The Data Controller is Vanda Research Limited, a limited company registered in England and Wales (registration number 10021632) the registered office of which is at C/O BCS, Windsor House, Station Court, Station Road, Great Shelford, Cambridge, Cambridgeshire CB22 5NE, United Kingdom. You can contact the data controller by writing to Stephanie Burnage, Vanda Research Ltd, Heathcoat House, 20 Savile Row, London W1S 3PR, or sending an email to [email protected].

Vanda Research Ltd have no Data Processors, in relation to personal data, i.e. any person (other than an employee of the data controller) who processes the data on behalf of the data controller.

25/05/2018

Stephanie Burnage, the Data Protection Officer.

The European General Data Protection Regulation, came into force on 25^th May 2018 and is the basis of this Data Protection Policy.

This Data Protection Policy sets out how we, Vanda Research Limited, collect, store and use information about you when you use our website, https://vandaresearch.com and where we otherwise obtain or collect information about you.

The reasons for the policy are to comply with the law, follow good practice, to protect clients, staff and other individuals and to protect the company.

We collect individual information from our company staff and individual and company information from consumers of our research.

This Data Protection Policy complies with both the law and good practice and respects individuals’ rights. The company will be open and honest with individuals whose data is held and provide training and support for staff who handle personal data, so that they can act confidently and consistently.

In the event of data breaches the Supervisory Authority (the ICO) will be notified within 72 hours. In addition, for major breaches the data subjects will be notified without delay. A personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data.

The Board has overall responsibility for ensuring that the organisation complies with its legal obligations.

The Data Protection Officer is Stephanie Burnage, COO, Vanda Research Ltd. Her responsibilities include:

• Briefing the Board on Data Protection responsibilities
• Reviewing Data Protection and related policies
• Advising other staff on Data Protection issues
• Ensuring that Data Protection induction and training takes place
• Notification to the ICO if required
• Handling subject access requests
• Approving unusual or controversial disclosures of personal data
• Approving contracts with Data Processors

All staff should read, understand and accept any policies and procedures that relate to the personal data they may handle in the course of their work.

We record the names and contact details of the individuals within institutions with whom we have research supply agreements.

We record the names, ‘know your client’ information and contact details of the institutions with which we have research supply agreements.

We have a regular cycle of checking, updating or discarding old data on our staff and research clients.

The lawful basis for the personal data processed is one or more of the following, described in Article 6 (1) of the General Data Protection Regulation:

(a) Consent: the individual has given clear consent for us to process their personal data for a specific purpose.

(b) Contract: the processing is necessary for a contract we have with the individual, or because they have asked us to take specific steps before entering into a contract.

(c) Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).

(d) Vital interests: the processing is necessary to protect someone’s life.

(e) Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.

(f) Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.)

Data collected from our research clients is on the basis of (b) Research contracts and (f) Our legitimate interests.

Once given, consent can be withdrawn, but not retrospectively.  There may be occasions where Vanda Research Ltd has no choice but to retain data for a certain length of time, even though consent for using it has been withdrawn.

We record the name, email address, postal address and telephone number of individuals filling in the form on the Contact page on the website. This information is not transferred outside the EEA and is stored via Amazon Web Services (AWS).

We do not use any first party cookies on our website. We use third party cookies to collect data for Google Analytics, in order to ensure that users get the best experience on our website.

Google Analytics cookies collect and store information on how visitors are interacting with our website. For example, which webpages are visited most often, how long for, and what device you use to visit these pages.

We use these cookies to ensure areas of our website are working correctly and that we are providing users with relevant information. No identifiable information can be stored in or obtained from these cookies.

For more information, please see Google Analytics data privacy and security notice.

On the areas of our website that utilise cookies, you will be presented with an option to opt out of cookies.

We use a third-party provider, The Rocket Science Group LLC, to deliver our research products. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our products. For more information, please see The Rocket Science Group LLC's privacy notice.

We store information on the hard drives of Vanda Research Ltd computers and back it up on Dropbox, Office 365 and Google cloud-based systems.

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means) you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

We log all telephone calls with research clients for monitoring purposes but do not record conversations.

Information from compliance procedures, such as on-boarding, research handling and quarterly compliance meetings, is stored on hard copy files and kept in secure storage.

Vanda Research Ltd is committed to ensuring that Data Subjects are aware that their data is being processed and

• for what purpose it is being processed
• what types of disclosure are likely, and
• how to exercise their rights in relation to the data

We retain contact details of research clients so that we can provide them with research products in accordance with the Agreements we have with them.

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by contacting the Data Protection Officer by email at [email protected], in writing to: Vanda Research Ltd, Heathcoat House, 20 Savile Row, London W1S 3PR, United Kingdom, or by phone on +44 203 167 6980:

• to request access to your information and information related to our use and processing of your information;
• to request the correction of your information;
• or request the erasure of personal data (right to be forgotten) providing there is no overriding legitimate grounds;
• to request that we restrict our use of your information;
• to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller;
• to object to the processing of your information for certain purposes; and
• to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

The controller will provide information on action taken on request to the data subject without undue delay and in any event within one month of receipt of the request.

• In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, which is the Information Commissioner’s Office (ICO), whose website is below.

All employees of Vanda Research Ltd and those who have access to any kind of personal data will have their responsibilities outlined during their induction procedures.

Data Protection issues will be covered during employee training, team meetings, supervisions, etc.

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/