Cell Therapy Catapult Limited Privacy Policy

PRIVACY NOTICE

WHAT IS THIS PRIVACY NOTICE FOR?

This privacy notice is for data collected by the Cell Therapy Catapult Ltd (CGT Catapult) for the purposes of developing and running our operations.  We may collect personal data such as name, profession, phone numbers, email, work place, dietary requirements relating to business development via our website or through any interactions we have with you at events or other correspondence.  This notice informs you about how we protect your privacy and sets out the different areas where your privacy is concerned, outlining the data which is collected, the way it is processed, where it is stored and how long it is retained.

WE ARE A DATA CONTROLLER

CGT Catapult is a Controller of the personal data that you (the data subject) provide to us.  We take data protection and security very seriously. Your data will only be available to relevant employees who need access to it, our policy is to only use data processors who agree to data sharing standards in line with GDPR requirements.  We maintain a Data Protection policy which governs the use and storage of all data that we process.

ABOUT YOUR DATA

Users contacting any of CGT Catapult’s services do so at their own discretion. Your personal information is kept private and stored securely until a time it is no longer required, has no use or you request for it to be deleted, in accordance with GDPR and your rights, listed below.

CGT Catapult regularly uses information you submit to provide you with further information about the products/services that it offers or to assist you in answering any questions or queries that you may have submitted. This includes using personal details to subscribe you to any email newsletter program CGT Catapult operates but only if this was made clear to you and your express permission was granted.

EVENTS AND COMMUNICATIONS

CGT Catapult operates a contact program, used to inform subscribers about events, white papers, scientific research, sector specific news, products and services that CGT Catapult offers.   Users can subscribe through an online automated process should they wish to do so, but they do so at their own discretion. Some subscriptions may be manually processed through prior written agreement with the user.

All personal details relating to subscribers are held securely and in accordance with the GDPR.

Email marketing campaigns published by CGT Catapult may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates, frequency of activity, IP organisation, IP address, company name, country, state, postcode.

This information is used to refine future email campaigns and to supply the user with more relevant content based around their activity.

CGT Catapult processes this data using the lawful basis of either legitimate interest or consent.

In compliance with data protection and electronic communications regulations, subscribers are given the opportunity to unsubscribe at any time through an automated system. This process is detailed in the footer of each email campaign. If an automated un-subscription system is unavailable, clear instructions on how to unsubscribe will by detailed instead.

EVENTS HOSTED BY CGT Catapult

CGT Catapult may host events and require additional information for the organisation of such events. All personal details regarding attendees are held securely and in accordance with the GDPR. The additional information required may include but is not limited to biographies, dietary requirements and accessibility needs. CGT Catapult will share this information with third parties, such as the caterers only to the level required to allow for organisation of the event. Such information will be retained according to our Data Retention Policy. 

GCT Catapult WEBSITE

The CGT Catapult website contains tracking facilities. Browsers’ activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include: IP organisation, IP address and country.

EXTERNAL LINKS AND EMBEDDED CONTENT

Although CGT Catapult looks to only include quality, safe and relevant external links and content, users are advised to adopt a policy of caution before clicking any external web links mentioned throughout this platform.

External links are clickable text/banner/image links to other websites. Embedded content may include videos from other platforms such as Youtube, Vimeo, Wista etc.

CGT Catapult cannot guarantee or verify the contents of any externally linked website or embedded content despite their best efforts. Users should, therefore, note they click on external links or content at their own risk and CGT Catapult cannot be held liable for any damages or implications caused by visiting any external links mentioned.

SOCIAL MEDIA PLATFORMS

Communication, engagement, and actions taken through external social media platforms that CGT Catapult participates on are covered by the terms and conditions as well as the privacy policies held with each social media platform respectively.

CGT Catapult will never ask for personal or sensitive information through social media platforms and encourages users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.

CGT Catapult may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.

TRIALS PARTICIPANTS

The main reasons that we collect data regarding trials subjects are:

  1. Trials subjects – we provide clinical research to subjects who have consented to a clinical trial.  We will hold pseudonimised data on you, which means that we are unable to identify your name or further personal information.  All correspondence will remain with the holder of your master record, which is the body where you signed up for the trial.  By working in this way, we can maintain your privacy and collect only the information we need to undertake the trials.  Clinical trials are only carried out with your informed consent and your rights are further explained on the ‘informed consent form’ that you will be asked to sign.  Clinical trials data is retained for 30 years. We might publish results of trials, but before we do we will ensure that all personal information is removed from any report.

In providing these services your data may be shared with regulators.

We also use some of your personal data in our legitimate interests, we do not think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service. However, you do have the right to object to us processing your personal data on this basis.

  1. Support services – we might collect and hold personal information in providing supporting services, for example:
    1. Managing enquiries
    2. Managing complaints

CLIENTS AND COMMERCIAL PARTNERS

The main reasons that we collect data regarding clients and commercial partners, which will include other partners such as academics wishing to work with Cell Therapy Catapult are:

  1. Managing relationships – We will collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses.  We may also hold extra information that you or someone in your organisation has chosen to tell us.  We hold this information in order that we can maintain a relationship with you and enter into contractual arrangements etc.
     
