1. WHY YOU SHOULD READ THIS POLICY
We are a controller of your information which means that we are responsible for looking after it. We will use your personal data fairly, lawfully and in a transparent manner, and in accordance with the Data Protection Laws.
If you have any questions in relation to this policy or generally how your personal data is processed by us, please contact our DP Responsible Person by letter addressed to: DP Responsible Person, AMO Pharma Ltd, 1 Park Row, Leeds, West Yorkshire, England, LS1 5AB; or by email at firstname.lastname@example.org.
This policy applies to any personal data that we collect about you when you:
- visit our website www.amo-pharma.com (our "website")
- contact us as a customer, health care professional, potential investigator, investigator, patient or caregiver
- supply goods or services to us
- give us professional advice
- apply for a vacancy with us
- visit our premises
- enrol in or participate in any way in a clinical trial
2. WHAT INFORMATION DO WE COLLECT ABOUT YOU?
Where it is appropriate in the circumstances, we collect your name and contact details (including your title, company and/or department, address, telephone number and e-mail address), the category of the person contacting us e.g. patient, caregiver, investigator, investor, healthcare provider, customer, supplier etc. We may ask you to provide sensitive personal data such as date of birth and past medical history from time to time. If such data are requested, you will be given additional information as to why the sensitive personal data are being requested and how they will be used.
Each time you visit our website it is possible that personal data about your computer may be collected, including how many times you use the website, which pages you visit and other traffic data. This information can make it possible to build a profile of users of the website. Some of these data will be aggregated or statistical, which means it will not be possible to identify you individually. Please see our Cookies Policy for further information about what information may be automatically collected when you visit our websites.
Please note that we may combine personal data we receive from other sources with personal data you give to us and personal data we collect about you.
3. WHERE DO WE GET THIS INFORMATION FROM?
We collect some of your information directly from you, either through information that you give to us or information that we collect during your visits to our website or through your communications with us in person, by telephone, by email or by post. We also obtain some information from other third parties, including our customers and partners within our clinical development programmes.
4. WHY DO WE NEED YOUR INFORMATION?
We collect and use your information where it is essential or helpful in supporting our business and product development goals at AMO Pharma. We also collect and use your information:
- to set up and manage clinical trials
- to provide you with information if you have requested updates about our development programs, research activities and any corporate news via newsletters and press releases
- to develop and improve our products and services
- to notify you about changes to our products and services
- to review applicants' CVs and suitability for a role
- as part of our efforts to keep our sites safe and secure (for example through the use of CCTV on our sites)
4.1 Special Categories of Personal Data
Data Protection Laws define certain personal data as falling into 'special categories of personal data' such as personal data regarding your racial or ethnic origin, trade union membership, genetic data, biometric data for the purposes of uniquely identifying a person, data concerning your health (including mental and physical health), or data concerning your sex life or sexual orientation.
We may ask you for some special category personal data or you may voluntarily give such personal data to us in connection with our management of clinical trials. We will only use this personal data for the purposes of ensuring your suitability for such trials and that such trials are carried out safely, effectively and with scientific rigour. We will only process such data on the basis of your explicit consent, or for public interest, scientific research purposes.
We may also process your special category personal data if you are an employee of ours for the purposes of your employment.
We may share any of your personal data which falls into a special category of personal data with investigators and regulators in connection with any clinical trials in which you participate on a pseudonymised basis.
4.2 Basis for using your information
4.2.1 Necessary for the entry into or performance of a contract
When you enter into an agreement with us, for example as a customer, a supplier, a trial subject (by signing the trial consent form) or an employee, a contract between you and us will have been or will be entered into. In order for us to fulfil our obligations under such contract (e.g. to enable us to provide our products and services to you), we will need to collect, process and share (as further detailed below) your personal information. Failure to provide the requisite personal information when entering into the agreement or objecting to this type of processing / exercising your deletion rights will unfortunately mean we cannot provide our products and/or services to you.
