Retention Policy

Introduction

This document outlines the Data Retention Policy of C.G. Papaloisou, a pharmaceutical company affiliated with Alector Pharmaceuticals and is the parent company of Louanfarm Ltd. It specifies the retention periods for various categories of records and data to ensure compliance with legal, regulatory, and operational requirements. The policy applies to all information relating to healthcare professionals, patients, third parties, and job candidates.

The policy defines specific retention periods based on the type of data, its use, and its relevance to the company’s ongoing activities. It also clarifies the concept of a product’s “active life” to determine appropriate retention timeframes for product-related data.

 

Definitions

Product Active Life: The period from the discovery of a product until

• the discontinuation of clinical development for an investigational product,
• the withdrawal of a product from the market, or
• the acquisition of the product by another company.

A product is considered “active” as long as (i) clinical development has been officially discontinued, or (ii) the company or marketing authorization holder continues to manufacture or sell the product in any part of the world.

Active Life: The time during which a record is considered current and relevant. This is reviewed annually. Action must be taken once records are no longer active, current, useful, have been replaced, or officially closed.

 

Retention Period

Healthcare Professionals

Adverse event reports	Product active life + 50 years
Records of meetings with external parties	10 years
Visit report	3 years
Contact details retained for informational purposes	Active life (i.e., until withdrawal of consent)
Reporting and disclosure of payments and value of items provided to healthcare professionals	10 years
Patient assistance programs	10 years
Accounting records, data files & supporting documentation	12 years

 

Patients

Adverse event reports	Product active life + 50 years
Records of meetings with external parties	10 years
Non-clinical patient information	Last activity date + 3 years
Patient assistance programs	10 years

 

Third Parties

Contracts & related documentation	Termination of contract + 6 years
Donations/Sponsorships	10 years
Accounting records, data files & supporting documentation	12 years
Investigations related to compliance matters	End of investigation + 6 years
Legal process & legal claim records	End of legal process/claim + 10 years
Customer complaint records	10 years
Responses to product-related inquiries	Product active life + 6 years
Scientific communication & interactions	6 years
Unsuccessful candidate records	1 year

 

Last updated Sep 2025