Consent Management ================== Review of the legal basis for data processing --------------------------------------------- There are three options that justify **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 DSGVO and Art. 1626, 1902 BGB) Castellum is mainly used for the management of **Recruitment consent**. **Study consents** must be obtained separately from the database by the respective **Study conductor** at the execution level 1. Click on **Admin** on the front page 2. Go to **Consent documents** in the **Subjects**-field - There you will see a list of all consent documents that have already been created - As additional information, the date of creation and the validity of the consent document are displayed Updating consent forms ---------------------- Consent documents are marked as invalid if a change in the law occurs, significant changes are made to the old document, or other reasons require the subjects's signature on a new document 1. There are two options that can be implemented when a consent document becomes invalid. - For both options, first go to **Admin** at the front page > **Consent documents** > click on the creation date of the consent document to be modified 1. The consent document can be marked as **Is valid** AND **Is deprecated** - **Is deprecated** can be seen as a intermediate step in the process of declaring a valid consent document to be invalid - If both checkboxes are marked, the subjects remain in the database and may be recruited. However, a new declaration of consent should be obtained as soon as possible 2. If only the box **Is deprecated** is ticked, the consent document is presumed to be invalid in general - If the invalidity of the document is saved, there is no longer any recruitment consent of subjects in the database This does not apply if the **Legal basis for data processing** refers to a **Study consent** or a **Guardianship**. The **Legal basis for data processing** can be viewed for each individual subject by following the instructions below: - Go to **Subjects** on the front page - Enter the first and last name of the subject and click on **Submit** - Go to **Details** next to the subject - You can see three different **Legal basis for data processing** in **Overview** and which of those apply to the respective subject 2. If you wish to upload a valid and current consent document, proceed as follows: - Click on **Admin** on the front page - Go to **Consent documents** - Click on **Add Consent Document** (oval with grey background) - Choose the file you want to upload - Click on one of the saving options Deletion of a consent document ------------------------------ 1. Click on **Admin** on the front page 2. Go to **Consent documents** 3. Choose the consent document to be deleted 4. Click on **Delete** 5. Confirm the query about whether the version should be deleted by clicking on **Yes, I am sure** Maintenance of Recruitment consent ----------------------------------- To get an overview of all subjects for whom a new **Recruitment consent** is required, proceed as follows: 1. Click on **Subjects** on the front page 2. Go to **Maintenance** (blue button) 3. Choose the fourth tab **Consent** - You will see a list of all subjects with recruitment consents that are not current 4. Click on **Details** next to the indication **Last updated on: XY** - A new window will open for each subject with invalid recruitment consent 5. Go to the fourth tab **Data protection** individually - You will see an orange field that indicates the following text: **The subject has recently come of age. Please ask them to renew or withdraw their consent. This message will disappear once you change the value of the checkbox.** 6. Obtain a valid recruitment consent either by E-Mail, telephone or post - As an intermediate step, click once on the checkbox **Recruitment consent**. This is how you note that you are waiting for confirmation from the subject 7. If the subject agrees or withdraws his/her consent in the current consent document, this must be indicated - If the subject agrees, click on **Confirm** below **Recruitment consent** and **Save** - If the subject requests a deletion according to GDPR, click on **To be deleted** and save your submission