July 30, 2020
GCO Compliance guide
In these uncertain times, due to the ongoing pandemic, it is imperative to ensure continuity of communication by virtual means. While engaging online with external speakers, it is therefore, essential to maintain the awareness of industry guidelines and internal standard operating procedures related to compliance.
Below are a few compliance considerations for Virtual Meetings:
- Content vs. Participant Locations: The content of the meeting should be suitable for all participating countries. There may be restrictions depending on the origins or location of meeting participants.
2. Compliance with applicable national and international industry codes and laws.
3. Internal and external compliance/legal approvals such as:
– General internal (virtual) meeting approval (i.e., business reason and the details of the event)
– Speaker engagement approvals (i.e. approvals for chosen speakers on the assignment)
– Attendee approval (the number and type of attendees)
– Approval of content
4. Contracts with external speakers should be in consultation with organizations own legal department. In addition to standard clauses, such as honoraria payment responsibilities and transparency disclosures, include clause(s) related to the speaker’s recording material (voice or video), identifying:- Who will hold the rights to that footage/recording?
– What purposes will the (voice or video) recording be used for?
– What personal information may/will be displayed with the footage (name, specialty, and degree)?
5. Ensure all external non-contracted attendees:
– Provide their consent to the terms and conditions related to data privacy & usage of their data.
– Provide their consent to the non-disclosure terms (if applicable). It can also be included in the event registration website
6. Contracts with technology suppliers: An audiovisual/virtual platform supplier should be properly contracted. Clauses concerning privacy/GDPR and handling of data breaches thereof; processing of collection of personal data and confidential information; NDAs (non-disclosure agreements); data security and data retention period should be included.
7. Event Insights: Ensure that the audio visual / virtual supplier can track attendance during the meeting with the appropriate level of detail.
8. Security of your registration website and virtual meeting platform – ensuring only the approved attendees can see/have access to the provided content.
9. Due diligence: Use approved or preferred suppliers. Ideally those that have been through a thorough data security and data management assessment during the RFP process.
10. Reporting: After the event occurs, the applicable transparency reporting of ToVs (Transfers of Value) should be completed (according to applicable local and international laws and industry regulations).
GCO Compliance Guide for Pharma Virtual Meetings
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