HITRIplus: Personal Data Processing – Project and Website

HITRIplus’ Processing of Personal Data – general information about the Project and the Consortium

In the HITRIplus Project personal data are processed in order to achieve the five strategic objectives, aimed at the advancement of ion therapy research.

The data processing activities carried out by the Project by means of related Partners can be summarized in the following categories:

Internal Platform

The internal HITRIplus platform is a service dedicated to building a community of researchers and industrial partners. By registering to the platform, the data provided are used, in execution of the contract between the parties, to:

  • Verify the legitimacy of the request for access to the reserved area
  • Allow access to the area dedicated to the Project documentation
  • Exchange information and encrypted documents with the “helpdesk service” via interface with a chat system

The data collected consist in identification and contact details (email), including professional LinkedIn profile aimed at verifying identity and professional requirements to access the reserved area. The provision of data is mandatory for the service execution.

The data are not transferred to third parties but the provider of the site management (data processor) and are accessible only to the staff of CNAO’s Communication Office.

The subscriber can request the deletion of his profile at any time by sending a request to comunicazione@cnao.it or privacy@cnao.it.

This processing activity is performed via this website, as described below.

Clinical Newsletter

All members of the internal platform (either by subrscription or by upload) receive a periodic newsletter with scientific information sent on the basis of legitimate interest of HITRIplus coordinator (CNAO) to execute the Project and share knowledge about ion therapy research.

For this purposes, only contact details of the data subjects will be used by CNAO’s Communication Office and by the specialized suppliers in charge of communication activities. Data will be stored and used until the data subject exercises the opt-out to receive the clinical newsletter, which can be carried out at any time from its footer, thus preventing subsequent transmissions.

This processing activity is performed via this website, as described below.

General Newsletter

All users of this site who are interested in being informed about HITRIplus activities, can request from the footer of the site (or from any other forms contained in specific landing pages or documents) to be subscribed to the newsletter in order to receive, via email, information and news about the activities of the HITRIplus Project, including invitations to participate in events or surveys and fund raising campaigns.

For this purpose and in execution of the contract, the contact details of the data subjects will be used by CNAO’s Communication Office and by the specialized suppliers in charge of communication activities. The data will be stored and used until the data subjects revokes the consent to receive the newsletter, which can be carried out at any time from its footer, preventing subsequent transmissions.

This processing activity is performed via this website, as described below.

To integrate and propel medical research on cancer treatment with heavy ions beams, a web based heavy ion therapy patient registry collecting clinical and dosimetric data of cancer patients receiving carbon ions radiotherapy, is created.

Data for observational perspective research are collected only with the consent of patients who have initiated CIRT in one of the adrontherapy center. Patients are asked for consent to use their identification data and other very personal information on the tumour that afflicts them and the therapy they are subjected to. Data are pseudonymized by each ion therapy center (MEDA, CNAO, UKHD and UKGM) before the transmission to the Registry

A read-write access to this data will be granted only to the researchers of the four Centres, and if necessary to the Commission Services.

The data stored in the Registry are retained for 50 years, according to the informed consent for personal data processing for clinical research purposes provided to patients.

This processing activity is not performed via this website, and described here for the sake of transparency.

Courses Registration

HITRIplus organizes courses and masterclasses on heavy ion therapy research delivered by leading scientists and engineers which will broaden the view and increase the understanding in the field.

Participants for each school are selected through a merit-based equal opportunity (including gender equality) European-wide call. At this end, the personal data required for the application for the single course (identification, curriculum and contact data, videos and photos) are therefore necessary, in execution of the contract, for evaluate the eligibility of the student, be able to manage registrations and contact those who register for information or changes or cancellations of the event.

The data are collected and managed by SEEIIST (UKIM, CMSM) which take lead responsibility for the organisation and marketing of the courses and can be accessed by the staff of the CNAO’s Communication Office and the specialized provider who manages this website.

Data are stored according to the rules specified for the single event in the related information notice.

This processing activity is performed also via this website, as described below.

Internship and Secondments

HITRIplus organizes secondments (for employed researchers/practitioners) and internships (for students) to spend a few weeks at one of the European heavy ion therapy research infrastructures and hence gain hands-on experience.

The participants will be selected through a merit-based equal opportunity (including gender equality) open call to the whole European community. At this end, the personal data required for the application for the secondments/internships (identification, curriculum and contact data) are therefore necessary, in execution of the contract, for evaluate the eligibility of the individual and be able to manage registrations.

The data are collected and managed by UM which takes responsibility of organising the secondments and internships. Moreover, they could be accessed by the staff of CNAO’s Communication Office and the specialized provider who manages this website and then transferred to the hosting facility.

Data are stored according to the rules specified for the single facility.

This processing activity is performed also via this website, as described below.

The physicians who want to join the Transnational Access (TA), a service offered by HITRIplus, and request an assessment of eligibility for treatment with hadrontherapy for a patient must transmit information relating to the state of health and other patient’s very personal information  to HITRIplus’ clinical team (User Selection Panel), to allow their assessment. In this sense, the processing of personal data is carried out in execution of the contract between the parties (physician, potential patient and HITRIplus USP, including the 4 adrontherapy centers as joint-controllers).

Whatever the type of potential patient and request, the physician must follow a procedure that can be activated only through this website and that allows the complete and secure transmission of all information necessary to carry out the assessment. The document sending system used on this site is encrypted: no personal information is stored on the site, but delivered directly to the recipient (User Selection Panel) and not accessible to any third parties.N

All the requested information is used with the sole purpose of carrying out the preliminary evaluation of the clinical case, necessary to determine if the subject can be a candidate for hadrontherapy treatment, failure to provide data prevents us from proceeding with the evaluation. The data will be accessible and consulted only by the the User Selection Panel (USP) and, in case of positive evaluation, transmitted to one of the four TNA providers (CNAO, MEDA, UKHD and UKGM).

