This section describes SILLAR CLINICAL’s line of conduct when processing personal data. This line of conduct is applied to both automatic and manual data processing operations.
- Controller: Natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data.
- Personal data: 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.
- Processing: Any operation or set of operations that is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- Processor: Natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller.
- Third country: A non-European Union (EU) country
- Third party: A natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
SILLAR CLINICAL uses various technological and procedural security measures to protect the Personal Data it collects, uses or transfers from loss, misuse, alteration or destruction.
Any dispute relating to or in connection with the application and interpretation of the policy is governed by Belgian law and only the courts of Ghent, Belgium have exclusive competence to take cognizance of said disputes and any tort actions related thereto.
Personal data from a data subject in EU shall not be transferred to third countries, international organizations or third parties unless the recipient has an adequate level of protection of the personal data as per GDPR.
Data Subject Rights
Data subjects in this context have the following rights:
- Right of access
- Right to rectification
- Right to erasure
- Right to restriction of processing
- Right to data portability
- Right to object
- Right not to be subject of Automated individual decision-making
1. Right of access by the data subject
Each data subject has the right to access his or her personal data and has the right to obtain the following information:
- the purposes of the processing
- the categories (e.g. genetic or biometric information, race, Religion, membership to Union) of personal data concerned
- the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations according to the appropriate safeguards
- where possible, the envisaged period of which the personal data will be stored, or, if possible, the criteria used to determine that period
- where the personal data are not collected from the data subject, any available information as to their source.
The data subject has the right to lodge a complaint with supervisory authority. Personal data shall be retained according to applicable law.
2. Right to rectification
Data subjects have the right to have inaccuracies in, or incompleteness of, his or her personal data rectified and completed, free of charge and without any delay.
3. Right to erasure – right to be forgotten
The data subject has the right to obtain the erasure of personal data concerning him or her without undue delay where one of the following grounds applies:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the data subject withdraws consent where there is no other legal ground for the processing
- the personal data have been unlawfully processed
The right to erase shall not apply to the extent that processing is necessary: for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in so far as the right is likely to render impossible or seriously impair the achievement of the objectives of that processing.
4. Right to restriction of processing
The data subject has the right to obtain restriction of processing where one of the following applies:
- the accuracy of the personal data is contested by the data subject
- when the personal data is no longer needed for the purposes of the processing
5. Right to data portability
The data subject has the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided.
6. Right to object
The data subject has the right to object, on grounds relating to his or her particular situation, at any time. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject. The data subject has the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest (e.g. clinical study report). Where personal data are processed for direct marketing purposes, the data subject has the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
7. Right not to be subject of Automated individual decision-making
The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
In case of further questions or remarks, as well for requests to access, rectify or remove your personal data, please contact the DPO (firstname.lastname@example.org) at Sillar Clinical BVBA, Nagelstraat 28, 8700 Tielt, Belgium.