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 Limited, 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 [email protected]
WHAT PERSONAL DATA WE PROCESS, WHY WE PROCESS IT, AND WHAT OUR LAWFUL BASIS IS.
When you visit our website
When you visit our website, we may place Cookies on your computer. Additionally, Google Analytics is enabled on our website, and our third-party marketing partners, see the section ‘Third Party Marketing Partners’, has access to the data that it collects via Google Analytics.In some instances, this may include your personal data. This is used to track website use and traffic and will never be used for any other purpose. You give your consent to allow thisanalytics data to be collected is managed via our Cookie pop-up – see our Cookie Notice for further information.
If you use our pre-screener questionnaire form, we collect your basic contact information, along with the outcomes of the pre-screener, in order to contact you to discuss next steps, such as application for any research studies. To process this data, we will request your Explicit Consent. When you complete a pre-screener questionnaire form, we ask you to statewhether or not you have some pre-existing conditions that may exclude you from taking part. This process is done automatically, and therefore you have the right to object to or contest against this automated processing. To do this and ask us to consider your circumstances directly, contact us at [email protected].
In some cases a Pre-screener questionnaire form will only collect your contact details and no further specific information. In these instances, we collect your personal information directly from you on the basis of Legitimate Interests. Your information will be stored to enable our team to contact you regarding the content of the relevant pre-screener questionnaire form.
Links to third party websites
Our website may contain links to other websites run by other organisations. This privacy notice applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other websites even if you access those using links from our website.
In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the privacy notice of that third party site.
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 and consent preferences you have set on those platforms.
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 within our various clinics. If you access a vacancy and wish to apply, you will be asked to send your CV, a brief description of the vacancy that you are applying for, along with basic contact information so that we can reach out to you. 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. We do this so that in the event you are unsuccessful for the vacancy applied for, we may contact you if a similar position becomes available. This processing is for our Legitimate Interests in sourcing and recruiting the best staff for our organisation.
Please note, where you are successful in your application, we will process your personal information in accordance with our employee privacy notice.
When you apply to participate with NeuroClin’s Services on a Clinical Study
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 indirectly via a referral from your GP, or from a family member or carer, who is supporting you.
In order to facilitate this participation, we will add your personal information, as volunteered by you or from indirectly as described above, to our database and use it 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.
When we process your personal information for these purposes, we will rely on Legitimate Interests as our lawful basis, as required under the UK GDPR.
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 such as your ethnicity, which is defined as Special Category Data under the UK GDPR. When we process your Special Category Data, we require a further lawful basis under Article 9 of the UK GDPR, of which we rely on the processing being necessary for the purposes of scientific research in the public interest.
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 refer to your study informed consent form and/or read the trial sponsor’s own privacy notice.
Our Early Detection & Private Treatment Pathway for Alzheimer’s
In order to provide Stage 1 of this service, we will obtain your Consent to process your basic contact information, and share this with our trusted partners, for the completion of remote memory tests and lifestyle questionnaires.
Following completion, and depending on patient suitability, you may be eligible for Stage 2 and onwards of this service, where we carry out additional procedures and assessments as detailed within the relevant Terms and Conditions. When processing your personal data within these stages of the Early Detection pathway, including when taking payment, we will rely on Article 6 (1) (b) Contract. Processing of your health data will be carried out under Article 9 (2) (h), where processing is necessary for the provision of health care / treatment.
If you are a family member or carer supporting someone attending our clinic
We may receive your name, contact details and relationship to the patient, 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.
This processing is carried out under Legitimate Interests or Protecting Vital Interests, asour lawful basis under the UK GDPR.
Where you intend to fulfil the role of study partner, we will require your full name. We will obtain your consent for processing this personal data.
If you are a supplier, contractor, or other current or prospective business contact
We may collect your business contact details such as your name, business address and business e-mail, and your company’s bank account details. If you are a sole trader, much of this may be your personal details. We need these details in order to provide our services, maintain any contractual agreement we have with you or your business, and pay or invoice suppliers and contractors.
If you are a potential business contact, proposing to offer services to us, we may process your personal data in relation to entering into a contract with you or your organisation.
Where our contract is directly with you, where you are a sole trader for example, our lawfulbasis for the processing is Contract. Where our contract is with your employing organisation, our lawful basis for processing your personal information is for our Legitimate Interest in providing and maintaining any service agreement.
