This integrity policy (the “Integrity Policy”) describes how CTC Clinical Trial Consultants AB, org. no. 556849-1848 Dag Hammarskjölds väg 10B 752 37 Uppsala, Sweden (“CTC” or ‘‘us’’), processes personal data about you. On our websites ctc-ab.se and forskningsperson.se you have the opportunity to get in contact with us. If you do, you will be asked to disclose certain personal information about yourself to us. CTC is the personal data controller of the data collected and processed as described in this Integrity Policy and is therefore responsible for ensuring that your personal data is processed correctly and securely in accordance with applicable legislation. CTC respects your interest in how your personal data is processed. We hereby want to inform you on how we will use your personal data and what rights you have.
We ask you to carefully read this Integrity Policy before you share any personal data with us.
If you are interested in participating in our clinical trials, please visit our website www.forskningsperson.se for more information on how to participate and upcoming clinical trials.
You are more than welcome to contact our data protection officer via email email@example.com if you have any questions regarding this Integrity Policy and our processing of your personal data.
What personal data is collected and processed by CTC?
The categories of personal data that we may process about you may be:
- Identity information, such as national personal identity number, date of birth, name, initials, signature, etc.
- Contact information, both personal and professional, such as postal address, phone number, mobile phone number, e-mail address, principal, employer, job title, job role, workplace, information about contact person, contact details for the principal or employer etc.
- Photos that you share with us or photos that we take, such as portraits, photos from events etc.
- Billing information, such as billing address, reference person and other billing information, billing history, payment reminders, costs and cost specifications, account information and other payment information, payment history, etc.
- Qualification and recruitment information, i.e. information about the applied appointment or appointment of interest, information in any personal letter, CV, resume and submitted credentials and other documents, information provided by references, test values, notes and summaries of interviews and other contacts during the recruitment process, summaries and analyses from any recruitment consultant or other service provider employed in connection with recruitment, certificate of service and testimonials, etc.
- Health information, such as information regarding medical history and ongoing medications submitted as part of your registration in our recruitment database of clinical trial subjects at our website www.forskningsperson.se.
- Technical website information, such as IP address, language settings, browser type, browser settings, time zone, operating system, platform, screen resolution, response time, download error, your geographical location, and related traffic and usage information, such as which links you click and when, the address of the website you arrived from, what marketing information you received and opened.
In addition, we may treat other categories of personal data provided by you or the party for which you are a contact person.
We will only process your national identification number if and to the extent that it is clearly motivated by the purpose of the treatment, the importance of a secure identification or other relevant reason.
For what purposes do we process your personal data?
Submitting a contact form on our websites ctc-ab.se or www.forskningsperson.se, or interacting with us by other means. CTC collects and processes information about you that we need to respond and administer the contact request and inform you about our business operations. In addition to use your personal data for the purpose of interacting with you, we process your data for the purpose of provide proposals and evaluating, manage and execute a potential relationships with you, and, as applicable, the company you represent. CTC processes the following category of personal data: Identity information, contact information, photos and other information that you share with us related to our business discussions.
Submitting a job application via our website or partner’s website or by other means. CTC collects data about you that we need to recruit the right person for a job position at CTC and to collect, administer and evaluate your submitted application and perform related recruitment activities and interact with you and your references for this purpose. CTC processes the following category of personal data: Identity information, contact information, photos, qualification and recruitment information and other information that you share with us related to your application.
Registration to our general recruitment database and/or to a specific clinical trial, at our website www.forskningsperson.se. CTC collects data about you that we need to administer the contact with you (inform you of upcoming studies, schedule clinical visits, administration of compensation etc.). In addition, we collect information about you in our recruitment database to perform recruitment activities in the clinical studies CTC conducts on behalf of our customers. CTC processes the following category of personal data: Identity information, contact information and health information.
