PRIVACY NOTICE – HEALTHCARE PROFESSIONALS
MeiraGTx Holdings PLC including all our affiliates (“MeiraGTx” also referred to as “we”, “us” or “our”) values your privacy and is strongly committed to protecting your personal information. This Privacy Notice explains how we receive, collect, use and transfer your personal information.
MeiraGTx sponsors several clinical studies, trials and programs (collectively, “Studies”) at the site where you are working and, processes your personal information through your involvement in one or more of these Studies.
INFORMATION WE MAY PROCESS ABOUT YOU
We collect and process your personal information to pursue our business activities in accordance with applicable laws. We may collect this information directly from you through your interactions with us, when you sign up for a service or enter into a contract with us or from third-party sources including publicly accessible sources such as websites, publication databases, journals, national registries, professional directories and other digital platforms or from service providers and business partners acting on our behalf.
We may collect and process information about you including:
- General information such as your identity (name and date of birth) and contact information (postal and/or email address), government issued identification (e.g. drivers license, passport), information relating to the queries you make to us;
- Educational and professional details such as your job title, professional qualifications, work experience, organizational or institutional affiliations, conferences and events participated in, publications;
- Details of your relationship with us and previous trials and research activities you have collaborated on; and
- Payment related information such as your bank details, where necessary for payment of invoices.
WHY WE PROCESS YOUR INFORMATION
We may process your personal information for the purposes of:
- Conducting the studies such as assessment of your qualifications and eligibility for the studies; management, monitoring and review of the study; analysis and verification of the results of the studies; preparation and submission of regulatory filings, correspondence and communications to regulatory authorities relating to the studies; publication of the investigator and other site staff contact information, details of the studies and results of the studies on publicly accessible clinical trial registries, databases and websites, archiving of studies records.
- Conducting our business operations and fulfilling our legitimate business interests such as provision of services that is part of our business activity; to respond to your questions and comments; manage our payments in relation to the studies and/or other clinical trials; efficiently conduct the studies in line with applicable industry standards, further our research and development activities and improve our products and services.
- Complying with a legal, regulatory, ethical obligation, industry best practices and our policies such as transparency requirements relating to the studies including reporting of our interactions with you and public disclosure of payments or other transfers of value made to you; respond to and comply with requests from regulatory authorities (e.g. ethical boards, data protection authorities); compliance with inspections and investigations by regulatory authorities relating to the studies.
We process your personal information for the above purposes based on one of the following legal bases:
- Compliance with applicable laws, regulations, governmental orders;
- Performance of our obligations arising from any contract in place with you;
- Fulfilling the legitimate business interests pursued by us, our service providers acting on our behalf or by a third-party insofar as such interests do not pose a high risk to your rights and freedoms;
- If we need to ask for your consent in order to process your personal information, we will request such consent separately and will ensure that the reasons for requesting your consent are clearly explained.
DISCLOSURE OF YOUR INFORMATION
We will only disclose your information in accordance with the applicable laws and for the above-stated purposes, to the following parties:
- Third-party service providers acting on our behalf such as clinical research organizations or parties assisting us with the conducting of clinical trials and studies. We have appropriate contracts in place that define the legitimate use and sharing of personal information in accordance with this Privacy Notice and oblige such service providers to only process personal information that is necessary for the performance of the contract or are required by applicable laws.
- Our affiliates, subsidiaries and/or divisions that may be located in the United Kingdom, the European Union and the United States.
- Regulatory authorities, as required by applicable laws, including health authorities, ethics committees, institutional review boards and other governmental bodies for the purposes of, including but without limitation to, responding to official requests or queries, realisation and the performance of clinical trials and studies.
- Hospitals, medical institutions or research centres for the purpose of initiating or managing a new or existing clinical study.
- Parties including prospective or actual buyers or sellers in the event of a merger, acquisition, or other reorganization or sale or disposition of all or any portion of our business and/or assets
Some of these third parties may be located in a country where the applicable laws regarding the use of personal information differ to those in your own country. Where your personal information is transferred abroad, we will ensure a commensurate level of protection is applied to the personal information and that applicable laws and regulations are complied with (e.g. for residents of the European Economic Area (“EEA”) this includes the use of European Commission approved standard contractual clauses).
HOW LONG WE RETAIN YOUR INFORMATION
We generally retain personal information for as long as needed for the purpose(s) for which it was collected. In some cases, we may be required to retain your personal information for a longer period where applicable laws or regulations require or allow us to do so.
We implement appropriate technical, physical, and organizational measures which are intended to safeguard any information you provide to us, and to protect it from unauthorized access, loss, misuse, alteration or destruction.
You have rights in relation to your personal information arising from the applicable data protection legislation. These include the right to:
- Access, rectify and erase your personal information: You may have the right to request access to information that we hold about you; request corrections or updates to your personal information; or, in some cases, ask us to erase your personal information to the extent that we are not required to retain it by law.
- Restriction of processing: You may have the right to request the restriction of processing of your personal information, in which case, your personal information will only be processed for certain purposes.
- Data portability: If processing is based on your consent or a contract you have entered into with us, you have the right to receive the personal information which you have provided to us in a structured, commonly used and machine-readable format and you may have the right to transmit the personal information to another entity without hindrance from us.
- Object: Where we rely on legitimate interests as a legal basis for processing personal information, you have the right to object, on grounds relating to your situation, at any time to the processing of your personal information by us and we are required to no longer process your personal information. If you exercise this right, your personal information will no longer be processed for such purposes unless otherwise authorized by law.
- Submit Complaints: You also have the right to lodge a complaint with a data protection authority if you are not able to resolve a problem directly with us and wish to make a complaint regarding the use of your personal information.
If you wish to exercise one of the above-mentioned rights, please refer to the ‘Contact Us’ section.
If you have any queries about this Privacy Notice or you wish to exercise your rights and/or make complaints concerning our handling of your personal information, you may contact us at firstname.lastname@example.org.
In EEA countries, the relevant national data protection authority is responsible for overseeing compliance with privacy laws in that country. You may contact your local data protection authority for more information about your rights, or if you are not able to resolve a problem directly with us and wish to make a complaint. A list of European data protection authorities is available here: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
Effective Date: February 13, 2020