Important Q3 Life Sciences Compliance and Transparency Developments and Updates

By Michael Arbini

Polaris is pleased to provide compliance and transparency developments and updates that took place in Q3 that may have an impact on your business:


Recently, our team conducted a research project to collect information regarding consent and individual disclosure in the 2015 EFPIA reporting cycle.

Based on our findings, Iceland had the highest rate of consent, followed by Switzerland, the UK, Italy and Lithuania. These countries each had 70% individual consent rates or higher. The lowest reported consent rate was in Greece, with an effectively 0% HCP consent rate. Other countries with very low reporting rates included Poland, Croatia, and Spain, with less than 25% individual consent.

We also analyzed the data for the total amount of reported value transfers per country. Germany had by far the highest amount of spend reported, with just under 7.5 EUR per capita (600 million EUR total) spent. This included almost 400 million EUR spent specifically on R&D – more than double that of what most other countries reported overall.


As we covered in our last edition, in July 2016 the EU-US Privacy Shield was launched to replace the EU-US Safe Harbor. The Department of Commerce laid out the five steps for companies to self-certify.

As a data processor, Polaris self-certifies that we adhere to the protections set out in seven Privacy Shield Principles, which provide greater protections and transparency on how personal data is transferred, used and protected. The process Polaris followed is outlined below:

  • We confirmed that Polaris is eligible to join the Privacy Shield – all entities that fall under the jurisdiction of the Federal Trade Commission (FTC) or the Department of Transportation (DOT) are eligible (Polaris is under the jurisdiction of the FTC).
  • Then, we created two (2) Privacy Policies (one for Polaris Management and one for Polaris Solutions) that reference our adherence to the Privacy Shield, explain our information handling practices and the choices we offer individuals with respect to the use and disclosure of their personal information.
  • Lastly, we named the Better Business Bureau (BBB) as our dispute resolution mechanism and registered our Privacy Policies with them.

Check back each month for more updates.