Privacy Notice for Health Professionals
1. Introduction
This privacy notice describes how Sanos Group ApS (or any of our EU subsidiaries) (“Sanos”) processes personal data relating to health professionals, clinical investigators, sub and, or co-investigators, other site staff such as nurses, pharmacists or technicians with whom we have a professional relationship and whose personal data may be processed during business activities.
2. Sanos is the data controller – how can you contact us?
The data controller responsible for the processing of your personal data is typically the legal entity within Sanos Group ApS that you are in contact with, and that determines the purposes and means of the processing.
If you are unsure which legal entity this refers to, the information will typically be available in the agreement, correspondence, or other materials you have received. You are also welcome to contact us directly for clarification.
You can contact us here:
Sanos Group ApS
Telefonvej 8D, 2.,
DK-2860 Soborg
Denmark
CVR no. 41409029
VAT-no. 40314636
DPO E-mail: dataprotection@sanos.com
3. Categories of Personal data processed by Sanos
Personal data Sanos collect from you may include name, identification number, address, email and other contact details. Financial information, qualifications, publications and information from CV, previous experience within clinical trials and GCP training. We may also process data from our digital services such as e-mail communication, websites, social media or from publicly available information. The data we process comes directly from you or your supplier/employer if you consented to them sharing your personal data.
4. Legal basis and the purpose for processing
Sanos only process personal data for specific purposes, and only the type and amount of information needed to fulfil the purpose. We only collect personal data when necessary, and the collected data will never be sold or shared to 3rd party (for exceptions, see 4. Sharing of personal data). All personal data processing requires a legal basis and we do not process your data without.
General purpose of personal data processing includes: Conducting clinical trials in accordance with GCP, research related to development of a pharmaceutical product, diagnostics or medical aids. To comply with financial disclosure regulations and to optimize services we deliver to you.
Sanos processes the personal data you or your employer/supplier provided us, for the above-mentioned purposes, to pursue the legitimate interests of Sanos, cf. Article 6(1)(f) of the General Data Protection Regulation (“GDPR“). And to be in compliance with regulatory obligations in relation to clinical trial activities (EU Regulation on Clinical Trials).
5. Sources, disclosures and recipients
In most cases, Sanos collect personal data directly from you.
Other sources and/or disclosures that are independent data controllers, may be:
- Your employer
- The Sponsor of the clinical trial
- External lawyers, advisors
- Regulatory bodies
- Ethics committees
Sanos use data processors to process your personal data on behalf of Sanos, such as:
- Intra-group companies
- IT service providers
- Consultants & advisers
Such data processors will only process personal data about you on behalf of Sanos and in accordance with the instructions given by Sanos. Thus, these third-party recipients are not permitted to process your personal data for their own purposes.
In some situations, Sanos may share your personal data; Name and Contact information in subject recruitment advertisement. All advertisement is approved by an Ethical Committee or IRB before publication.
6. Transfer of your personal data to a third country (outside of the EU/EEA)
If your personal data is transferred to data controllers or data processors, which are located in countries outside the EU/EEA, including group entities, not ensuring an adequate level of data protection, such transfer will be subject to Sanos providing appropriate safeguards pursuant to art. 46 in the GDPR or by ensuring a derogation for specific situations pursuant to art. 49 in the GDPR.
7. Storage of your personal data
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including to comply with legal, regulatory, contractual, and internal policy requirements. When your data is no longer needed, it will be securely deleted or anonymized in accordance with applicable laws and our data retention policies.
The specific retention period may vary depending on the nature of the data and the context in which it was collected. For more detailed information about applicable retention periods, you are welcome to contact us.
Please note that we per clinical trial regulations are required to keep Clinical Trial documentation for 25 years from end of study.
8. Your rights as a data subject
Below is an outline of your data subject rights. However, kindly note that such rights are not unconditional.
As a starting point, you have a right of access to the personal data, which we store and further process about you. Furthermore, you have the right to rectification and erasure, and the right to restriction of the processing activities.
Under certain circumstances, you may also request that we provide you with an overview of your personal data in a structured, commonly used and machine-readable format and request us to transmit such data to another data controller.
If processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of the processing carried out before withdrawal. You may withdraw your consent by contacting us at dataprotection@sanos.com.
The Danish Data Protection Agency has issued a guideline on the data subjects’ rights. If you want to read more about your rights, please click here. Please note that the guideline is in Danish.
9. Questions and complaints
If you want to exercise any of your rights, if you have any questions regarding this privacy notice or the processing of your personal data, you may contact us at dataprotection@sanos.com.
If you have any complaints regarding the processing of your personal data, please do not hesitate to contact us.
Sanos DPO: dataprotection@sanos.com
You also have the right to file a complaint with your local data protection authority. For Denmark this is the Danish Data Protection Agency (Datatilsynet).
(July 2025)