Privacy Policy

Please read this Privacy Policy carefully. By completing a questionnaire and/or submitting personal and sensitive information through this website via our “Sign Up” form or by telephone or in another manner to Atlantia Ltd in relation to your interest in volunteer opportunities, you (“You”) consent to Atlantia’s collection, processing and use of Your Personal Data in accordance with Atlantia’s Privacy Policy.

 “Personal Data” in this context means any information relating to an identified or identifiable natural person, whereas an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as name or an identification number or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal Data may comprise data concerning health.


Contents:

Who we are
Updates to this Policy
Data Protection Officer
What Information Do We Collect About You?
How do We use Your Personal Data?
How is Your Personal Data Protected?
Storage and Transfer of Your Personal Data
Disclosing Your Personal Data
Your Rights
Contact Us


Who We Are

Atlantia Ltd (“We” or “Us” or “Our”) in this policy, are a clinical trials company that conduct food clinical research studies for and on behalf of our clients, known as “Sponsors”.
This part of the Atlantia website (http://atlantia.ie/) (the “Website”) is devoted to the recruitment of volunteers for clinical research studies being completed in Ireland by Us for clinical research study Sponsors. We are committed to protecting Your privacy. This Privacy Policy describes how We handle and protect Your personal and sensitive information in connection with the recruitment process.


Updates to this Policy

From time to time We may make changes to this Policy for example, when We change the way We collect or process Your data. You will find the updated versions of this Policy on our website at https://atlantia.ie/privacy-policy
It is important that You visit this website regularly to keep up-to-date on these changes.


Data Protection Officer

Our Data Protection Officer (DPO) manages how We collect, use and protect Your personal and sensitive information to safeguard your rights under the new General Data Protection Regulation (GDPR) (EU) 2016/679. You can contact our DPO at dataprotectionofficer@atlantiafoodtrials.com or by writing to them at: Data Protection Officer, Atlantia Food Clinical Trials, Floor 1, Heron House, Blackpool, Cork.


What Information Do We Collect About You?

Submitting Your information through Our “Sign Up” form and “Pre-screening” questionnaires is entirely voluntary. When You contact Us through the Website, telephone number or calling into our clinic, in connection with becoming a volunteer on one of our clinical research studies, We need to collect certain personal and sensitive information about you as the first stage of our recruitment process.

The “Sign Up” form on the Website will collect Your:

  • Name
  • Email address
  • Telephone number
  • Date of birth
  • Gender
  • Date & Time of Your Consent.

We will contact You, using the information You have provided in this form, via email, about Our upcoming trials. We may also contact You by telephone, if Your information matches criteria for an upcoming trial. We may then ask You questions from one Our “Pre-screening” questionnaires, as detailed in the next paragraph.

If You complete one of Our “Pre-screening” questionnaires on the Website, Your information will be kept in an online Microsoft 365 account, until one of Our Recruitment Officers, uploads Your information to our Clinial Trial Management System (CTMS), then deletes it from the Microsoft 365 account. Each eligibility criteria may differ slightly from trial to trial, but, in general, we may also ask You for Personal Data in relation to Your health and medical conditions, such as;

  • Height,
  • Weight
  • Body Mass Index
  • Personal/ Family Medical history
  • Smoking, alcohol and recreational drug habits
  • Allergies
  • Reproductive status
  • Contraceptive use
  • Blood Donation
  • Clinical research study participation, and;
  • Date and Time of Your Consent.

If You receive an email from Atlantia, Our email subscription services will also collect:

  • Your IP address

To the extent You make personal information available to Us, You consent to Us processing such information in accordance with this Privacy Policy.


How do We use Your Personal Information?

We will use the information You submit to Us via the Website for the purposes of;

  • communicating with You (by telephone or email) to establish Your eligibility for a clinical research study;
  • to organise the processing of Your interest in becoming a clinical research study volunteer;
  • to send You information about clinical research studies or information that would allow you to participate in a clinical research study;
  • to send You health-related information;
  • to respond to Your queries or requests;
  • to produce aggregated and anonymised data analytics, statistical research and reports, which may be used to review and change Our services; and
  • in other ways as required or permitted by law or with Your consent.

When We contact You by telephone, We will use a paper or digital questionnaire to collect the Personal Data that is essential to help Us determine if You are eligible for a clinical study. Once Your eligibility has been established for all studies You may be eligible for, We will update Your eligibility status on Our recruitment officers study database and shred the paper telephone questionnaire immediately. The digital questionnaire, if used, remains on Your profile, on our CTMS. If You are deemed eligible, We will then book You in for Your first appointment, using our online room-booking tool


How is Your Personal Information Protected?

We take protection of Your personal information very seriously and have applied organisational and technical security measures to safeguard and prevent unauthorised access to Your personal information.
Access to the information stored on servers and Our CTMS is granted only to our trained recruitment officers and designated staff members. All staff members that will process Your data have been trained in data protection.

