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Atlantia general data protection statement

Last Updated: Tuesday, September 27, 2022 - 11:51
ABOUT US

This Data Protection Statement applies to the following companies in the Atlantia Group:

  • Atlantia Food Clinical Trials Limited- Floor 1, Heron House, Blackpool, Cork, T23 R50R, Ireland
  • Atlantia Food Clinical Trials Inc-142. E. Ontario Suite 1200, Chicago 60611, Illinois, USA

References to “we”, “us” and “Atlantia” shall apply to the company in the group that is processing your Personal Data.   
We are a world-class provider of human clinical studies. We are a full-service, ICH-GCP compliant, Contract Research Organisation (CRO). We deliver human clinical studies in the following areas; functional foods and beverages, ingredients, supplements, prebiotics, probiotics and microbiome-based therapeutics and cosmeceuticals.
We need to process Personal Data to operate our business. We are committed to protecting the rights of individuals in accordance with data protection legislation including the General Data Protection Regulation in Europe (the “GDPR”).
 

CONTACT DETAILS

We have appointed a Data Protection Officer.  If you have any questions about this Data Protection Statement or the way in which your Personal Data is being used by us, please contact:

Data Protection Officer 
Address:
Floor 1, Heron House, Blackpool, Cork, T23 R50R, Ireland, 
Email:    dataprotectionofficer@atlantiatrials.com 
Telephone:  +353 (0)21 430 7442

Our website is: www.atlantiaclinicaltrials.com

THE STRUCTURE OF OUR DATA PROTECTION STATEMENTS

For ease of use, Atlantia has split its Data Protection Statements into three separate statements as follows:

THE PURPOSE OF THIS DATA PROTECTION STATEMENT

This Data Protection Statement applies to Personal Data that Atlantia processes generally as part of its business.  It applies to business contacts and members of the public including sponsors, suppliers, and visitors to our website referred to herein as “Contacts”.  

If you are a Volunteer please see this statement: [https://atlantiaclinicaltrials.com/atlantia-volunteer-data-protection-statement].  If you are a candidate seeking employment with Atlantia please see this statement: https://atlantiaclinicaltrials.com/atlantia-employee-selection-data-protection-statement  

The definition of Personal Data is as follows:

Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

This Data Protection Statement describes the Personal Data that we process about Contacts and sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be used by us where we are controllers of that Personal Data for the purposes of the GDPR.  Please read this Data Protection Statement carefully to understand our views and practices regarding the Personal Data we collect and how we will treat it. 

As a Clinical Research Organisation, we undertaken research studies for and on behalf of Sponsors.  In general, the sponsors are the controllers of the Personal Data relevant to participants in a particular study.

WHO THIS DATA PROTECTION STATEMENT APPLIES TO

This Data Protection Statement applies to Personal Data that Atlantia processes generally as part of its business.  It applies to business contacts and members of the public including sponsors, suppliers and visitors to our website referred to herein as “Contacts”.  

SOURCES OF PERSONAL DATA

We collect Contact Personal Data from:

  • our business contacts including sponsors, suppliers, partners, shareholders, board members, investors and business prospects;
  • regulators, auditors and ethics committees;
  • visitors to our website to provide and improve our services and develop our website;
  • members of public that we may interact with as part of our services;

We will only ever source Personal Data that is necessary and in a way that would be generally expected.

We receive Contact Personal Data from a variety of sources, as follows:

  • the Personal Data is often provided directly as part of the relationship;
  • the Personal Data may be collected indirectly from another person within the company of the Contact;
  • the Personal Data may be collected indirectly from a website or from a third party.
CATEGORIES OF PERSONAL DATA

We process the following categories of Personal Data about Contacts.  For each category we have included an example of the type of Personal Data that may be part of that category:

Personal Data Category Description
Contact Data may include: name, address, email address, phone number, online communication id (e.g MS Teams); social media profile
Communication Data  may include: details of phone calls, email correspondence and hardcopy correspondence, notes of meeting and communications
Marketing Data may include: contact data and any preferences in receiving marketing from us and your communication preferences
Financial Data may include: contact data, payment related information, bank account details, financial data, PPSN and financial data received as part of the services we provide
Web Data may include Personal Data provided on any forms on our website and, to the extent that it includes Personal Data, information on the type of device you’re using, its IP address, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.
OUR LEGAL BASIS FOR PROCESSING PERSONAL DATA

We process all Personal Data lawfully and in accordance with the requirements of the law. The GDPR sets out the legal grounds for processing Personal Data. 
When Atlantia processes Personal Data of Contacts it is generally on one of the following legal basis:

CONTRACT
We will process Personal Data where necessary to perform our obligations relating to or in accordance with any contract that we may have with you or to take steps at your request prior to entering into that contract (e.g. our Clinical Trial Agreement);

For certain processing activities we may rely on your consent. 
Where we are unable to collect consent for a particular processing activity, we will only process the Personal Data if we have another lawful basis for doing so.
You can withdraw consent provided by you at any time by contacting us at dataprotectionofficer@atlantiatrials.com
 

LEGITIMATE INTEREST
At times we will need to process your Personal Data to pursue our legitimate business interests, for example for administrative purposes, to collect debts owing to us, to provide information to you, to expand our business opportunities, to operate, evaluate, maintain, develop and improve our websites and services or to maintain their security and protect intellectual property rights.  

