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.
Product Active Life: The period from the discovery of a product until
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 Action must be taken once records are no longer active, current, useful, have been replaced, or officially closed.
|
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 |
|
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 |
|
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