Trials4us: Volunteer Privacy Notice 

This privacy notice sets out how Richmond Pharmacology Limited  (referred to as “Richmond”, “our” or “we”) processes the personal data when you register as a clinical trial or study volunteer via our website (www.trials4us.co.uk / www.trials4japanese.co.uk) or our Volunteer Recruitment Team.

Please read this privacy notice carefully to get a clear understanding of how we collect, use, protect or otherwise handle your personal information. 

Please be advised that Richmond are the Data Controller for volunteer recruitment and registration activities, as well as certain activities relating to the health, safety and security of visitors to our site.  

If you agree to participate in a clinical trial or study, you will be provided with further information regarding how your personal data will be processed in relation to the trial or study.  This information will be provided in the Study Sponsors Patient Information Pack and Informed Consent Form prior to your participation.  

Study Sponsors are the Data Controllers for study-specific data, which includes tests and diagnostics, and any queries or requests relating to this type of data and processing, should be referred directly to them via the contact details provided in the Informed Consent Form.

WHAT PERSONAL INFORMATION DO WE COLLECT?  

In order for you to register as a trial or study volunteer, including when we conduct screening to establish your eligibility to participate in specific studies, we will collect personal information from you. This allows us to create a profile account for you that holds your information.  This personal information will be collected when you register on our website for clinical trials and/or blood donations, during telephone conversations with our Volunteer Recruitment Team or when you respond to a survey or other marketing communication from us. We may also collect personal information through other features on our website. The types of personal information we collect include your: 

• name; 
• home address; 
• phone number (home, work or mobile);  
• email address;  
• date of birth;  
• gender;  
• passport details or details relating to proof of identity;  
• place of birth
• employment status

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In certain circumstances (e.g. to assess eligibility for a clinical trial), we may also need to collect sensitive personal data about you, which may include information about your:  

• health (e.g. if you are a smoker or how much alcohol you consume); 
• ethnicity; 
• height; 
• weight 
• blood type; and 
• medications and allergies.

 

If you enrol for a clinical trial and to ensure your safety, we may also ask for personal information relating to your next of kin (e.g. their name and your relationship to them), or for personal information relating to whoever referred you to us (e.g. their name and contact details.)  

If you are interested in any of our trials or studies a Volunteer Recruitment staff will call you to collect further information to determine eligibility.  You may also be required to attend our clinical site for further physical and medical testing and diagnostics, but you will be advised if that is the case.

 

THIRD PARTIES PERSONAL INFORMATION 

Where you submit information on behalf of another person, you confirm that you have made that person aware of how we may collect, use and disclose their information, the reason you have provided it, how they can contact us, the terms of this notice and that they have consented to you acting on their behalf. 

HOW DO WE USE YOUR PERSONAL INFORMATION? 

We will only use and, where applicable, share your personal data for one or more of the following purposes: 

• to register you as a clinical trial or study volunteer and create an account (profile)
• to analyse your suitability as a clinical trial or study volunteer, e.g. to check that you are of the correct age for the specific trial or study; 
• to respond to any enquiries or complaints you may have relating to our service; 
• to send periodic emails regarding upcoming clinical trials and or blood donations, study specific information, information regarding scheduled appointments, appointment reminders and general company information; 
• to follow up with you for further correspondence (live chat, email or phone enquiries); and 
• to ensure the security of your account and our business, for example, by requesting personal information to prevent or detect fraud or abuses of our website
• to ensure the safety and security of our facilities, our staff and visitors
• to reimburse volunteers for any legitimate expenses incurred when participating in studies.

Some of your identifying personal data (National Insurance Number or passport number) is also entered onto a UK register named TOPS-check so that other research units such as us can ensure you are not participating in more than one clinical trial at the same time. It is important to note, however, that this data can only be obtained by authorised users of the TOPS-check system who have your details already.

CHILDREN 

As a general policy, Richmond does not allow persons under the age of 18 to register on our website as a clinical trial volunteer. We also do not knowingly send marketing communications to persons under the age of 18. To the extent that Richmond does process children’s personal data, it will take steps to ensure an enhanced level of data protection. In the case of children aged 16 and under Richmond shall ensure that consent is given or authorised by the holder of parental responsibility over the child. Where consent is relied upon in these circumstances, Richmond shall ensure that any information provided is understandable to children and approved by the relevant Ethics Committee.  

INFORMATION FOR MARKETING PURPOSES 

When you register as a clinical trial or study volunteer, we will use your information as follows:  

• to provide you with information about our clinical trials or blood donations which we feel may interest you; 
• to administer a contest, promotion, survey or other site feature; and 
• for market research purposes, where we may contact you to ask for your feedback. 

If at any time you wish us to stop using your information for these purposes, please use the appropriate opt-out link in our messages to you or email us at volunteer@richmondpharmacology.com. 

