Illingworth Research Group Limited have been asked by the clinical trial sponsor/their nominated third party to facilitate electronic source data collection as part of the Clinical Trial. To do this, we must collect, store and share your personal information, making us the “data processor”. This means that we hold and use personal data about you.
This policy sets out how we collect and use personal information about you when you are collecting source data from patients and submitting via the application (also known as SourceGO), in accordance with the General Data Protection Regulation (GDPR) and data protection legislation. This policy applies only to users of the application.
Please read the following carefully, to understand our practices regarding your personal data and how we will use it in respect of the App, and your use of the Service.
Consent to installation of the App
Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data.
By installing the App, you are indicating your consent to our processing of your personal data, specifically full name and email address.
How you can withdraw consent
You may change your mind and withdraw consent at any time by contacting us SourceGOsupport@illingworthresearch.com but that will not affect the lawfulness of any processing carried out before you withdraw your consent.
- SourceGO mobile application software (App) available on both Google Play and the Apple Store. Once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
- The SourceGO service accessible through the App (Services) that is available on the App Site or other sites of ours (Services Sites). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
This policy is provided in a layered format with sections relating to the following:
Important information and who we are
Illingworth Research Group Limited is the controller and is responsible for your personal data (collectively referred to as "Illingworth", "we", "us" or "our" in this policy).
Our full details are:
- Full name of legal entity: Illingworth Research Group Limited
- Email address: SourceGOsupport@illingworthresearch.com
- Postal address: Hazelwood House, Tytherington Business Park, Larkwood Way, SK10 2XR, United Kingdom
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues or other competent supervisory authority of an EU member state if the App is downloaded outside the UK.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if there are any changes during our relationship with you.
The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data.
- Contact Data.
- Device Data.
We explain the categories of personal data here.
How is your personal data collected?
We will collect and process the following data about you:
- Information you give us. This is information (including Identity and Contact) you consent to giving us about you through your existing contractual agreement with Illingworth Research Group or by corresponding with us (for example, by email or chat). It includes information you provide when you use the App to facilitate the collection of electronic source data report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
How we use your personal and Special Category data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing.
- Where we need to perform a contract we are about to enter or have entered with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Purposes for which we will use your personal and Special Category data
|Purpose/activity||Type of data||Lawful basis for processing|
|To install the App and register you as a new App user||Identity
Performance of a contract with you
Necessary for our legitimate interests
|To process in-App source data collection submissions.||Identity
Performance of a contract with you
Necessary for our legitimate interests
|To manage our relationship with you including notifying you of changes to the App or any Services||Identity
Performance of a contract with you
Necessary for our legitimate interests (to keep records updated and to analyse how users utilise our application)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
|To administer and protect our business and this App including troubleshooting, data analysis and system testing||Identity
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)|
Disclosures of your personal data
When you consent to providing us with your personal and Special Category data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table above:
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
Many of our external clients and investigator sites are based outside the region the data was collected so their processing of your personal data will involve a transfer of data outside the region collected.
Whenever we transfer your personal data out of this region, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the region collected.
All information you provide to us is stored on our secure servers. Information stored “at rest” on our secure servers is protected using industry standard data encryption. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way. Data being transmitted between you as the User (End User) and Illingworth as part of the Service is protected using industry standard encryption methods. Data stored on our servers is protected using encryption at rest and state of the art firewalls to prevent unauthorised access.
No personally identifiable data is stored on the End User device. Two encrypted tokens are stored on the End User device to facilitate ease of login.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
By law we must keep basic information about you (including Contact, Identity, Data) for seven years after electronic source data submission for the Clinical Trial for audit purposes.
In some circumstances you can ask us to delete your data: see our legal rights below for further information.
Your legal rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer or your personal data.
- Right to withdraw consent.
You can exercise any of these rights at any time by contacting us at Hazelwood House, Tytherington Business Park, Larkwood Way, Macclesfield, SK10 2XR, United Kingdom OR SourceGOsupport@illingworthresearch.com
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
EEA means the European Economic Area.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal third parties
Other companies in the Illingworth Group acting as joint controllers or processors and who are based in Spain, France, Italy, Australia and the United States of America and provide IT and system administration services and undertake leadership reporting.
External third parties
Service providers acting as processors who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Service providers acting as processors who provide travel, accommodation and transportation to you as part of the Services.
HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers base in the UK who require reporting of processing activities in certain circumstances.
Your legal rights
You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data's accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Description of categories of personal data
- Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender, passport information including number, name, country of issue and expiry date.
- Contact Data: home address, email address, telephone numbers and emergency contact details.
- Financial Data: bank account and payment card details.
- Transaction Data: includes details about payments to you and details of in-App requests.
- Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device),] mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting information.
- Content Data: includes information stored on your Device, including photos, videos or other digital content;
- Profile Data: includes your username and password, in-App request history, your preferences and feedback.
- Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
Special Category data
This will include any information you provide to us specifically related to a request you make within the App (such as a request for transport, or accommodation), and may include details about your race or ethnicity, religious or philosophical beliefs and information about your health.