We will not process your Personal Data on a legitimate interest basis where the impact of the processing on your interests or fundamental rights and freedoms outweigh our legitimate interests. 
You may object to any processing we undertake on this basis. If you do not want us to process your Personal Data on the basis of our legitimate interests, contact us at dataprotectionofficer@atlantiatrials.com and we will review our processing activities.

LEGAL OBLIGATION
If we have a legal obligation to process Personal Data, such as the payment of taxes, we will process Personal Data on this legal ground.

OUR PROCESSING ACTIVITIES

We use your Personal Data to provide you with our services and to assist us in the operation of our business.  Under data protection law, we must ensure that the purpose of processing is clear.
We have set out below the general purpose of processing, the categories of Personal Data processed and the related lawful basis for processing.

Purpose/Activity Personal Data Lawful basis 
Operational Activities
  • for relationship management and support
  • to send notifications about changes/updates to our services
  • to fulfil our legal and contractual obligations
  • to manage/respond to a complaint/appeal
  • to notify you of updates to this Data Protection Statement
  • Contact Data
  • Communications Data
  • Contract
  • Legitimate Interest in managing our business
Marketing & Promotion activities
  • to respond to any requests from you
  • to send newsletters and other information that maybe of interest
  • to contact you as part of our relationship or for lead generation and general administration
  • to inform you of events or webinars that might be of interest
  • to deliver and organise our conferences, seminars, events 
  • Marketing Data
  • Contact Data 
  • Web Data
  • Consent 
  • Legitimate Interest in promoting our business
Website Delivery 
  • to respond to web forms completed by you
  • to promote our services
  • to improve and administer the website; and
  • for internal operations, including support, troubleshooting, data analysis, testing, research, statistical and survey purposes
  • to ensure the safety and security of our website and our services
  • Web Data
  • Consent 
  • Legitimate Interest in maintaining and securing our website
Managing payments and administration of contract
  • to process payments to and from our business
  • to manage and administer our contracts
  • Contact Data
  • Communication Data
  • Financial Data
  • Contract
  • Legitimate Interest in administering our contracts
Management of Corporate Affairs
  • to take minutes at board meetings
  • to contact shareholders/investors
  • to enter into partnerships and other commercial relations
  • to undertake appropriate due diligence
  • Contact Data
  • Communication Data
  • Financial Data
  • Contract
  • Legitimate Interest in managing our corporate affairs
  • Legal Obligation
DISCLOSURE OF PERSONAL DATA

In certain circumstances, we may disclose Personal Data to third parties as follows:

  • to business partners and subcontractors who support us in the performance of our services including email, Skype, Communication Platforms, Customer Relationship Management system, web developers, payment processors, data aggregators, hosting service providers, external consultants and IT consultants;
  • to analytics and search engine providers that assist us in the improvement and optimisation of our website;
  • if we or substantially all of our company is merged with another company or acquired by a third party, in which case Personal Data held by us will be one of the transferred assets; 
  • to other companies in the Atlantia group of companies for the purposes of administration, marketing, employee selection and provision of our services;
  • if we are under a duty to disclose or share Personal Data in order to comply with any legal obligation (including tax, audit or other authorities), or in order to enforce or apply any contracts that we have;
  • to our auditors, lawyers and insurance providers;
  • to protect our rights, property, or safety, or that of our Contacts or others. This may include exchanging Personal Data with other companies and organisations for the purpose of fraud protection. When we engage another organisation to perform services for us, we may provide them with information including Personal Data, in connection with the performance of those functions. We do not allow third parties to use Personal Data except for the purpose of providing these services. 
SECURITY MEASURES

We will take all steps reasonably necessary to ensure that all Personal Data is treated securely in accordance with this Data Protection Statement and the relevant law, including the GDPR.
In particular, we have put in place appropriate technical and organisational procedures to safeguard and secure the Personal Data we process.
We monitor for and do everything we can to prevent security breaches of the Personal Data that we process.
Once we have received your Personal Data, we will use strict procedures and security features for the purpose of preventing unauthorised access and ensuring that only those who need to have access to your Personal Data can access it.
We also use secure connections to protect Personal Data during its transmission. 
If you think that there has been any loss or unauthorised access to Personal Data of any individual, please let us know immediately. 

TRANSFERS OUTSIDE THE EEA

In order to provide our products and services we may need to transfer Personal Data outside the European Economic Area (EEA). We ensure that any transfer of Personal Data outside the EEA is undertaken using legally compliant transfer mechanisms and in accordance with the GDPR.

If we transfer Personal Data outside of the EEA, we generally rely on the Standard Contractual Clauses under Article 46.2 of the GDPR adopted by the EU Commission. We may also rely on some of the other legally compliant transfer mechanisms provided under the GDPR.

