process and use the following categories of personal data about you which have been obtained either from you or from certain third parties (e.g. your employer or the healthcare institution you work for, or other business contacts) (collectively, personal data):
Personal data is collected, processed, and used for the following purposes (collectively, processing purposes). Furthermore, BD relies on the following legal grounds for the collection, processing, and use of personal data:
|Processing purposes||Categories of Personal Data Involved||Legal Basis|
|Delivering products and services, including technical support and maintenance services.||Identification data; product data; communication details.||The processing is necessary for the purposes of the legitimate interests pursued by BD (Art. 6(1)(f) GDPR) – legitimate interests are stated in the first column.|
|Providing customer service and engaging in other communication with the Customer.||Identification data; product data; communication details.||The processing is necessary for the purposes of the legitimate interests pursued by BD (Art. 6(1)(f) GDPR) – legitimate interests are stated in the first column.|
|Marketing and customer relationship activities, which may include profiling or categorization of your potential interests in BD products and services for tailored marketing.||Identification data; professional data; product data; communication details.||The data subject has given consent to the processing of his or her personal data (Art. 6(1)(a) GDPR).
The processing is necessary for the purposes of the legitimate interests pursued by BD (Art. 6(1)(f) GDPR) – legitimate interests are stated in the first column.
|Product/service development and improvement of quality and functionality of products and services.||Product data.|
|Training records of clinical and other staff||Identification data; professional data;
|Security and fraud prevention activities such as prevention of fraud, misuse of IT systems, or money laundering, physical security, IT and network security, or internal investigations.||Identification data; professional data; communication details; product data; financial or payment data.||The processing is necessary for compliance with a legal obligation to which BD is subject (Art. 6(1)(c) GDPR).
|Complying with legal obligations or standards, responding to and complying with requests and legal demands from regulators or other authorities in or outside of your home country, compliance with transparency laws governing interactions with healthcare professionals and equivalent laws and regulations, industry standards and codes such as the MedTech Europe Code of Ethical Business Practice, details of training given to distributors and other intermediaries relating to compliance.||Identification data; professional data; product data; communication details; financial or payment data.||The processing is necessary for the purposes of the legitimate interests pursued by BD (Art. 6(1)(f) GDPR) – as stated in the first column.
The processing is necessary for compliance with a legal obligation to which BD is subject (Art. 6(1)(c) GDPR).
The provision of personal data as described in this Notice is necessary for the processing purposes described above. While the provision of your personal data is generally voluntary, you may not be able to benefit from the processing purposes if you do not provide the personal data.
You should expect that we will transfer your personal data to third parties for the processing purposes as follows:
Access to your personal data is generally restricted to those individuals that have a need to know or use that data in order to fulfill their job responsibilities.
You should expect that the recipients identified above which will receive or have access to your personal data may be located inside or outside the European Economic Area (” EEA“).
Your personal data is stored for as long as is necessary to achieve the processing purposes for which the personal data is collected, in accordance with applicable data protection laws. When BD no longer needs to use your personal data for the purposes identified above, we will remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations). If we anonymize data, they no longer qualify as personal data and can no longer be attributed to you in which case we may use such data without further notice to you.
To determine the appropriate retention periods for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, whether we can achieve those purposes through other means, and the applicable legal requirements.
Right to withdraw your consent: If, in accordance with applicable law, you have declared your consent regarding certain types of processing activities (in particular regarding the receipt of direct marketing communication via email, SMS/MMS, fax, and telephone), you can withdraw this consent at any time with respect to future processing by using the methods mentioned in the original or any related communication. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. You can also withdraw your consent by contacting us as set out below.
Additional data privacy rights: Pursuant to applicable data protection law, you have the right to: (i) request access to your personal data; (ii) request rectification of your personal data; (iii) request erasure of your personal data; (iv) request restriction of processing of your personal data; (v) request data portability; and/or (vi) object to the processing of your personal data. Below please find further information on your rights to the extent that the GDPR applies. Please note that these rights might be limited under the applicable local data protection law.
You have the right to obtain a copy of the personal data undergoing processing free of charge. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
This online request form enables you to submit a request to exercise your rights under GDPR. Please fill out the below form and we will address your request.
You may exercise this right by contacting us as stated in Section 7 below. Such a right to object may, in particular, not exist if the processing of your personal data is necessary to take steps prior to entering into a contract or to perform a contract already concluded. If you have given your consent to receive direct marketing via email, SMS/MMS, fax, and telephone, you may withdraw your consent as explained above.
To exercise your rights please contact us as described below. You also have the right to lodge a complaint with the competent data protection supervisory authority in the relevant Member State (for example, the place where you live or work – contact details can be found here: https://edpb.europa.eu/about-edpb/board/members_en
If you have any questions about this Notice, wish to contact BD’s Data Protection Officer, or if you wish to exercise your rights as mentioned above, please contact us at:
By email: email@example.com
Data Protection Officer
BD Switzerland Sàrl
Route de Crassier 17,
Business Park Terre-Bonne,
Bâtiment A4, 1262 Eysins,
We may update this Notice from time to time in response to changing legal, regulatory or operational requirements. We will notify you of any such changes, including when they will take effect, by updating the “Last revised” date above or as otherwise required by applicable law.
Last revised: 22 November 2018