  2. Managing finances – We may collect personal information in relation to our Finance processes such as bank details, so that we can pay you. In certain circumstances, such as when you engage with our Finance teams, we may share information with other third parties such as debt recovery agents.
     
  3. Licensing and IP – If you are partnered with us on a new therapy or manufacturing process then some limited personal data may be included in our licensing applications.  In general, these will be shared with the MRHA which is a UK entity, however it is possible that information might also be passed to other licensing authorities outside of the EEA.  In these cases, we will ensure that your data is protected by recognised safeguards as detailed in the international section of this privacy statement.
     
  4. Meeting mandatory requirements – we will collect personal information in the process of managing our clinical trials and supporting services in a compliant manner.  We need to obtain and maintain personal information to evidence clinical trials safety, such as identification and career and qualifications records, medical information to support incident investigations, and records of training courses.  Where we collect any sensitive information, we ensure that we have a lawful reason, or we obtain your explicit consent.

    Where information is collected to support the manufacture of pharmaceuticals we will retain this information for 7 years.  If the personal data is required to support clinical trials, it will be retained for 30 years to meet our regulatory obligations.

    In providing these services, your data may be shared with official agencies such as clinical trials regulators.

We also use some of your personal data in our legitimate interests, we do not think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service. However, you do have the right to object to us processing your personal data on this basis.

  1. Marketing and developing our business – we may from time to time collect personal information from you or other sources to help us to grow our business, such as when you provide us with a business card or we obtain your information at conferences etc.  If we do obtain information in this way we will inform you of our intention to use it in the development of our business,

    We will always respect your right to restrict this type of processing of your personal data by providing you with the opportunity to opt-out of these types of communications.
     
  2. Support services – we might collect and hold personal information in providing supporting services, for example:
    1. Contacting individuals in relation to press releases
    2. Collating and managing business proposals

SUPPLIERS

The main reasons that we collect data regarding suppliers are:

  1. Managing relationships – We will collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses.  We may also hold extra information that someone in your organisation has chosen to tell us.
     
  2. Managing finances – We may collect personal information in relation to our Finance processes such as bank details, so that we can pay you. In certain circumstances, such as when you engage with our Finance teams, we may share information with other third parties such as debt recovery agents.
  1. Meeting mandatory requirements – we will collect personal information in the process of managing our clinical trials and supporting services in a compliant manner.  We need to obtain and maintain personal information to evidence clinical trials safety, such as identification and career and qualifications records, medical information to support incident investigations, and records of training courses.  Where we collect any sensitive information, we ensure that we have a lawful reason, or we obtain your explicit consent.

    Where information is collected to support the manufacture of pharmaceuticals we will retain this information for 7 years.  If the personal data is required to support clinical trials, it will be retained for 30 years to meet our regulatory obligations.

    In providing these services, your data may be shared with official agencies such as clinical trials regulators.

HOW LONG WE KEEP YOUR DATA

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or reporting requirements.  Please ask to see our Data Retention Policy for more information on our personal data retention schedule.

WHERE YOUR DATA IS PROCESSED AND STORED

CGT Catapult assesses any data processor it engages in relation the processing of your personal data.  As part of this assessment we ensure that we have a relevant data processing agreement in place.

We do not normally transfer any personal data outside of the UK or the European Economic Area (EEA), where we do so we will only transfer your data in accordance with the conditions set out in the GDPR.

WHAT ARE YOUR RIGHTS?

Under GDPR you have a number of rights in relation to your personal data.

Right to Access – you may request a copy of the personal information that we hold about you.

Right to Rectification – You have a right to have data corrected if you believe that the data that we hold on you is incorrect, we would love to hear from you if you feel that we have something wrong.

Right to Erasure – In some circumstances you have the right to have data we hold on you deleted.  If the purpose we are processing your data is purely for marketing purposes, we always respect you right to erasure.

Right to Restrict Processing – In some circumstances you have the right to ask us to stop processing your data without deleting it from our systems.  You may do this for example if you want us to hold on to it for a different purpose.

Right to Object – You have the right to object to any processing that we undertake if you believe that we do not have an adequate lawful basis.  We will take any objections into account but may override them if we can demonstrate that we need to continue with the processing.

Right to Transfer – You have the right to have any data that we hold on you transferred to another data controller.

Automated Decision Making – You have a right not to be subject to a decision based on automated processing including profiling. 

In the event that you wish to exercise any of your rights or that you wish to complain about how we have handled your personal data, please contact our Data Protection Officer at stephen.alford@ct.catapult.org.uk or in writing at:

Cell and Gene Therapy Catapult

C/O Data Protection Officer

12TH Floor Tower Wing,

Guys Hospital

Great Maze Pond

London SE1 9RT

Our Data Protection Officer will then investigate your complaint and work with you to resolve the matter.

If you still feel that your personal data has not been handled appropriately according to the law, you can contact Information Commissioner’s Office and file a complaint with them.

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