Regulatory Open Forum

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  • 1.  Italian Data Protection Agency

    Posted 20-Mar-2012 11:55

    Hello All

    Is there someone that has experience submitting a CTA in Italy that could provide some insight on the Data Protection Agency?  I would really appreciate your input.

    First of all we want to understand why is the DPA form 'needed'?

    1.    It has been suggested that we submit only "Table 1 - Processing of Genetic Data".  We are wondering in your experience if the DPA form is submitted only when genetic data are collected? 

    2.    Our reading of the regulation seems to say that purpose of the DPA form is to protect privacy of Italians.  So 'electronic data transfer' is why we think it is needed to do this at all. If that is the case then it is needed anytime there are eCRFs whether or not they collect genetic data.

    Understand exactly why and when the DPA form is required would be extremely helpful.  Is it just when genetic data is captured or do all studies submit it?  And which tables have you submitted?

    I would appreciate hearing your experiences and what you have submitted

    Thank you for your time

    -carol



    -------------------------------------------
    Carol Bailey RAC
    Director, Regulatory Affairs
    OncoGenex
    Bothell WA
    United States
    -------------------------------------------


  • 2.  RE:Italian Data Protection Agency

    Posted 21-Mar-2012 06:19

    Hi Carol

    We do loads of CTA for US clients in Italy - and this is a very common question.

    Why - the reason is that you will database data about Italian citizens - but it is not about the eCRF data, as this is typically anonymised. You will be databasing the names and addresses (professional address, and often private email addresses) of the PI and the sub-Investigators.

    You need to register with the DP agency once, and you need to do this within the first 6 months of the first trial which you do in Italy.

    So - if you have ever sponsored a study in Italy before, it should already have been done.  If this is your first time, it is a fairly simple process.

    Feel free to contact me directly, if you need any more assistance in Italy.

    It is a great country for oncology, but there are certainly some "hints" to getting Italy to work for you.

    Regards

    -------------------------------------------
    Kathryn Hutchinson
    Director of Regulatory Affairs
    AMS Advanced Medical Services Ltd
    London
    United Kingdom
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  • 3.  RE:Italian Data Protection Agency

    Posted 22-Mar-2012 10:27
    Helllo Kathryn
    I really appreciate your prompt reply.  Can you give me some further details?

    In the DPA submissions you have filed - what is the most common table submitted?

    Is it typical to do more than 1 table?

    thank you
    -carol

    -------------------------------------------
    Carol Bailey RAC
    Director, Regulatory Affairs
    OncoGenex
    Bothell WA
    United States
    -------------------------------------------