Maison Milentis, a société par actions simplifiée registered at the RCS of Paris under number 107 334 203, with its registered office at 173 rue de Courcelles, 75017 Paris, France, is the controller of the personal data described in this notice.
You can reach us at legal@maisonmilentis.com or by writing to us at that address.
We give you this notice before we collect any personal data from you, as clause 13.1 of our Expert Services Agreement requires. It explains what we hold about you, why we hold it, who sees it, how long we keep it and what you can ask us to do.
It covers two groups. Experts on our bench, and those we are considering admitting to it — if you have received our Expert Services Agreement, that is you. And people whose professional contact details we hold because we may approach them about joining the bench, but whom we have not assessed and may never contact. Most of what follows applies to both; where something applies only to experts we say so.
We publish this notice on our website so that anyone whose details we hold can find it, whether or not we have written to them.
It does not cover our clients or their people.
Most of it comes from you: what you send us when you join, what you tell us during onboarding, and the payment and invoicing details you give us so that we can pay you.
The rest comes from:
If we hold only your professional contact details and have not assessed you, we hold the first two categories below and nothing else. The rest applies once you are being admitted to the bench.
Contact and identity. Your name, email address, telephone number, postal address, organisation, job title and degree.
Professional profile. Your professional category, whether you are a clinician or a researcher, your qualifications, and the state or country of your primary licensure.
Credentials. Your licence and registration numbers, and the results of our checks against the primary registers.
Employment. Your current employer and those you have worked for over the preceding 24 months.
Interests and affiliations. The board, advisory and committee positions you hold, and any financial interest you have told us about, other than ordinary investments. We use these to check for conflicts.
Restricted topics. The trials, sponsors and products you have told us you cannot discuss.
Screening. The results of our sanctions, exclusion and debarment searches, our review of published sources, and the decision we reached on each. Section 6 explains this further.
Identity verification. A record that we verified your identity: the method used, who confirmed it, when, and a reference. We do not keep a copy of any identity document, or any image of you.
How we source and route work. How you came to us, whether you approached us yourself, whether you hold a public-sector clinical post, and the tier we have assigned you.
Payment. Your bank details, your tax forms and how you invoice us.
Engagements. The assignments you have worked on, the honoraria paid to you, the dates, and the records that evidence each engagement was run properly — your attestations, the fair market value basis for your rate, and the agreements you signed.
We do not hold health information about you. Being a clinician is a profession, not a condition.
To decide whether to admit you to our bench, and to keep you on it. Our legitimate interests, and those of the clients we serve, in working only with verified experts of known integrity. Once you have signed our Expert Services Agreement, we also process your data to perform that agreement.
To perform our agreement with you. To offer you assignments, agree scope and fees, receive your work and pay you.
To screen you against sanctions lists. Our legal obligations under European restrictive-measures rules, which prohibit us from making funds available to designated persons.
To check for conflicts. Our legitimate interests, and those of our clients, in making sure that no expert is engaged on a matter in which they have an interest, or in which they act for another party.
To keep accounting records and meet our tax obligations. Our legal obligations under French law.
To make transparency disclosures. Our legal obligations, where a law or an applicable industry code requires disclosure; and our legitimate interests in disclosing voluntarily where no code compels us. Clause 10 of the Expert Services Agreement records your agreement to these disclosures. Section 7 explains what becomes public.
To evidence that our engagements were run properly. Our legitimate interests, and those of our clients and of the public, in being able to show after the fact that every engagement met the standards we promise.
Where we rely on legitimate interests, you can object. Section 10 explains how.
This is the most sensitive thing we do with your data, so we set it out on its own.
Before you begin work, and at intervals afterwards, we search sanctions, exclusion and debarment lists maintained by governments and regulators, and we review publicly available sources for anything bearing on your integrity. We record what each search returned and the decision we reached on it.
We do not set out to collect information about criminal offences, and we do not seek out court records, charges or convictions. A search may nonetheless return a result that concerns or suggests an offence. Where that happens we record the fact of the result and our decision on it, and we do not obtain the underlying record.
You can ask us what our searches returned about you and what we concluded, and you can tell us if you think we have it wrong.
Our clients. Before your name is released, a client sees only a profile from which you cannot be identified, and a reference code. Your name reaches a client only where you have consented in writing to release it, to that client, for that assignment. That is enforced in our systems, not only in our procedures: an assignment naming you is refused unless your consent is on file. A client who receives your details is an independent controller of them, and our contract with every client requires it to use them only for the assignment concerned.