Entering into a business relationship with CTC. CTC collects and processes information about you in your capacity as, or as a representative of a company that is or may be, a customer, partner, supplier to CTC that we need in order for us to be able to execute an agreement with you and fulfil our contractual rights and obligations (financial transactions, provide services etc.) between CTC and you and, as applicable, the company you represent. In addition we need to process your information to fulfil legal requirements such as accounting and tax requirements and in certain cases due to archiving requirements under the clinical trial regulation. CTC processes the following category of personal data: Identity information, contact information, photos, billing Information and other information that you share with us related to our business contract.
What is the legal basis for the processing of your personal data?
The legal basis for the respective processing activities is as follows.
Visiting our websites. The legal basis for processing is CTC’s legitimate interests.
Submitting a contact form on our website or interacting with us by other means. The legal basis for processing is CTC’s legitimate interests.
Submitting a job application via our website or partner’s website or by other means. The legal basis for processing is CTC’s legitimate interests.
Registration to our general recruitment database and/or to a specific clinical trial, at our website www.forskningsperson.se. The legal basis for processing is contract, please find the contract here. The contract describes the processing of personal data within our recruitment operations in further detail. The legal basis for processing is with regards to any payments handled in a specific clinical trial, legal obligation with regards to the handling of payment of any compensation connected to your participation in the clinical trial. Please note that the legal basis for processing your personal data within a clinical trial that you participate in will be described and communicated to you in connection with the information that you are provided prior your consent to participate in the clinical trial. Such processing within a clinical trial may be done by us on behalf of the customer responsible for the clinical trial, meaning that such customer may be the controller for personal data collected within the clinical trial.
Entering into a business relationship with CTC. The legal basis for processing is contract and legal obligation.
What are our legitimate interests?
As mentioned above, we may process your personal information because it is necessary for the purposes of our legitimate interests. Our “legitimate interest” corresponds to the purpose for which we perform each processing based on our interest.
When we process your personal information for our legitimate interests, we perform a balancing test where we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate interests, such as business, commercial and employer interests, do not automatically override your interests. We will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
We do not consider that our processing disadvantages you in any way. We use your information only in ways you would understand and reasonably expect, and which have a minimal privacy impact, or where there is a compelling justification for the processing.
You have a right to object to processing that is based on our legitimate interests. If you wish to do so, please send an e-mail to firstname.lastname@example.org.
How to revoke your consent
We do not process your personal data based on your consent. If we at any point in the future will process your personal data based on your consent (in such case you will be duly informed beforehand), you have a right to revoke your consent to this processing of your personal data at any time. If you would like to make use of this right and revoke your consent, please contact us at email@example.com. Please note, if you revoke your consent, it does not affect the legality of the processing we have performed based on your consent before it was revoked.
If you choose not to provide certain personal information to us?
You are not required to provide personal information to us except when provided by law. But please note, if you choose not to provide us with certain personal data or limit our right to process your personal data, that may result in that we cannot fully manage our relationship with you, process your job application or fail to meet an agreement we have with you.
How long do we keep your personal data?
Your personal data is kept by CTC only for as long as there is a need to keep the data to fulfil the purposes for which the data was collected in accordance with this Integrity Policy. Thereafter, your personal data will be deleted. Contact information received by our contact forms or by similar means is stored during such time CTC considers that the information is necessary to maintain the relationship with you, and as applicable, and the company/organization in question that you represent. To the extent your personal data is processed as part of performing a clinical trial, personal data will be stored in accordance with the archiving periods set out in relevant applicable laws and regulations (including but not limited to the clinical trial regulation). Personal data processed under a business relationship with CTC will be kept during our contractual relationship and thereafter as long as there are any outstanding rights or obligations arising from our contractual relationship. Thereafter, only necessary information is saved if and to the extent we have a legal obligation to save the information. Necessary accounting information is stored for a period of seven years in order to comply with statutory storage time.
If you register to be part of our recruitment database and/or to a specific clinical trial, at our website www.forskningsperson.se, we will keep your personal data as described and agreed under the personal data contract available here.
Who do we share your personal data with?
