Sanofi: complaint about unsolicited Toujeo webinar invitations by email (no breach) | AUTH/3471/2/21 | PMCPA Case

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Key facts

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Case number	AUTH/3471/2/21
Company	Sanofi
Complainant	Contactable complainant (described as a nurse)
Product	Toujeo (insulin glargine 300 U/ml)
Issue	Alleged unsolicited promotional emails (Toujeo Coach webinar invitations) and alleged pressure on representative; GDPR concern raised
Applicable Code year	2019
Clauses considered	1.11, 9.1, 9.9, 15.2
Decision	No breach of the Code
Complaint received	5 February 2021
Case completed	9 August 2021
Appeal	No appeal
Additional sanctions	None stated

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Reviewed by Dr Anzal Qurbain (FFPM) — ABPI Final Signatory

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What happened

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A contactable complainant (described as a nurse) said that towards the end of 2020 a Sanofi representative emailed “Toujeo Coach” webinar invitations.
The complainant alleged they had not given Sanofi or the representative permission to use their email address and considered this a GDPR issue.
The complainant said the representative apologised and stated they were under pressure because permissions to email and emails sent were being tracked by Sanofi, and low performers had been made redundant.
The complainant did not name the representative and asked the PMCPA to look into the matter anonymously.
Sanofi assumed the complaint related to invitations sent in November 2020 to a Sanofi UK-led webinar on 19 and 26 November 2020: “Additional Support for your Toujeo Patients (Insulin glargine 300 U/ml); Toujeo Coach Q&A Webinar”.
Sanofi said representatives were provided with certified materials (email invitation ref MAT-GB-2004596 v1.0; briefing document ref MAT-GB-2004594 v1.0) instructing that emails should only be sent to Toujeo prescribers who had consented to receive direct promotional marketing emails.
Sanofi described its CRM consent flagging, training on consent requirements, and stated there were no activity metrics from March 2020 onwards for input measures such as expected/actual customer contacts.
Sanofi also explained a September/October 2020 diabetes sales force reorganisation that included retrospective assessment of customer email consent and virtual meeting participation (together up to 25% of selection score), but said there was no incentivisation tied to sending webinar invitations.

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Outcome

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No breach of the Code.
The Panel found there was insufficient information to allow Sanofi to identify the specific circumstances or determine whether the complainant had given permission to be contacted by email.
The Panel did not consider the complainant had established the case on the balance of probabilities.
The Panel found no information before it that Sanofi had breached GDPR as alleged.
No breach of Clauses 1.11, 9.1, 9.9 and 15.2.

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Sanofi: complaint about unsolicited Toujeo webinar invitations by email (no breach) | AUTH/3471/2/21

Key facts

What happened

Outcome

Clauses considered

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