NEUROCLIN PRIVACY NOTICE
This privacy notice explains the reasons why we may collect, hold and use your personal data and explains your rights under the current data protection law applicable in the United Kingdom.
What do we mean by “we”?
When we say “we“, “us”, or “our”, that means NeuroClin, a limited company registered in Scotland under company number SC243637. Our registered office is NeuroClin, Excel House, 1 Renshaw Place, Eurocentral, Motherwell, ML1 4UF.
We are registered with the Information Commissioner as a Data Controller (registration no: Z9787035).
Our Data Protection Officer is provided by RGDP LLP and can be contacted either at 0131 222 3239 or info@rgdp.co.uk
WHAT PERSONAL DATA DO WE PROCESS AND WHY?
When you apply to participate in our research studies
We collect your personal information directly from you, such as when you register with us on our website, telephone, or in person at roadshows, fairs and other group events. We may also receive your personal information via a referral from your GP, or from a family member, or carer, who is supporting you.
We use your personal information for our legitimate interests in the following ways:
- To add your personal information as volunteered by you to our database and use it in accordance with your preferences to identify and notify you of clinical trials for which you may be suitable and in which you may wish to participate. This is to establish suitability for current studies and with your authorisation, to review your information in the event that future studies arise for which you may be suitable.
- To administer registration records (including reminder letters, paying your travel expenses)
- To provide details to you on information that may be of benefit to you.
- To notify you about any changes to our service. This is to keep you informed of changes that may affect our business and the services that we provide.
- To investigate complaints and queries in order to investigate and address such information provided to us in order to progress matters raised and to improve our service.
- To monitor / record telephone conversations to or from you in order to ensure best quality, adherence to our policies, to improve our service standards, resolve complaints and for staff training purposes.
- To protect the rights, property and/or safety of NeuroClin, its personnel and others associated with the organisation.
When you are on our database but you are waiting to participate in a study, we are the data controller of your personal data. We will collect data about your health, and sometimes other sensitive data related to your health, such as your ethnicity, which is defined as Special Category Data in the UK GDPR. Our legal basis for processing this Special Category Data is for the purposes of scientific research in the public interest, and to monitor your health before and during research studies.
If you are enrolled to participate in a particular study, the study sponsor will be the data controller of your personal data for the duration of that trial. We will be processing your personal data on behalf of the sponsor, under a contract with them. For further information you should read the trial sponsor’s own privacy notice.
If you are enrolled to participate in a study which involves procedures which take place outside of our organisation, this may include but is not limited to MRI scans and PET scans, the organisation performing the scan may hold your data within their systems for the purposes of the scan. The data they hold will be held in accordance with their local GDPR policies and procedures. For more information please ask a member of the study team.
If you are a family member or carer supporting someone attending our clinic for a study
We may receive your name, contact details and relationship to the study participant from your relative/friend, if not directly from you. We will use this information to contact you in relation to your relative/friend’s visits to the clinic and for emergency purposes if necessary.
When you apply for a job with us
If you click on the ‘Careers’ section of our website, you will be presented with a summary of any current vacancies that we have. If you access a vacancy and wish to apply, you will be asked to send your CV and a brief description of the vacancy that you are applying for. This will be automatically forwarded to our HR Manager. Your details will be kept for a period of up to 6 months after which they will be deleted from our recruitment database. This processing is for our legitimate interest in sourcing and recruiting the best staff for our organisation.
When you work with us
A separate Privacy Notice for our employees is available on request.
If you are one of our suppliers
We will hold contact details of third parties and employees of third parties who provide services to assist us to operate our business. We have a legitimate interest to process these contact details for the purposes of running our business. This data will generally consist of corporate contact details. We will also process your personal data in order to make payment for purchased products and/or services as per our contract with you, which may involve sharing your personal data with our accounts payable systems providers.
If you visit our premises
We have a signing-in book for safety and security of our staff and customers. We may also collect your image from our CCTV cameras which are located in our premises for security of our staff, customers and other visitors to our premises, and to assist with the prevention and detection of crime. Signs are in place where CCTV is in operation. This processing is for our legitimate interest in protecting our premises, employees and visitors.
