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Banner Image of Non-Promotional Activity

Photo, Video and Cell Etiquette

In today’s technology-driven world, it is common for individuals to record, photograph, or videotape themselves and others as part of their daily activities. However, many may not be aware that recording, photographing, or videotaping people without their consent while on private property or at their workplace can violate state and federal privacy laws, including the privacy rights of those who have not given permission for such recordings.

Quick Tips:

  • Recording or photographing during training meetings or sales training are generally not permitted unless as part of the corporate- approved curriculum or under an exception for compliance, safety or other protected activity or concern.
  • Phone calls should be taken outside of offices, pharmacies and HCIs. Telephone calls and use of text or emailing inside these areas can be distracting to patients and office staff and may create an impression of insensitivity to those around you.

Photos and Videos

Bausch + Lomb employees are expected to uphold a high level of professionalism and confidentiality at all times. Recording or photographing actual or simulated sales calls, training sessions, Promotional Materials, healthcare professionals, office staff, patients, samples or sample storage areas, lunch-and-learns, office forms, prescriptions, or patient charts is strictly prohibited unless explicitly approved by Legal.

Although such recordings or photographs may seem innocuous, they should be avoided unless written authorization is obtained. If an HCP requests that you record a sales call or any other interaction, you should politely decline and immediately inform your manager.

Recording or photographing during training meetings or sales training sessions is not allowed unless it is part of the corporately approved curriculum. During these meetings, you may be exposed to proprietary information, and appropriate measures should be taken to maintain its confidentiality.

Phone Calls

Phone calls should be conducted outside of offices, pharmacies, and healthcare institutions (HCIs). Taking calls within these environments can distract patients and staff and may be perceived as inconsiderate. Bausch + Lomb colleagues should also remain aware of their surroundings when making calls, sending texts, or emailing in any healthcare setting, as these actions can have a similar disruptive effect. While inside offices, pharmacies, and HCIs, please minimize the use of loud or flashing ringtones and notifications on smartphones or other handheld devices.

Bausch + Lomb Colleagues are not permitted to use cameras or other recording devices (audio, visual or both) while in a healthcare setting (office, pharmacy, HCI, etc.) or other location where PHI may unintentionally be recorded while conducting business, with the exception of situations involving a potential compliance, patient safety concern, or employee safety or other concern related to employee protected concerted activity. This includes the use of cameras or recording devices employed or accessed using a smartphone or other tech devices.

It is the responsibility of all of us to safeguard patient data and maintain confidentiality at all times. Representatives must avoid discussing patient personal data, including health information, or confidential business information in public areas or offices where unauthorized Third Parties might be overhearing. Additionally, caution should be exercised when traveling or working remotely to ensure that confidential information remains secure.

For any questions or further guidance on protecting personal and confidential data from unauthorized disclosure, please contact Bausch + Lomb’s Global Privacy Office at IR-Privacy@Bausch + Lomb.com.