The data are deleted after 30 days from their receipt, unless it is given access to the TNA service, in which case the data subject (both physician and patient) receives specific information at the first access to one of the four hadrontherapy facility and the relevant data are stored in related clinical records.

The researchers who want to join the Transnational Access (TNA), a service offered by HITRIplus, and apply for beam usage must fill in the related request form and send their personal identification data. In this sense, the processing of personal data is carried out in execution of the contract between the parties (researcher and HITRIplus USP, including the 5 adrontherapy centers as joint-controllers).

Whatever the type of project, the research must follow a procedure that can be activated only through this website and that allows the complete and secure transmission of all information necessary to carry out the beam time request assessment. The document sending system used on this site is encrypted: no personal information is stored on the site, but delivered directly to the recipient (User Selection Panel) and not accessible to any third parties.

All the required information is used with the sole purpose of carrying out the preliminary evaluation of the research project, necessary to determine if it can be approved. The data will be accessible and consulted only by the the User Selection Panel (USP) and, in case of positive evaluation, transmitted to one of the five TNA providers (GSI; CNAO, MEDA, UKHD and UKGM).

The data are deleted after 30 days from their receipt, unless it is given access to the TNA service, in which case the data subject receives specific information at the first access to one of the hadrontherapy facility and the relevant data are stored in its information systems.

HITRIplus Website’s Processing of Personal Data

The Data Controller of the personal data processed on this site (http://www.hitriplus.eu) is Fondazione CNAO – Strada Campeggi 53 – 27100 PAVIA – privacy@cnao.it

Fondazione CNAO’s Data Protection Officer can always be reached at the address dpo@cnao.it.

The processing activities held on this site are handled by CNAO personnel, as well as by the website manager (external provider), who edits and host it, properly appointed as data processor.

At the date of this information notice, no transfers are made outside the European Economic Area for all related processing activities. For clarification, information, or further details you can always refer to privacy@cnao.it or to CNAO’s DPO.

Some services that process personal data among multiple pages and sections of the website are made available to users. Among the abovementioned categories of processing, the services which involve the processing of personal data through this website are the following:

  1. Networking and Communication, Dissemination and Outreach: data for registration to the “internal platform” (identification, contact and professional information) are collected through the available forms and transmitted to the mass mailing system for the dispatch of newsletters, retained until the data subject’s opt-out.
  2. Networking and Communication, Dissemination and Outreach: data exchanged through the “Helpdesk” chat system are collected and registered with the aim of providing answers and deleted after 30 days.
  3. Education, Training and Job Opportunities: a web page is provided for those individuals and institutions who want to join the courses, internships or secondments organized by HITRIplus. They can be applied for, or through the compilation of a form and the upload of the CV, or by direct sending to an email address.
  4. Transnational Access (clinical): a request page is provided to non-project physicians requesting the assessment of a patient for experimental therapy. The page provides a form to be filled that allows the upload to the destination repository of a significant number of precoded attachments including patient’s health data.
  5. Transnational Access (research): a request page is provided researchers for the beam usage application. The page provides a form to be filled that allows the upload to the destination repository of the required attachments related to the research project.

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  1. CNAO uses technical cookies, designed to improve the experience on this website (and therefore in execution of the service). Technical cookies’ data are possibly accessible only to the specialized provider who manages this website and are deleted at the end of each session.
  2. CNAO uses third-party statistical cookies, i.e. Google Analytics, which are used to monitor the site’s performance in aggregate form, for example to find out the number of pages visited or the number of users who have viewed a particular section. In general, the analysis of these cookies generates aggregate statistical data without any reference to the identity of the site surfers. This information is also useful for evaluating any changes and improvements to be made to the site itself. This plugin is not a tool of our ownership, for more information, therefore, you can consult the information provided by Google. CNAO receives only aggregate information from Google, but Google can track the behaviour of the individual user using the information for its own purposes.
  3. CNAO uses profiling cookies tout-court in order to disseminate information on hadrontherapy and the related possibilities of treatment to specialist users. Profiling cookies track user behaviour on the pages of this website to provide targeted communications also through social media. Profiling activities and consequent exposure to targeted communications are typically addressed to a target of specialist professionals with whom HITRIplus Consortium want to build relationships with in order to spread the culture on hadrontherapy, on research, and about Hitriplus five major objectives..

For this reason, upon accessing the site and with certain periodicity, we will ask for  your consent to activate analytical and / or profiling cookies or if we must leave them inactive. If you give your consent but then change your mind, or otherwise prefer not to be tracked, you can always:

  • view the details of the cookies issued by this site, accessible from the consent request banner (which can be viewed simply by clearing the browser cache). Your choice can be changed at any time.
  • use anonymous browsing (Do Not Track option) of your browser. To find out how to activate the option on the main search engines, click on the browser you use Internet Explorer, Google Chrome, Mozilla Firefox, Apple Safari.

User’s Rights

All data subjects, as interested parties, have the right at any time to obtain by CNAO information about the existence of any personal data and to know its content and origin, as well as request its correction, deletion or limitation of the processing. They also have the right to lodge a complaint with the competent Personal Data Protection Authority for alleged violations of current legislation.

All the rights summarized above can be exercised by writing to the address:  privacy@cnao.it  or by following the detailed information in the related information notice. In any case, it will be our care to answer you without delay.

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