How should companies publish data about deceased health professionals?

Data protection legislation only applies to information which relates to an identifiable living individual. Information relating to a deceased person does not constitute personal data and therefore is not subject to data protection legislation.

However, whilst it might be lawful to publish this information on Disclosure UK, companies will rightly wish to remain sensitive to such a case. If a company is contacted by next-of-kin or employer regarding information published on Disclosure UK about a deceased health professional, the company will need to handle these on a case-by-case basis, and should include its approach in the relevant methodological note.

The ABPI and PMCPA expect companies to react sensitively, while also balancing transparency in their interactions with health professionals, against the nature of the request, and the ToV in question.