Consent Management =================== Checking the Consent Documents ------------------------------- There are three options that justify a **Legal basis for data processing**: - **Recruitment consent** (Art. 6 (1) lit. a, Art. 9 (2) lit. a GDPR) - **Study consent** (Art. 6 (1) lit. a, Art. 9 (2) lit. a GDPR and Art. 27 BDSG) - **Guardianship** (Art. 6 (1) lit. a, Art. 9 (2) lit. a GDPR and Art. 1626, 1902 BGB) Castellum is mainly intended for the management of recruitment consents. Study consents must be obtained separately from the respective study conducters 1. Log in to Castellum by using your username and password 2. Click on **Admin** on the front page 3. Scroll all the way down and click on **Consent documents** - You will see a list of all consent documents that have been created - Additional information displayed is the date of creation and whether the consent document is valid or not Updating the Consent Documents ------------------------------- Consent documents are marked as invalid if a change in legislation occurs, substantial changes have been made to the old document or other reasons require the signing of a new document. 1. There are two options you may implement when a consent document becomes invalid For both options first go to **Admin** on the front page > **Consent documents** in the last section > click on the date the consent document you want to change the status for has been created 1.1. The consent form can be marked as **Is deprecated** AND **Is valid** - **Is deprecated** can be considered as an intermediate step between the validity and invalidity of a consent document - with this option, the subjects may remain in the database and may be recruited but a new consent document should be obtained soon 1.2. If you uncheck the box saying **Is valid** but leave the check in the box stating **Is deprecated**, the consent document is generally marked as no longer valid - If the invalidity of the consent is saved, there is no longer consent for the recruitment of a subject in the database This does not apply when the **Legal basis for data processing** is a **Study consent** or **Guardianship**. You can see the legal basis for data processing for each subject individually by following the instructions below: - Click on **Subjects** on the front page - Type in the first and last name of the subject and click on **Submit** - Click on **details** next to the subject - In the tab **Overview** you can see the three possibilities for consent and which of them apply to the respective subject 2. If you wish to upload a consent document that is currently valid, proceed as follows: - Click on **Admin** on the front page - Scroll down and click on **Consent documents** - Click **ADD CONSENT DOCUMENT** (grey oval on the upper right) - Select a file - Choose one of the three saving options Deletion of a Consent Document ------------------------------ 1. Click on **Admin** on the front page 2. Scroll down and click on **Consent documents** 3. Click on the consent document to be deleted 4. Click on **Delete** 5. Confirm the question regarding the deletion of the consent document by clicking **Yes, I'm sure** Maintenance of Recruitment Consents ------------------------------------ In order to get an overview of all subjects for whom a new recruiting consent is required, proceed as follows: 1. Click on **Subjects** on the front page 2. Go to **Maintenance** 3. Click on the fourth tab **Consent** - You can see which **subjects have an outdated consent** in a list 4. Click on **Details** next to **Last updated on: XY** - A new tab will open for each subject for whom consent is deprecated or invalid 5. Go to **Data protection** (fourth tab) - If you see an orange description field that says **The current consent refers to an outdated document and will soon expire, thus rendering the recruitment consent invalid. Please contact this subject and ask them to consent to the latest document or withdraw their consent. This message will disappear once you change the value of the checkbox.**, proceed with steps 6-7 6. Obtain valid consent for recruitment either online, by telephone or postal - As an intermediate step, check the box **Recruitment consent** once 7. If the subject consents to the latest document or withdraws its consent, that has to be marked - If the subject consents to the latest document: Press **Confirm** in the box **Recruitment consent** and press **Save** - If the subject requests GDPR deletion, check the box **To be deleted** and press **Save**