EU and UK Data Subjects Information Notice

Background

This Privacy Information Practices applies to OpAns LLC and details:

a) Our handling of Europe and United Kingdon resident information in running and managing our business, and b) Our handling of Special Category Personal information during the conduct of the clinical diagnostics and testing services that we provide to Clinical Trial Sponsors in Europe and the United Kingdom.

It describes our position under the Data Protection Legislation and how you can contact us is you have any concerns about the personal information that we handle.

Throughout this notice, where we refer to Data Protection Legislation, we mean the Data Protection Act 2018 (DPA2018), United Kingdom General Data Protection Regulation (UK GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any legislation implemented in connection with this legislation.

The Personal Data That we utilise.

OpAns Position under the Data Protection legislation:

OpAns position under the Data Protection Legislation depends on how we have come into possession of your information.

- Where OpAns has possession of your information for our own business purposes then we are a data controller and the information in Section 1 below will apply.

- Where OpAns has possession of clinical information in order to provide our diagnostic services to our customers we are considered a Data Processor for the that we receive. This means that we only use the personal information to provide our diagnostic services to the Trial Site and Trail Sponsor under our contract with them.

Section 1 - Information for Individuals who have interacted with OpAns Directly.

What Data Does OpAns Collect

We only collect personal information that we genuinely need to manage our relationship with you and in accordance with the Data Protection Legislation.

We collect information about you directly from you when you interact with us in any capacity, whether through our website, at an event, through our social channels or via email.

The information we collect could include:

- Name

- Telephone Number

- Email Address

- Postal Address

- Company and position within the company

- Payment Information (bank or payment card information)

- Details of the services you have engaged us to provide

- Details of any conversation we have had with about service provision

How does OpAns use the Data

We use this information to:

- Manage our business relationship with you or your organisation

- Manage, review and improve our business practices

- Communicate with you about our business, our services and our relationship with you.

Your Rights

You rights under the Legislation are –

The right to be informed about our collection and use of personal data:

You have the right to be informed about the collection and use of your personal data. This information notice gives you this information.

The right to access your personal information:

You have the right to access the personal information that we hold about. This is sometimes termed ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge and aim to do so within 1 month from the point that we are able to confirm your identity. We will ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information.

The right to correction your personal information:

If any of the personal information we hold about you is inaccurate, incomplete or out of date, you can ask us to correct it.

The right to restrict processing:

You have the right to ask us to restrict the processing of your personal data. For example, this may be because you have issues with the accuracy of the data we hold or the way we have processed your data. The right is not absolute and only applies in certain circumstances.

The right to erasure:

You have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances.

The right to object:

You have the right to object to our processing of some or all of the personal data that we hold about you. This is an absolute right when we use your data for direct marketing but may not apply in other circumstances where we have a compelling reason to do so, for example if we have a legal obligation.

The right to make a complaint:

You can make a complaint to a relevant regulator at any time about the way we use your information. However, we hope that you would consider raising any issue or complaint you have with us first using the information in Section 3.

Section 2 – Information for Clinical Trial Subjects.

What Data Does OpAns Receive:

In the course of providing our services OpAns receives samples taken at a clinical site labelled with clinically coded medical information, this means that the directly identifiable personal information has been obscured with a unique identifier. As such, although the clinical site can identify you directly OpAns cannot as we are not provided with any additional information about you.

How does OpAns use the Data:

OpAns conducts the analysis of any samples at our Lab based in the United States. We only use the sample information for the purposes directed in our agreement with the Trial Sponsor. We use the coded information to provide reports back to the Trial Site as required under our contract.

Your Rights:

As a Data Processor OpAns cannot directly respond to individual rights request. If you have any questions about the handling of your personal information you should contact your Clinical Trail Site.

Section 3 - Complaints/Questions.

As we are an organisation based outside of the UK and EU we have appointed a representative in each of these jurisdictions to act as our representative. If you believe your privacy rights have been violated, you have the right to file a complaint with us through our representatives using the below information;

By Post:

UK Data Subject –

The DPO Centre, 50 Liverpool Street, London, EC2M 7PR

EU Data Subjects –

The DPO Centre, Alexandra House, 3 Ballsbridge Park, Dublin, D04 C7H2

By Email:

EU-UKrepresentative@opans.com

This notice was last updated on: 03/12/2024

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