When you visit our website
When you visit our website, we may place Cookies on your computer. Please see our Cookies Notice on our website for further information. You have the option to manage whether Cookies are placed on your device or change preferences at any time. We will also use online identifiers, namely your IP address, along with your interactions with our website, in order to analyse and further improve the website interface and performance.
If you use our Alzheimer or Parkinsons Pre-screener
When you use our pre-screener, we ask you to say whether or not you have some pre-existing conditions that may exclude you from taking part in our studies. This process is done automatically, and you have the right to object to this automated processing, and ask us to consider your circumstances directly, by contacting us at info@neuroclin.com.
Children’s Privacy
Our website is not intended or designed to attract individuals under the age of 18. We do not collect personal information from any person whom we know to be underage and therefore require you to confirm in the Contact Us section to confirm that you are over 18 years of age before completing any personal information.
Links to third party websites
Our website may contain links to and from other websites. If you follow a link to or from any of these websites, please note that these websites have their own privacy notices and that we do not accept any responsibility or liability for these notices. Please check these notices before you submit any personal information to these websites.
When you interact with us on social media
When you interact with us on social media platforms such as LinkedIn and Twitter we may obtain information about you (for example, when you like or post on our Twitter page). The information we receive will depend on the privacy preferences you have set on those types of platforms.
SHARING YOUR DATA
Third Party Marketing Partners
We use third party advertising partners for a variety of marketing services which may include but are not limited to managing our website, LinkedIn, Facebook, Twitter, Instagram, Google Analytics and YouTube.
Our marketing activity is managed by our third party processor via Mailchimp. The following data will be collected via Mailchimp:
- Email addresses (required field)
- First name (required field)
- Last name (required field)
- Consent box (I agree to receive future emails from NeuroClin (required field)
Mailing list subscribers can unsubscribe from the mailing list at any time. Neither NeuroClin Ltd nor its third party marketing partners will ever:
- Share your mailing data with any third party
- Use your mailing list to promote non-NeuroClin Ltd services
- Promote any third party on any mailing list communication
- Copy your data
- Store your data anywhere other than on our Mailchimp account
Only authorised personnel will have access to our Mailchimp account.
Google Analytics is installed onto our website and our third party marketing partner has access to the data that it collects via Google Analytics. This is used to track website use and traffic and will never be used for any other purpose. You can consent to allow the analytics to be collected, via the pop-up when you open the website home page.
We may also share your personal information with:
- Third party service providers and agents that we appoint, or who act on our behalf as locum doctors or other specialist service providers, that require access to certain personal information for the sole purpose of delivering the service on our behalf. Service providers and agents are restricted via contracts from using this information in any way other than to provide services for us, or services for the collaboration in which they and we are engaged. Advarra Inc who currently provide our Clinical Trial Management System will also anonymise (de-identify) your personal data and then use this for development and improvement of their software systems. The data being used in this way cannot then identify you as an individual.
- Emergency services in the event that we need to report an accident or illness or to request emergency assistance.
- Lawyers, accountants, auditors or similar advisors who assist with our administrative processes or whom we ask for advice.
- Police Scotland, courts, regulators (including health regulatory authorities), government authorities or other third parties , where there is a legal or regulatory obligation, or otherwise to protect the rights of any third party.
- A buyer, assignee or transferee in the event that the business or a part of it is sold, assigned or transferred.
- Investors and other relevant third parties in the event of an actual or potential sale or other corporate transaction related to NeuroClin Ltd.
- Other third parties, where we have a lawful basis to do so.
Our Clinical Study Sponsors
If you are participating in a clinical study, we will transfer statistical information relating to the study to our clinical trial sponsors. Only the statistical information, from which you cannot be individually identified, required for the study statistics and monitoring as per the relevant study protocol will be transferred. In most circumstances this information is transferred via secure electronic databases and software systems.
HOW DO WE PROTECT YOUR PERSONAL DATA?
We use security methods to protect the personal information that we process, including internet standard encryption technology. However please note that whilst we take appropriate technical and organisational measures to safeguard the personal information that you provide to us, no transmission over the Internet can be guaranteed as secure. Consequently, please note that we cannot guarantee the security of any personal information that you transfer to us over the Internet.