COOKIES

Cookies are small text files placed on your computer or mobile device by websites that you visit, and they help us improve the products and services that we offer you. They are used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies may allow a website to remember your activity over a period of time. Cookies are optional and you do not have to accept them.  

Further information on the cookies we use on the website and the purpose behind their respective uses are set out in our Cookie Notice.
 

USE OF THIRD-PARTY WEBSITES

Our website may contain links to and from third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy settings, and these are not endorsed by us.  We do not accept any responsibility or liability for these third-party websites. Please undertake the appropriate due diligence before submitting any Personal Data to these websites.

RETENTION

In some circumstances it is not possible for us to specify in advance the period for which we will retain your Personal Data. In such cases we will determine the appropriate retention period based on balancing your rights against our legitimate business interests.  We may also retain certain Personal Data beyond the periods specified herein in some circumstances such as where required for the purposes of legal claims.

Further information about our retention practices are set out below:

Purpose/Activity Type of Personal Data
Operational Activities For the duration of the contract or for 7 years post-termination
Marketing and Promotion Activities 24 months in the case where no meaningful engagement or earlier in the case you unsubscribe.
Website Delivery  12 months
Managing Payments and administration of the contract 7 years
Management of Corporate Affairs 7 years unless required to retain indefinitely

 

 

 

 

 

In certain cases, we may retain Personal Data for longer than specified here if required under relevant laws or in the event of any legal claim.

YOUR RIGHTS

You have various rights relating to how your Personal Data is used. 

Right of access to the Personal Data we hold about you
You have the right to ask for all the Personal Data we have about you. When we receive a request from you in writing, we must give you access to everything we have recorded about you as well as details of the processing, the categories of Personal Data concerned and the recipients of the Personal Data.
We will provide the first copy of your Personal Data free of charge, but we may charge you a reasonable fee for any additional copies.
We cannot give you access to a copy of your Personal Data in some limited cases including where this might adversely affect the rights and freedoms of others. 

Right of rectification of Personal Data 
You should let us know if there is something inaccurate in your Personal Data.
We may not always be able to change or remove that Personal Data, but we will correct factual inaccuracies and may include your comments in the record to show that you disagree with it.  

Right of erasure of Personal Data (right to be forgotten)
In some circumstances you can ask for your Personal Data to be deleted, for example, where:

  • your Personal Data is no longer needed for the reason that it was collected in the first place
  • you have removed your consent for us to use your Personal Data (where there is no other lawful basis for us to use it)
  • there is no lawful basis for the use of your Personal Data
  • deleting the Personal Data is a legal requirement

Where your Personal Data has been shared with others, we will do what we can to make sure those using your Personal Data comply with your request for erasure.
Please note that we cannot delete your Personal Data where:

  • we are required to have it by law
  • it is used for freedom of expression 
  • it is used for public health purposes
  • it is used for scientific or historical research or statistical purposes where deleting the Personal Data would make it difficult or impossible to achieve the objectives of the processing
  • it is necessary for legal claims. 

Right to restrict what we use your Personal Data for
You have the right to ask us to restrict what we use your Personal Data for where:

  • you have identified inaccurate Personal Data, and have told us of it
  • where we have no legal reason to use the Personal Data, but you want us to restrict what we use it for rather than erase the Personal Data altogether

When Personal Data is restricted, it cannot be used other than to securely store the Personal Data and with your consent to handle legal claims and protect others, or where it’s for important public interests.

Right to have your Personal Data moved to another provider (data portability)
You have the right to ask for your Personal Data to be given back to you or another service provider of your choice in a commonly used format. This is called data portability.
This right only applies if we are using your Personal Data with consent and if decisions were made by a computer and not a human being. It does not apply where it would adversely affect the rights and freedoms of others.

Right to object
You have the right to object to processing of your Personal Data which is based on public interest or legitimate interest processing.  We will no longer process the Personal Data unless we can demonstrate a compelling ground for the processing.

Right not to be subject to automated decision-making
You have the right not to be subject to a decision based solely on automated processing.  This right shall not apply where the processing is necessary for a contract with you, or the processing is undertaken with your explicit consent, or the processing is authorised by law.

You can make a complaint
You have the right to lodge a complaint with the local supervisory authority for data protection in the EU member state where you usually reside, where you work or where you think an infringement of data protection law took place. 

AMENDMENTS TO THIS DATA PROTECTION STATEMENT

We will post any changes to this Data Protection Statement on the Website and on our job ads in recruitment portals and when doing so will change the effective date at the top of this Data Protection Statement.
In some cases, we may provide you with additional notice of changes to this Data Protection Statement, such as via email. We will always provide you with any notice in advance of the changes taking effect where we consider the changes to be material.

QUESTIONS OR COMPLAINTS

Thank you for reading our Employee Selection Data Protection Statement.  Please Contact us if you have any questions.  
If we are unable to resolve your concerns, you have the right to contact the supervisory authority in the country where you live or work, or where you consider that the data protection rules have been breached 

Online Form: https://forms.dataprotection.ie/contact
Address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
Tel: +353 578 684 800 or +353 761 104 800