Privacy statement
We take very seriously our obligations to protect the privacy of our partners including our clients, their employees and business partners as well as that of the participants in all Clinical Trials conducted by our clients and/or ourselves.

This privacy policy has been updated to be consistent with the requirements of the EU General Data Protection Regulation and describes how we collect and use personal information. It also explains how to obtain further information on the data we hold.

Tools4patient.SA. is registered as a Data Controller with APD (Autorité de protection des données) (Registration number 10DJZ2ZD).

How we use your information

We hold personal information where this is necessary to interact with our business partners including their employees; our clients (e.g. Sponsors); our suppliers (e.g. Clinical Investigator Sites) and any other business partners such as worldwide regulatory agencies for the purposes of agreeing or executing project contracts with them.

When business partners disclose information to us we assume that they have the necessary agreements in place with the other parties for this disclosure.

We also hold pseudonymised data information from subjects participating in clinical trials conducted by our clients or by ourselves. This supports the clinical trials data analysis. Prior to participating in a clinical trial, the subjects receive, in the informed consent document, the information regarding the collection, storage, transfer, and use of their data. Those data are always pseudonymised and in some circumstances anomimyzed.

Information that we hold

The information that we hold, related to our business partners, includes business and individual names, business addresses, business email addresses and telephone numbers. It also includes financial information necessary for the processing of payments.

We do not collect any sensitive personal data from our clients or business partners.

No sensitive personal data will be collected relating to participants in Clinical Trials with the very rare exception that it may be necessary to copy an exhibit during an audit of a trial to provide evidence of an issue. In the rare even that this is necessary, all identifiers such as patient name or date of birth will be redacted at the point of collection leaving only the patient number visible.

How your data are stored and protected

Information may be stored electronically in our IT systems and infrastructure, or in our offices with required protection measures to limit uncontrolled access.

We will not supply personal information from a business partner to any third party without explicit permission, except as necessary to complete our contracts with this business partner or to fulfil our business or legal obligations

We will not knowingly transmit your information outside of the EEA unless necessary to perform an agreed project, for example agreed communications with a US employee of one of our business partners, agreed communication with a Regulatory Agency or in preparation for an audit of a site in a third country.

How long do we retain information

We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary to complete our agreed projects, fulfil contract terms or as required by laws or regulatory guidelines related to the project activities or general business obligations such as financial records.

Since most of our projects relate to regulated Clinical Trial activities, it is likely that most records will be retained for many years unless we are notified by our clients that this retention is no longer necessary. As a minimum, records of all activities, including correspondence, will be retained for at least 6 years.

We review our records annually to ensure that we are not holding unnecessary information.

Access to personal information/your rights

Tools4patient will be as open as we can be in terms of giving people access to their personal information. If we do hold information about you, we will:

give you a description of it
tell you why we are holding it;
tell you who it could be disclosed to; and
let you have a copy of the information in an intelligible form.
If we do hold information about you, you can ask us to have access to it and correct any mistakes.

You have the right to ask us not to use your personal information in the future and to remove your details from our databases and mailing lists.

We would also like to contact our clients periodically to provide general updates on information that we think may be of interest (e.g. changes in regulations) or updates on services that we offer. If you or any of your employees wish to be removed from our mailing list for general communications, you may at any time unsubscribe directly from Tools4Patient’s newsletter through “unsubscribe option” (always available) or send a message to us at dpo@cognivia.wpengine.com and we will take immediate action.

You also have the right to ask use to erase stored information about you and we will do this unless continued storage is required as part of a contractual, legal or regulatory obligation.

All requests relating to your personal information should be sent to us in writing at our registered offices and by email to DPO@cognivia.com.