SLA Pharma AG Privacy Notice
SLA Pharma AG (“we” and “us”) are a niche biopharmaceutical company, specializing in gastrointestinal and allied disorders, with products in clinical development and already approved for human use. In order to undertake the work we do, we process personal data. The personal data we process depends on whether we are acting in our capacity as a Sponsor of a clinical trial or managing our business relationship with you.
If you wish to contact us regarding your personal data and data protection, please send an email to email@example.com
Information About Us S.L.A Pharma UK Ltd.
Limited registered in England under company number 3370027
Registered address: 3a Chestnut house, Farm close, Shenley. Hertfordshire
Data Protection Officer: Joe Stock
Email address: firstname.lastname@example.org
What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
SLA Pharma AG as a Sponsor
Where we act as a Sponsor of a Clinical Trial, we will only ever process personal data about you in line with the information you received when you consented to be part of the trial. This information will be contained within your Informed Consent Form and Patient Information Sheet.
For Clinical Trials, we will only receive pseudonymised data about you. This means any information which can be directly attributed to you will be replaced with a unique code. We do not receive your name, contact details or date of birth.
Please refer to your Patient Information Sheet for specific details on your trial, or feel free to contact your Hospital where you undertook the Clinical Trial or us directly (details below) for a copy of that information.
SLA Pharma AG in managing business relationships
Where we process personal data in relation to our business relationship with you, the personal data we collect will be that that you provide to us, including name, contact details and the company you work for.
What Are My Rights?
GDPR provides certain rights to individuals in regards to your data. These rights do have some exemptions however, and whether you can exercise them will depend on whether you are a clinical trial participant or business contact.
- a) The right to be informed about our collection and use of your personal data.
- b) The right to access the personal data we hold about you.
- c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
- d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have
- e) The right to restrict (i.e. prevent) the processing of your personal data.
- f) The right to object to us using your personal data for a particular purpose or purposes.
- g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Further information about your rights can also be obtained from the Information Commissioner’s Office.
If you wish to exercise any of your rights, please contact us at DPO.email@example.com and we will respond to your request within one month.
How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data.
Where we are Sponsor of a Clinical Trial, it is considered in our legitimate interest to undertake research into clinical advancements where you have consented to be part of the research. As we process your health data for research purposes, GDPR allows a specific exemption for us to process for this purpose. We will only use this personal data for the purposes of the Clinical Trial.
Where we use personal data in managing business relationship, we process your personal data because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for the following purposes:
Providing and managing your account
Supplying our products OR services to you (Your personal details are required in order for us to enter into a contract with you.)
Personalising and tailoring our products AND/OR services for you
Communicating with you. This may include responding to emails or calls from you
Supplying you with marketing information by email AND/OR post that you have opted-in to (you may unsubscribe or opt-out at any time by emailing the following email address: firstname.lastname@example.org.
How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. For Clinical Trials, there are defined retention periods in clinical trial laws for holding your personal data. This is 15 years in the UK and 25 years in the EU. For business relationships, we will hold the data for no longer than is necessary or until you request us to no longer contact you.
How and Where Do You Store or Transfer My Personal Data?
If you are involved in a Clinical Trial, your personal data may be transferred outside the EEA, dependent on the trial. Please see below for how to access information on your specific trial. Where this is done, it will only be to a country that is considered to have adequate levels of data protection, or with added safeguards to ensure your personal data is protected.
Do You Share My Personal Data?
When processing personal data for a Clinical Trial, your hospital will share your personal data with organisations who are contracted to provide different services to assist the clinical trials, such as drug safety organisations, electronic record companies and labs. These organisations work under a strict contract and can only process any personal data under the terms set within that contract.
For our business relationships, we will not share your data unless in some limited circumstances, where we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
SLA Pharma AG also have a Swiss company (SLA Pharma AG) and an Irish company (SLA Pharma AG IE)
You may contact any company in regards to your data protection rights on the contact details below.
How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of the SLA Pharma AG UK Data Protection Officer:
Email address: DPO.SLApharma@kdpc.uk
For queries to the Swiss and Irish company, please contact: email@example.com
You have the right to make a complaint to the UK regulator for data protection, the Information Commissioners Office if you are not happy with any aspect of processing personal data. They can be contacted at https://ico.org.uk/.
Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available at www.slapharma.com