Investigator and Site Staff Member Privacy Notice

Effective 04 September 2022​

1. Objective

This Privacy Notice describes how Allucent collects, uses, stores and discloses the Personal Data that you supply to us and your rights regarding the data that we hold about you.

2. Introduction

Allucent, operating through all CATO SMS and Pharm-Olam affiliates (collectively “we”, “us” or “Allucent”) is committed to complying with all applicable laws and regulations relating to privacy, the processing of Personal Data and data protection, and/or any state, national or other jurisdictional laws implementing these laws and/or regulations including, but not limited to the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and any applicable national implementing laws, regulations and secondary legislation, as amended or updated. Looking after the personal information you share with us is very important and we want you to be confident that your Personal Data is kept safely and securely and to understand how we use it for our internal business purposes.

At all times your data will be treated in accordance with this Privacy Notice. This Privacy Notice replaces any previous notices you may have been sent.

Allucent, operating through all CATO SMS and Pharm-Olam affiliates

Data Protection Officer:
Natasa Spasic
Data Protection Officer
Ph: +49 (0) 89 3750899 35

3. Terms and Definitions

Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

Personal Data means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

4. Why Do We Process Your Data?

Allucent collects information about personnel working for organisations that have been or will be contracted to provide services for one or more clinical trials and stores this data in its database in order to contact individuals for possible participation in future trials.

5. Based on What Do We Process Your Data?

Allucent collects and processes this data based on the legitimate interests pursued by Allucent or its affiliates, which is to: a) maintain a database of contact information of clinical trial staff at investigator sites who could be contacted in the future for participation in upcoming clinical trials, as well as to assess the previous site performance when proposing sites to potential clients as part of feasibility processes and build metrics of study performance e.g. patient recruitment, start up timelines, and b) to conduct feasibility activities for potiential Sponsors of clinical trials.

When relying on legitimate interests as a reason for processing data, Allucent ensures that those interests will not override the rights and freedoms of individuals.

6. What Data Do We Collect and How?

Allucent may collect your data in a variety of ways. For example, data is collected through feasibility questionnaires, study contact lists, CVs or resumes, study specific forms, etc, as well as from an online tool with lists of investigators per specialty (eg. indication and trial phase) that collects the Personal Data of investigators from the public domain. We store this information in our secure database that allows it to be used in multiple studies.

For feasibility purposes, Allucent collects information about you via feasibility questionnaires and also from publicly available sources, such as: full name, role, contact telephone number, contact fax number, work e-mail address and associated institution name and address.

Allucent collects information about you when you start to work on a study with us and stores it in its database for future use, such as: full name, common title, study role, job title, contact telephone number, contact fax number, mobile number (if needed), primary work e-mail address, medical qualification, work correspondence address, organization, area(s) of expertise, studies you have worked with us on (optional) and when you started working on the study.

7. Storage and Security

Data is stored securely in a central database and the system used by Allucent. Allucent uses appropriate technical or organizational measures to process Personal Data in a manner that ensures appropriate security of Personal Data, including protection against accidental or unlawful destruction, loss, alteration, unauthorized access to, or disclosure.

8. Recipients and Transfers to Third Parties

While processing your Personal Data for the purposes indicated above, certain internal recipients from Allucent may have access to the data as applicable for the purpose of processing, such as staff maintaining the central database, senior management and internal staff working on feasibility and proposals for potential studies.

Allucent will share your identifiable Personal Data with external recipients, such as potential Sponsors, only when they provide you with their privacy notice and assume controllership of your data as part of a potential study. Otherwise, Allucent will share only blinded information about site performance with Sponsors.

9. Cross-Border Data Transfers

Allucent works in multiple countries and therefore your data may be subject to cross border data transfers. For these purposes, appropriate safeguards are in place, such as standard contractual clauses or other safeguard mechanisms approved by applicable laws.

10. Retention

Your Personal Data will be stored for no longer than necessary considering the purposes it was collected for.

11. Your Rights

You have the right to ask Allucent to access your data on request, change incorrect or incomplete data, object to the processing of your data, delete or stop processing your data.

If you would like to exercise any of these rights, please contact Allucent´s Data Protection Officer listed above. Some of the abovementioned rights may be limited depending on the applicable laws.

In some jurisdictions, you can raise a complaint to the relevant supervisory authority for your region if you believe that the Allucent has not complied with your data protection rights.

12. Changes to this Privacy Notice

Allucent reserves the right to update this privacy notice at any time and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your Personal Data.