Privacy Notice for Health Professionals
1. Introduction
This information is for 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.
Sanos Group (or any of our subsidiaries) VAT-no. 41409029, Telefonvej 8D. 2., DK-2860 Soborg, Denmark ("Sanos”) is obliged to protect your personal data by law. This statement describes how we process and store your personal data. We only process your personal data according to this statement and current law.
2. 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 (please also see Job applicants privacy notice), 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.
3. 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 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.
4. Sharing of Personal Data
If you are an employee of Sanos we may disclose personal data about you to certain intra-group companies or service providers due to our activities and for the purposes listed in “Employee Privacy Policy”. Your personal data may also be transferred to the following categories of recipients if relevant and necessary or required by law: The Sponsor of the clinical trial, suppliers and service providers, IT systems, cloud service providers, consultants, advisors, external lawyers, regulatory bodies, Ethics committees. All third parties are obliged to protect your personal data in accordance with the law. They will only process data in accordance with the instruction given by Sanos or by Law. 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.
5. 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.
6. Storage of your personal data
For job applicants, please see “Job applicants privacy notice”. Sanos will delete your personal data when no longer needed for legal and regulatory requirements. Please note that we are required to keep Clinical Trial documentation for 25 years from end of study.
7. 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.
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.
8. 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 our Data privacy contacts.
If you have any complaints regarding the processing of your personal data, please do not hesitate to contact us.
Sanos has Data Privacy Contacts with the following contact information:
NBCD, Blueskin, Sanos Group and Sanos Supply:
Sara Daugaard Popik: sdp@nbcd.com
Sanos Clinic:
Chris Rosengaard Højland: chh@sanosclinic.com
Studies and Me:
Nicolas Bouchet: nicolas.bouchet@studiesandme.com
You also have the right to file a complaint with your local data protection authority.
(July 2023)