LEGAL BASIS FOR PROCESSING 

To process your data lawfully we need to rely on one or more valid legal bases, for different personal data processing activities, as follows:

Volunteer Profile Data

Purpose:

Registering new volunteers and creating volunteer profiles

Communicating with new and existing volunteers in relation to their engagement in potential and current studies.

Responding to issues, requests and complaints.

Legal Basis:

Performance of a Contract between the Volunteer and Richmond

Legitimate Interests of the Controller to create and maintain accurate volunteer profiles and to ensure data quality to ensure eligibility to participate in studies.

Vital Interests in protecting health and wellbeing of research study subjects

Volunteer Health Data

Purpose:

Screening to ensure and evidence eligibility in accordance with study protocols

Conducting research and analysis

Ensuring the health and safety of data subjects

Legal Basis:

Legal obligation of the Controller to ensure safety and efficacy.

Legitimate Interests of the Controller 

Explicit Consent

Archiving in the public interest for scientific research

Volunteer Financial Data

Purpose:

Payment of expenses and reimbursements

Record keeping and accounts

Legal Basis:

Performance of a Contract

Legal Obligation

Communications, Promotion and Marketing

Purpose:

Communicating with registered volunteers regarding new, planned/future studies.

Communicating with registered volunteers regarding studies that they are participating in.

Feedback to improve service and experience.

Business development and growth.

Legal Basis:

Legitimate Interests of the Controller to conduct business and enable growth

Legitimate Interests of the Controller to improve and develop service provision.

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Please note that where we rely on our legitimate interests to process your personal data, we ensure that our interests do not override yours or present a risk to your fundamental rights and freedoms.

DISCLOSURE OF YOUR INFORMATION  

We do not sell or trade your personal information and our general policy is that disclosure of your personal information to third parties will only take place in accordance with the applicable law and for the purposes listed above (or where we will have made your personal information anonymous). However, there are circumstances where we may wish to disclose or be compelled to disclose your personal data to third parties. These circumstances include disclosure:    

• to our outsourced service providers or suppliers to facilitate the provision of our clinical trials;  
• to another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your personal data will be permanently transferred to a successor company;  
• to legal advisors who may need to manage or litigate a claim; 
• to public authorities where we are required by law to do so; and 
• to any other third party where you have provided your consent. 

RETENTION OF PERSONAL DATA 

If you are, or have previously been, a clinical trial volunteer of ours or already registered on our site then we may continue to hold and process your information. Your personal information will be retained for as long as it is necessary to carry out the purposes set out in this privacy notice (unless longer retention is required by the applicable law). However, we will not retain any of your personal information beyond this period and the retention of your personal information will be subject to periodic review. We may keep an anonymised form of your personal information, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so. 

DATA SUBJECT RIGHTS  

Data protection law provides individuals with numerous rights, including the right to: access, rectify, erase, restrict and object to the processing of, their personal data.  Individuals also have the right to lodge a complaint with the relevant data protection authority if they believe that their personal data is not being processed in accordance with applicable data protection law.  

• Right to make subject access request (SAR). Where we are processing your personal data as a data controller you may, where permitted by applicable law, request copies of your personal data.  If you would like to make a SAR, i.e. a request for copies of the personal data we hold about you, you may do so by writing to the volunteer@richmondpharmacology.com. The request should make clear that a SAR is being made.  
• Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete personal data.   
• Right to withdraw consent. Where consent is the applicable legal basis for specific processing, you may, as permitted by applicable law, withdraw your consent to the processing of your personal data at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit certain service features for which the processing of your personal data is essential.  
• Right to object to processing. You may, as permitted by applicable law, request that we stop processing your personal data. 
• Right to erasure. You may request that we erase your personal data and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your personal data, such as, a legal obligation that we have to comply with, or if retention is necessary for us to comply with our legal obligations. 

If you wish to exercise any of your rights, please contact us via DPO@richmondpharmacology.com

If you wish to exercise any of your rights in relation to study data processed during a clinical trial or study, please contact the Study Sponsor directly via the contact details provided in the Study Informed Consent Form.

Your right to lodge a complaint with the supervisory authority. We will always endeavour to respond diligently and carefully to your queries, concerns or complaints, however, if you are unsatisfied with our action or response, you have the right to contact the relevant supervisory authority directly. 

To contact the Information Commissioner’s Office in the United Kingdom, please visit the https://ico.org.uk/global/contact-us/ for instructions. 

CHANGES TO THIS PRIVACY POLICY 

As we strive to improve our service, we may review this privacy notice from time to time. We reserve the right to change this notice at any time and an updated version will be published here on our website.  

CONTACTING US 

If there are any questions regarding this privacy policy, you may contact us using the information below:  

Richmond Pharmacology  
1a Newcomen Street 
London 
SE1 1YR 
England 

info@richmondpharmacology.com 
+44 (0) 20 7042 5800 

Data Protection Officer:  
DPO@richmondpharmacology.com