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Disclosure of 2019 TOVs in the UK

Did you eagerly log onto the Disclosure UK portal on 1st July to look for information on transfers of value made in the UK last year? You might have been surprised to find that there was NO disclosure of individual transfers of value at all. There is however, a very clear and understandable reason for this.

The process through which disclosure works in the UK is unique. Companies must submit their disclosure information to the Disclosure UK portal by 30th March each year. The portal is hosted by the ABPI, and during the course of Q2, the ABPI conduct data matching and verification of all the submitted data (this allow visitors to the portal to see all the TOVs for individual HCPs and HCOs regardless of company). As part of this, the ABPI contact all individual HCPs and organisations to notify them of the information that will be disclosed on the portal. Obviously, the timing of this activity this year coincided with the focused response of HCPs and HCOs to the COVID-19 pandemic. A decision was made not to put any additional pressure on individuals or organisations, and these communications have not been sent.

As this step is part of the agreed processing of personal information by the ABPI, the knock on effect is that the ABPI & PMCPA decided to temporarily publish data in a different way such that TOVs have been published in aggregate, and have not been broken down by individuals and organisations. Many companies have published full details of their data on their own websites, however this varies dependent on individual company policy. The ABPI & PMCPA will assess when and how they will publish full disaggregated data at a later date.

A full statement from the ABPI is available here.

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