Introduction

Welcome to MI-TRIAL LIMITED (MI-TRIAL) privacy policy for Mi-Trial The clinical trial companion app (Mi-trial, the system)

MI-TRIAL respects personal privacy and is committed to protecting personal data and fully complying with its legal obligations under the GDPR and the Data Protection Act 2018. MI-TRIAL is a ‘data processor’ in respect of Mi-Trial, which means that we only process personal data as instructed by our customers, i.e. the trial organisations or sponsors of your study who opt to use the system. 

Purpose of this privacy policy

This privacy policy aims to give you information about how MI-TRIAL collects and processes personal data when you download or use our Mi-Trial online system. 

Who are Mi-Trial?

MI-TRIAL 24/7 Limited (MI-TRIAL) is a company which was incorporated on the 1 October 2021 in England and Wales under No. 13657025 and whose registered office is at The Langley Building, Southmoor Road, Manchester, England, M23 9QZ. The business of MI-TRIAL is the development of health technologies, health apps, clinical web portals and clinical assessment tools. 

Contacting Mi-Trial

You can contact MI-TRIAL by writing to us at the above address, or by emailing us at hello@mi-trial.com or by calling us on 0114 286 6200. 

Who is responsible for the management of data protection at Mi-Trial

We have appointed a data protection officer to support the management of data protection at MI-TRIAL and for dealing with any questions you may have in relation to this privacy policy. You may contact MI-TRIAL using the contact details given in sections 2. and 3. above, or directly at data.protection@mi-trial.com. 

MI-TRIAL hosts its Mi-Trial app and cloud-based software using Amazon Web Services (AWS). For details on AWS and their Privacy Notice, visit https://aws.amazon.com/privacy/

Mi-Trial technical architecture also includes use of the following systems: 

● Google Firebase – for push notifications 

● AWS Cognito – for secure storing of your data, and authentication/login

● Microsoft SQL Server Express – for storing setup data for the Mi-Trial application and web portal

● AWS Elastic Beanstalk – Serving the mobile front-end applications

What sort of personal data do we collect and hold?

The Mi-Trial system is designed to hold minimal amounts of data about you. For security purposes and to verify your identity, three data points are held for all users of the system (trial organisations and participants): 

● Name (First Name and Last Name) 

● Email address

● Phone number – this is for use of 2-factor authentication (2FA)

We collect one additional data point for participants, to ensure we can verify your identity if needed:

● Address

Your personal data is held securely using AWS Cognito, which also is used for authenticating your logins using 2-factor authentication. For details of Cognito, visit https://aws.amazon.com/cognito/ 

The web portal will also display a schedule of your visits to your trial organisation, displaying your name and cascade of appointments. 

Any data you enter about medication, symptoms or other in your Events Diary in Mi-Trial, is not sent to your trial organisation. The data is not accessible by MI-TRIAL or your trial team, and is simply your personal diary of events you may wish to share at a visit.

Who is your data shared with?

To deliver Mi-Trial, MI-TRIAL requires the support of another company called The Cliff Face Ltd. The Cliff Face Ltd are a UK-based software development company focused on delivering bespoke digital app and cloud software solutions. MI-TRIAL hosts the system using AWS, but is not permitted to process the data collected within it other than as instructed by our customers. 

Technical details of your device (phone model, Android/iOS version, browser type and version) may be shared with The Cliff Face Ltd in the event of technical problems accessing or using Mi-Trial. This will only be done as instructed by our customer, with your consent.

MI-TRIAL only acts upon the instructions of our customers and data will only be shared with other bodies with their authorisation (unless exceptional circumstances apply, and we are required to share data by law). It is the responsibility of your trial organisation to provide a disclosure on how their service will be delivered and to seek consent from you if you wish to use our system to support your trial team with the delivery of their study.

Marketing

This app is solely for our customers’ purposes, so we will never share your personal or sensitive personal data with any third party for marketing or commercial purposes. Mi-Trial does not contain any advertisements. 

What are your data protection rights?

You have a number of rights under data protection law, including the right to see what data is held about you, have it corrected if it is inaccurate and even to have data removed from the system in some circumstances. If you wish to understand more about your rights or to exert them you must contact the body providing you with care as MI-TRIAL can only act when instructed by them We will of course do all we can to assist them if they so request.

Changes to this policy

MI-TRIAL keeps its privacy policy under regular review and places any updates on its home web page. This privacy policy was last updated on 26th May 2022. 

How to contact us

If you have any questions about MI-TRIAL or the system we provide please do not hesitate to contact us on email: hello@mi-trial.com or call us at: 0114 286 6200. Alternatively, write to us at: he Langley Building, Southmoor Road, Manchester, England, M23 9QZ 

Contacting the regulator to make a complaint

Data subjects have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority in relation to data protection issues (www.ico.org.uk). If a data subject feels that their data has not been handled correctly, or is unhappy with our response to any requests that they have made to us regarding our use of their personal data, they have the right to lodge a complaint with the Information Commissioner’s Office. We would, however, appreciate the chance to deal with any such concerns before you approach the ICO so please contact us in the first instance. 

The ICO can be contacted by calling 0303 123 1113 or by going online at www.ico.org.uk/concerns.