When you visit our premises
We have a signing-in book in which we collect your basis contact information, and we may also collect your image via our CCTV cameras, which are located in our premises. Both these activities are undertaken to ensure security of our staff, customers and other visitors to our premises, and to assist with the prevention and detection of crime. Appropriate signage is in place where CCTV is in operation, including necessary contact information for us, should you have any queries or concerns. This processing is for our legitimate interest in protecting our premises, employees and visitors.
Other uses of your personal information
We may also use your personal information for our legitimate interests in the following ways:
• To administer registration records (including reminder letters and paying your travel expenses)
• 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 and respond to complaints or queries in order to progress matters raised and to improve our service.
• To contact you if you have been noted as a reference of an individual who is applying for a vacancy at NeuroClin.
• 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 undertake analytics of your interaction with our website, to continually improve functionality, design, and user-interactivity.
• To protect the rights, property and/or safety of NeuroClin, its personnel and others associated with the organisation.
SHARING YOUR DATA
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.These may include our marketing partners, for the purpose of managing our various marketing channels, sharing data with specialist third parties for conducting certain scans or assessments, or for the provision and storing of data within a clinical trial management system. We will only share the information absolutely necessary for the provider to carry out their services, including pseudonymising your identifiers where possible, and will only share your information where we have your consent to so, or where it is otherwise lawful.
• 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 Limited.
• 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 study 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.
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 submitting any personal information.
HOW DO WE PROTECT YOUR PERSONAL DATA?
We use security methods to protect the personal information that we process electronically, including internet standard encryption technology, implementing pseudonymisation where possible, enforcing a number of access management and authentication controls on our various accounts and devices. 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 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 services. 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.
STORING YOUR PERSONAL INFORMATION
The personal data we collect from you may also be processed, accessed, or stored in countries outside the UK. 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 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 appropriate controls and safeguards for personal data transferred outside the UK 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 standard contractual clauses incorporate the UK Addendum, recognised by the UK GDPR, and additional measures to ensure the security of the personal data, or with your consent.
During the period we store your personal information, we will take reasonable steps to ensure the information is accurate and up to date; however please help us keep our records updated by informing us of any changes to your email address and other contact details as they occur.
HOW LONG 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. We review our retention periods on a regular basis and maintain this information within our Data Retention Policy & Schedule.
YOUR RIGHTS
You have a number of rights in relation to the personal information we hold about you, and we will ensure that you can exercise these rights accordingly.
Please note, these rights are not always absolute and certain conditions may apply. Where applicable under UK data protection law, and subject to these conditions, you are entitled to:
| Right | Description |
| Right to be informed about how we process your personal data. | You have the right to be informed about the collection and use of your personal data. |
| Right to access your personal data, commonly known as a “Subject Access request” (‘SAR’). | You have the right to request a copy of the personal data that we hold about you. |
| Right to rectification of the personal data that we hold about you. | You have the right to ask us to rectify personal data that you believe is inaccurate or incorrect. This includes the right to have information completed which you believe to be incomplete. |
| Right to be forgotten / right to erasure of your personal data. | You have the right to ask us to erase your personal information in certain circumstances. |
| Right to object to processing of your personal data. | You have the right to object to the processing of your personal data in certain circumstances. |
| Right to the restriction of processing of your personal data. | You have the right to ask us to restrict the processing of your personal information in certain circumstances. |
| Right to data portability. | You have the right to ask that we transfer the personal data that you provided us with to another organisation, or to you, in certain circumstances. |
| Right not to be subject to an automated decision. | When a decision is based on automated processing, and produces an adverse legal or similarly significant effect, you have a number of rights in relation to that decision. |
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.
If you wish to exercise any of your rights, are unhappy with the way that NeuroClin Has used your personal information, or have any other concern regarding anything in this privacy notice, we endeavour to assist you where we can. We ask that you reach out to us using the contact information below:
NeuroClin, Excel House, 1 Renshaw Place, Eurocentral, Motherwell, ML1 4UF
[email protected].
You also have the right to complain to the Information Commission, which you can do so via here: Make a complaint | ICO
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 US
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 [email protected].
Last Updated: 07 January 2026