Introduction

The collection and analysis of the most confidential information about people is of fundamental importance for conducting medical research. CS Pharma understands that in order for individuals to share their most sensitive information with us, we must have a culture of trust and that we will store data following safe data management practices.

CS Pharma is committed to ensuring that we handle all individual information in a responsible and careful manner and in accordance with data privacy and confidentiality laws.

This Privacy Policy (“Policy”) outlines our commitment as an organisation to the individuals whose data we manage, the key types of personal data we process and how that information is used. The Policy explains in general terms how we strive to comply with data privacy laws, including the European Union (“EU”) General Data Protection Regulation Article 6(1)(f) and Article 9(2)(j), UK (The Data Protection Act 2018) and any subsequent amendments to this regulation or local law equivalent that is later adopted (“Regulation”) and the privacy and confidentiality requirements of ICH Good Clinical Practice (GCP).

Who Are We?

CS Pharma is a specialised Consulting Company providing bespoke Resourcing Solutions supporting the development of new medications within the UK. Our team of highly skilled professionals cover a wide range of therapeutic areas and provide broad support across the pharmaceutical industry having supported over 200 clinical trials within the UK. As an employer and clinical research organisation we act as Controller over individual personal data and healthcare information. 

Industry Professional Information

CS Pharma will liaise with employees, consultants, contractors and other third parties employed or engaged by our clients, when conducting our research activities. CS Pharma will record and use the names, contact details and other professional information on these individuals for legitimate business-related purposes, including project and financial administration. This information may be used (including email addresses), to provide background on CS Pharma services for our clients.

Employee and Human Resource Data

We collect personal information from applicants pursuing employment with CS Pharma, including private contact details, professional qualifications and previous employment history to assist with the personnel recruitment process. CS Pharma carries out a range of background inspections on applicants, including DBS and professional disbarment checks. Consistent with the operation of a business, CS Pharma systems collect information on employed staff for human resource, performance, payroll, security and safety of our premises and tax purposes. CS Pharma processes similar information relating to consultants, contractors and other third parties that we engage to deliver products or services.

Website Visitors

CS Pharma collects named information about visitors to our company website when there is a request volunteered from an individual. This includes requests, for example by clients regarding information about company services, or when medical professionals are interested in contributing to a clinical trial or where job applicants are applying for a vacancy. CS Pharma may collect various data via cookie-based technologies, linked to virtual identities allocated to visitors when they access our websites. This information is used for website analytics and for first party marketing. These virtual identities are sometimes connected with real world identities of visitors when they submit named details. This enables CS Pharma to personalise marketing messages to make them relevant to those visitors.

Internal and External Disclosures of Personal Information

Personal information is only shared on a “need to know” basis within CS Pharma and its affiliates and with relevant third parties to deliver stated legitimate business purposes. Any access to personal information contained within databases and binders is carefully restricted and only viewable by appropriate staff for legitimate purposes. CS Pharma does not trade or sell personal information.

Under some circumstances, CS Pharma may be required by law enforcement or judicial authorities to disclose certain personal information as part of investigations or for litigation purposes. CS Pharma may disclose personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganisation, dissolution or other sale or transfer of CS Pharma or cases or all of its assets.

Any companies who work as vendors for CS Pharma are required to sign “processor” and/or confidentiality agreements whereby they commit to only process personal information consistent with contracted purposes and take organisational and technical security safeguards for the data​.

Your Rights

In accordance with data privacy laws and contractual commitments, CS Pharma ensures that individuals can exercise all relevant informational rights with respect to their personal information processed by the organisation, including but not limited to the right to access the personal data we hold about them,  the correction of their personal data when incorrect, out of date or incomplete, to withdraw consent at any time, object to processing of their personal data, request deletion of personal data we hold about them (this right may not be available to participants in clinical trials), restrict aspects of data processing, prevent direct marketing and request transmission of personal data in a common digital format (e.g. pdf) to the themselves or another organisation.

In all other respects, where no overriding interest prevails, CS Pharma will endeavour to allow the following informational rights under this Policy as a matter of good practice:

• to allow access to copies of personal information within a reasonable timeframe;
• to correct personal information where inaccurate; and
• to withdraw a previously provided consent to processing of personal information.

If you wish to exercise any of these rights, please contact our data protection officer using the details shown in the section titled “Inquiries, Complaints and Requests to Exercise Rights” below.

Information Security

CS Pharma maintains wide-ranging information security policies to apply technical and organisational security measures.  This is to ensure we protect sensitive and personal information that participants provide to us, against unauthorized access or loss. CS Pharma’s security breach policy provides a procedural response for managing any breach of personal information, including making necessary notifications to individuals or governmental authorities.  CS Pharma stores information on servers within the UK and use commercial measures to ensure that your data is kept safe and treated in accordance with this privacy policy and data protection and privacy laws.

Considerations When Online

The pages on CS Pharma’s website may contain links to external websites, i.e. outside of the company. These external websites are not controlled or endorsed by CS Pharma. This Policy does not apply to linked websites outside of CS Pharma.  CS Pharma recommends that visitors review the privacy policy of each individually linked website before submitting any personal information.  We do not accept any responsibility or liability for external/other websites’ privacy policies.

Our web pages also use cookies. A cookie is a data file that is placed by a website operator on the hard drive of a visitor to their website. CS Pharma and third parties with whom we work, may place cookies with the following functions on the computers of visitors to the CS Pharma website: to allow the site to deliver the service requested by the visitor; to remember repeat visitors; to improve the user experience of the site; to allow the company to perform site analytics; and to serve and help tailor our marketing messages on our websites and elsewhere on the internet, based on the visitor’s previous browsing activity.

The web browser and cookie settings on your electronic devices can be tailored to manage your online relationship with CS Pharma. At this time, we do not respond to “do not track” signals, however most web browsers will allow users to choose which cookies can be placed on their electronic device and to delete or disable cookies.  Visitors should be aware that disabling cookies may prevent them from using certain features on the CS Pharma website. For more information, please see our Cookie Policy.

Children’s Online Privacy Protection

CS Pharma does not collect information through our websites from individuals who are known to be under the age of 13, and no part of our online presence is directed to anyone less than 13 years.

Inquiries, Complaints and Requests to Exercise Rights

Communications, queries, requests to exercise informational rights (e.g., access to data) or complaints can be addressed for the attention of the Data Protection Officer, CS Pharma, 19 Park Road, Lytham St Annes, Lancashire, FY8 1PW, United Kingdom. Within UK individuals have the right in law to complain about how their information is managed to a supervisory authority that is responsible for regulating compliance with the Regulation. The following URL links to the relevant authority https://ico.org.uk/make-a-complaint/your-personal-information-concerns/.

Legal Status of Policy and Policy Changes

This Policy is not a contract, and it does not create any legal rights or obligations. CS Pharma reserves the right to modify or amend this Policy and may do so according to new or amended legislation.  The updated Policy will be posted on https://www.cspharma.com/privacy-policy (Last Updated: 18th May 2022).