We may disclose your personal data to chosen third parties in accordance with this Integrity Policy. In the event of such sharing or transfer we will take every reasonable legal-, technical- and organizational action in order to make sure that your personal data is handled in a safe manner and that the level of security is adequate. Any third party that processes your personal data on our behalf is bound by processor contracts which includes a provision that such third party shall follow our instructions, take the measures that we find necessary and observe confidentiality.
We may disclose your personal data to any of our consultants, insurers, professional advisers, suppliers, subcontractors, advertisement partners, business partners, customers and companies within our company group insofar as reasonably necessary for the purposes set out in this Integrity Policy. Hence, we might share your personal data when a third party provides us with services such as providing, hosting and maintaining IT systems, accounting, technical support, testing, surveys, etc. on our behalf.
We may also disclose your personal information to the extent that we are required to do so by law or a court order, in connection with any ongoing or prospective legal proceedings, in order to establish, exercise or defend our legal rights, for archival purposes of public interest, scientific or historical research or statistical purposes.
Transfer of personal data to third countries
CTC may transfer your personal data to countries outside the EU/EEA. If personal data is transferred to a country outside the EU/EEA, CTC will take measures to ensure that the personal data continues to be protected and will comply will all requirements that apply to transfers of personal data to countries outside of the EU/EEA pursuant to applicable data protection legislation.
A summary of your rights according to applicable legislation is set out below.
Right of information, access, rectification, and erasure. You have the right to obtain confirmation from us as to whether or not personal data concerning you are being processed by us. You have the right to access your personal data and to obtain, free of charge and once a year upon request, a copy of the personal data concerning you that is processed by CTC. If the personal data concerning you that is processed by CTC is inaccurate, incomplete, or outdated, you have the right to obtain rectification of such personal data. You have a right to request the erasure of personal data concerning you. Unless CTC has a legal basis to continue the processing of the personal data concerning you, such personal data shall be erased.
Right to object and restriction of processing. Under certain circumstances you have the right to object against and to obtain restriction of CTC’s processing of your personal data. Where processing has been restricted, CTC may only under certain circumstances carry out other processing activities concerning personal data than storage.
Right to object. You have the right to object, on grounds relating to your particular situation, at any time to certain processing of your personal data. The right to object applies when we process your personal data including profiling, to perform an engagement of public interest, as part of the exercise of public authority or after a balance of interest. Where personal data is processed for direct marketing purposes, you have the right to object at any time to our processing of your personal data for such marketing.
Right to data portability. At CTC, we do not apply data portability as portability of personal data does not have any practical applicability in our business operations.
Right to lodge complaints. Should you be dissatisfied with our processing of your personal data, please let us know, and we will do our best to meet your complaints. You also have a right to submit a complaint with the Swedish Data Protection Authority (Sw. Integritetsskyddsmyndigheten, (IMY), Box 8114, 104 20 Stockholm.
Protection of your personal data
You should always feel secure when you provide your personal data to us. We have implemented a wide range of security measures to protect your personal data against unauthorized access, modification and deletion. We will not disclose your personal data to anyone else other than what is set out in this Integrity Policy.
Links to other websites and social media
Regarding personal data that occurs and is processed on websites operated by other organizations, please note the following. Our website contains links to websites operated by other organizations, including but not limited to social media platforms such as Facebook, Instagram and LinkedIn, that have their own privacy policies. We refer users to the policy provided by the respective service providers for information on how each service provider processes personal data.
How do I get in contact with CTC?
Do not hesitate to contact us if you have any questions regarding this Integrity Policy, our use of your personal data or if you want to exercise any of your rights according to this Integrity Policy. Please find our contact details below.
Phone number: 018-30 33 00
E-mail address: firstname.lastname@example.org
E-mail address to our data protection officer: email@example.com
Changes to this Integrity Policy
CTC reserves the right to amend this Integrity Policy at any time. In the event of changes to this Integrity Policy, CTC will publish the amended Integrity Policy on its website with information on when the changes will come into effect. This Integrity Policy was last updated in November 2023.