With regard to personal information held by us, both electronically and in paper form, we pay a great deal of attention to ensuring that information is held securely, retained in non-public areas and is accessed only by those employees and third parties who require access in order to carry out their work.
We ensure that all of our employees and data processors respect the confidentiality of your data and that information is not disclosed to government or other legal authorities unless it is required by law or for regulatory purposes.
Where we store your personal information
The personal data we collect from you may also be processed, accessed, or stored in countries outside the UK or European Economic Area (“EEA”), for example, our clinical trial management system providers are based in the USA and your personal data may be accessed by them for maintenance and support of the clinical trial management system. It may also be processed by employees and third parties who operate outside of the UK or EEA who work for one of our suppliers or affiliates. We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Policy and will put in place safeguards for personal data transfer outside the UK or EEA including but not limited to:
- Personal data will only be transferred to countries that are deemed by the UK Government to have adequate data protection procedures in place.
- Where a destination country is not deemed to have adequate data protection procedures, we will rely on International Data Transfer Agreements, or equivalent contractual clauses determined by the UK GDPR, and additional measures to ensure the security of the personal data, or with your consent.
YOUR RIGHTS
Your Rights in relation to your Personal Information
The UK General Data Protection Regulation and Data Protection Act (UK GDPR) gives you a number of rights. The right to:
- Access (commonly known as a data subject access request) to information held about you. Your right of access can be exercised in accordance with the UK GDPR. If you would like to receive details of the personal information that we hold about you, please write to info@neuroclin.com.
- Correction where personal data held about you is inaccurate.
- Erasure of your personal data – although this may not always be possible if there are specific legal reasons why your personal data must be retained.
- Object to the processing of your personal data where we are relying on legitimate interest (or those of a third party), or where we are processing your personal data automatically You can object to processing carried out on this basis by emailing us at info@neuroclin.com.
- Restriction of your personal data. This enables you to suspend the processing of your data where there is a query as to whether the data is accurate, where its use is unlawful but you want to have it retained, or where you have objected to our use of your data but we have an overriding legitimate ground to retain it.
- Request transfer of your personal data to a third party.
- Withdraw consent at any time when we are relying on consent for the processing of your personal data. This may mean we are unable to provide information and services to you. If you wish to withdraw consent you should write to info@neuroclin.com.
Please be aware that not all of the above rights apply in all circumstances.
We will respond to all legitimate requests within one month of receipt wherever possible. If, for some reason, we are unable to do so we will inform you in writing. If you wish to exercise your right to any of the above, we will require proof of identity before implementing your request. If your request is found to be unfounded, repetitive or excessive we may charge a reasonable fee for processing.
Requests to exercise your rights should be addressed to NeuroClin, Excel House, 1 Renshaw Place, Eurocentral, Motherwell, ML1 4UF or info@neuroclin.com.
If you are unhappy with the way that NeuroClin has dealt with your personal data then you can contact the Information Commissioner. Contact details are available at www.ico.org.uk/concerns
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
We retain your personal information for no longer than is necessary for the purpose for which it is collected and held. When determining relevant retention periods, we will take account of the following factors:
- Our legal obligations under applicable law to retain data for a certain period of time.
- Our obligations under contract with study sponsors / providers/ ICH-GCP Guidelines.
- The statute of limitations under applicable law.
- Other guidelines issued by relevant data protection authorities.
If no longer required, we will securely erase your identifiable information. Please note that if you have been discharged from our clinic, the records of your treatment will be destroyed, but we will store your name and date of birth indefinitely. This is necessary, in the interests of your own health, so that we have a record of whether you have applied to participate in a study before. Our retention schedule is available on request from info@neuroclin.com.
CHANGES TO OUR PRIVACY NOTICE
Any changes we may make to this notice will be posted on our website. Please check back frequently to see any updates or changes to our privacy notice. This notice is effective from 13th January 2022.
CONTACT
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to NeuroClin, Excel House, 1 Renshaw Place, Eurocentral, Motherwell, ML1 4UF or info@neuroclin.com.
Updated 8/4/24