We will take all steps reasonably necessary to protect Your personal and sensitive information in accordance with GDPR and other applicable laws. We also adhere to the International Council for Harmonisation – Good Clinical Practice standard, which further helps to safeguard Your data.

We have organisational and technical security measures in place to ensure the privacy of Your Personal Data. However, We cannot control the privacy of Your information whilst it being moved to Us from Your computer. Therefore, We expressly disclaim any liability and are not responsible for the transfer process.

We will store Your personal and sensitive information for 5 years from the date of collection and will review your information every 2 years from the date of collection.


Storage and Transfer of Your Personal Information

Sign Up Form

  1. The information You give to Us by submitting a “Sign Up Form” is stored in a Plugin on our website providers servers in the United States of America.
  2. Our Recruitment Officers transfer this information to Our CTMS database to servers located in Germany.
  3. Your full name and email address are transferred from the Plugin to Our email management services servers, located in the United States of America.

Pre-screening Questionnaires

In Our “Current Studies” tab on the Website, there are links to “Pre-Screening” questionnaires that help Us determine Your eligibility for a specific trial.

  1. When You submit information via one or more of these Pre-screening questionnaires, Your information will be stored on a Microsoft cloud-based Office 365 account on servers in Ireland, the Netherlands, Austria or Finland.
  2. Our Recruitment Officers, transfer Your information to Our CTMS, located on servers in Germany to establish Your eligibility and, if you have consented, will then add the following information to the Your profile on the CTMS database:
  • Name;
  • Email address;
  • Telephone number;
  • Gender;
  • Date of birth;
  • Height;
  • Weight;
  • Body Mass Index;
  • Personal/ Family Medical history;
  • Smoking, alcohol and recreational drug habits;
  • Allergies;
  • Reproductive status;
  • Contraceptive use;
  • Blood Donation;
  • Clinical research study participation, and;
  • Date and Time of Your Consent.

For clarity, we note that we only transfer data to providers in the United States of America if they are part of the Privacy Shield, which requires them to provide similar protection to personal data processed in the United States as is applicable in the European Union.

We process your Personal Data on the following legal grounds.
• You have given us consent to the processing of your Personal Data for one of the purposes set out above (articles 6.1 (a) and 9.1 (a) GDPR);
• Processing is necessary for Our legitimate interests, consisting of keeping up-to-date records of our recruitment database (article 6.1 (f) GDPR).

We will store Your personal and sensitive information for 5 years from the date of collection and will review your information every 2 years from the date of collection.


Disclosing Your Personal Information

We will not share Your personal or and sensitive information to third parties for their direct marketing. However, We may disclose Your personal information to the following:

  • as required by law and to protect Our legal rights to the extent authorised or permitted by law;
  • to Our professional advisors and to parties providing products or services to Us (such as IT systems suppliers);

If You do participate in a clinical research study, some of Your personal information may be seen by the organisers of the clinical research study and by regulatory authorities that oversee clinical research studies in Ireland. However, Your name will not appear in any of the clinical research study documents, where We will only use a unique research study number.


Your Rights

You may exercise any of the rights described in this section by contacting us using one of the methods described in the “Contact Us” section below. We endeavour to respond to your request(s) as quickly as possible. However, it may take up to 30 calendar days from your initial communication, for our team to process your request completely.

1. Right of Access

  • You have a right to get access to the personal and sensitive information that we store about you.
    • Please contact our Data Protection Officer with your request via email: dataprotectionofficer@atlantiafoodtrials.com or using the other methods described in the “Contact Us” section below.

2. Right to Rectification

  • You have a right to rectification of inaccurate personal and sensitive information and to update incomplete information.

3. Right to have Information Erased

  • You have a right to request that we delete your personal and sensitive information
  • You may request that we delete your personal and sensitive information if you believe that:
    • We no longer need to process your information for the purposes for which it was provided
    • We have requested your permission to process your personal and sensitive information and you wish to withdraw your consent; or
    • We are not using your information in a lawful manner.

4. Right to Restriction of Processing

  • You have a right to request us to restrict the processing of your personal and sensitive information
  • You may request us to restrict processing your personal information if you believe that:
    • Any of the information that we hold about you is inaccurate;
    • We no longer need to process your information for the purposes for which it was provided, but you require the information to establish, exercise or defend legal claims; or
    • We are not using your information in a lawful manner.

5. Right to Data Portability

  • You have a right to data portability
    • You have a right to receive the personal information you provided to us in a portable format

6. Right to object

  • You have a right to object to processing of Personal Data

When You object against processing of  Personal Data, based on Our legitimate interests, We will in principle no longer process such data, unless We can demonstrate compelling legitimate grounds to continue processing overriding Your interests.


Contact Us

If you have a question or a comment about this Volunteer Recruitment Privacy Policy or any of Our data protection practices, please contact our DPO at:
dataprotectionofficer@atlantiafoodtrials.com.

You can also write to us at:
Data Protection Officer,
Atlantia Food Clinical Trials,
Floor 1,
Heron House,
Blackpool, Cork.

For more general enquiries or if you require access to your personal information, please call us on: +353 (0)21 4307442.