4.2.2 Legitimate business interests
- provide you with the products and/or services you have requested
- carry out research to understand how our customers use our products and services
- develop and improve our products and services
- ensure our clinical trials are managed safely and efficiently
- enable us to meet our regulatory requirements
As indicated below, we may also pass your personal data to third parties and this is also for our legitimate business interests.
We are required to carry out a balancing test of our legitimate business interests in using your personal data outlined above against your interests and rights under the Data Protection Laws. As a result of our balancing test, we have determined, acting reasonably and considering the circumstances, that we are able to process your personal data in accordance with the Data Protection Laws on the basis that we have a legitimate business interest.
If you have subscribed on our website to receive newsletters and or press releases these will be sent to you at the email address you provided, all in accordance with the Data Protection Laws. You may unsubscribe to these communications at any time.
We use your personal data falling into special categories of personal data where you have explicitly consented for us to do so.
You have the right to withdraw your consent to processing on this basis at any time.
5. WHO DO WE SHARE YOUR INFORMATION WITH?
We may share your employee personal information with the other members of our group but only for the purposes of your employment.
We may be obliged to provide information to third parties to comply with legal requirements or a court order, and may also use a number of carefully selected third parties to supply us with products and services, such as legal advice. We will only share your information with such suppliers where it is necessary for them to provide us with the services we need. We do not share your information with third parties for marketing purposes.
6. WHERE IS YOUR INFORMATION STORED AND HOW LONG DO WE KEEP IT FOR?
6.1 Transfers outside of the UK/EU European Economic Area ("the European GDPR Territory")
The information which we collect about you may be transferred outside the European GDPR Territory in order to provide the services that we offer. The level of information protection in countries outside the European GDPR Territory may be less than that offered within the European GDPR Territory. Where this is the case, AMO Pharma will endeavour to implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws. AMO Pharma will review the processors that we utilise and ensure that there are adequate safeguards in place to protect your personal data, such as adherence to binding corporate rules and standard contractual clauses.
6.2 Retention of your personal data
We will store your data for as long as necessary for the legitimate purpose under which the data have been collected, having regard also to any regulatory or legal requirements.
6.3 Security of your personal data
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our websites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7. WHAT RIGHTS DO YOU HAVE?
In some instances, we may be unable to carry out your request, in which case we will write to you to explain why.
|1. You have the right to request access to your personal data||You have the right to request confirmation that your personal data is being processed, access to your personal data (through us providing a copy) and other information about how we process your personal data.
|2. You have the right to ask us to rectify your personal data||You have the right to request that we rectify your personal data if it is not accurate or not complete.
|3. You have the right to ask us to erase your personal data||You have the right to ask us to erase or delete your personal data where there is no reason for us to continue to process your personal data. This right would apply where you withdraw your consent for us to process special categories of your personal data, or where you object to the way we process your personal data (see right 6 below).
|4. You have the right to ask us to restrict or block the processing of your personal data||You have the right to ask us to restrict or block the processing of your personal data that we hold about you. This right applies where you believe the personal data is not accurate, you would rather we block the processing of your personal data rather than erase your personal data, where we don't need to use your personal data for the purpose we collected it for but you may require it to establish, exercise or defend legal claims.
|5. You have the right to port your personal data||You have the right to obtain and reuse your personal data from us to reuse for your own purposes across different services. This allows you to move personal data easily to another organisation, or to request us to do this for you.
|6. You have the right to object to our processing of your personal data||You have the right to object to our processing of your personal data on the basis of our legitimate business interests, unless we are able to demonstrate that, on balance, our legitimate interests override your rights or we need to continue processing your personal data for the establishment, exercise or defence of legal claims.
|7. You have the right not to be subject to automated decisions||You have the right to object to any automated decision making, including profiling, where the decision has a legal or significant impact on you.
|8. You have the right to withdraw your consent||You have the right to withdraw your consent where we are relying on it to use your personal data.
8. WHAT IF YOU HAVE A COMPLAINT?
You can also contact the Information Commissioner's Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF www.ico.org.uk.
9. OTHER WEBSITES
Our websites may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or your use of those websites.
This policy was last reviewed and updated in March 2021.