Publicly, under transparency regimes. Payments to healthcare professionals are reportable under industry codes and under transparency laws in Europe, France and the United States. Under some of these your name and the amount we paid you become publicly searchable. We also disclose voluntarily in some cases where no code requires it. We would rather you heard this from us than discovered it.
Our suppliers. We use a small number of providers who process your data on our instructions and on written terms:
Others. Our professional advisers and auditors, and any authority, regulator or court where the law requires us to disclose.
Our systems are hosted in the European Union. Three of our providers involve processing in the United States: Google, whose corporate group is there and whose European storage options do not extend to backups, search indexes, metadata or data in transit; Resend, whose parent company is in the United States; and GitHub, whose infrastructure runs our nightly encrypted backup. All three are covered by the European Commission’s standard contractual clauses.
DigiCert is in the United States but receives no personal data, only a cryptographic hash, so no transfer arises.
If we hold only your professional contact details, we keep them for three years from our last contact with you, and then delete them.
While you are on our bench, and for six years after our agreement with you ends, we keep your record. Six years is the period in which a claim under the agreement could be brought.
Where you have delivered an engagement, we keep the records for that engagement for ten years from its close. This is longer, and it is deliberate: French commercial law requires us to keep accounting records, and the limitation periods for corruption offences in France and for false claims in the United States run for longer than the contract period. The clock runs from the close of the engagement, not from the date you leave the bench, because these records belong to the engagement rather than to our relationship with you.
Your identity verification record follows the same periods. The document itself is never held.
What erasure actually means here. If you ask us to erase your data after you have delivered an engagement, we will remove your contact details, but we will not delete the engagement record or the evidence supporting it. Data protection law permits us to keep it where we need it to establish or defend legal claims and to meet our own legal obligations, and this is such a case. Our evidence archive is also written so that it cannot be altered or deleted by anyone, including us — that is what makes it worth having. We would rather you knew this before you ask than after.
You can ask us to give you a copy of your data; to correct it if it is wrong; to erase it, subject to section 9; to restrict what we do with it; and to send it to you or to someone else in a portable form where that right applies.
You can object to any processing we carry out on the basis of our legitimate interests. You can withdraw your consent to the release of your name at any time, and withdrawing it does not affect a release we have already made.
You can also give us directions about what should happen to your data after your death, as French law allows.
Write to legal@maisonmilentis.com. We will answer within one month, and will tell you if we need longer.
Some of what we do is automated, and we set it out here so you know what is decided by a machine, what is decided by a person, and what you can do about either.
A tier we compute for you. We score each engagement against nine recorded factors — among them whether you practise clinically, whether a trial or an investigational product is involved, whether your employer is a competitor or restricted, whether the output will be published or filed, and whether the work touches confidential information. The score produces a tier. The tier decides how the engagement is supervised: whether a session must be moderated, whether a written output is read before release, and whether it must be cleared by a second person. It also feeds our internal pricing. It does not decide whether you join our bench, and it does not set your fee — your fee comes from a separate fair market value rate card. A person may raise your tier and must record why; nobody can lower it below the computed figure.
Two outcomes that a person cannot override. Where the subject matter of a proposed engagement is one we will not touch — unpublished trial data, patient data, an employer’s confidential information or material non-public information — the engagement can only be declined. The same applies where we would otherwise be acting for both sides of the same matter. In each case a named person records the decision, but the system permits no other answer.
What is not automated. Our screening is not. A sanctions, exclusion or debarment search returns a possible match, and a named person compares the secondary identifiers and decides whether it is you. Nothing is concluded by the match itself. The same is true of our conflict checks: apart from the two outcomes above, every flag is judged by a person who must record their reasoning and who can decide either way.
How to challenge any of it. These outcomes are produced from recorded facts — your employers, the topics you told us you cannot discuss, the restricted parties a client has named, the dates. They are not predictions about you. So the way to change an outcome is to correct the fact it rested on. Tell us what is wrong, we will correct the record and run the assessment again against the corrected facts, and the result may be different. Every run records exactly which information it considered, so we can show you what was used. You can also ask a person to look at any of it, tell us what you think we have got wrong, and contest the outcome.
Your data is encrypted in transit and at rest. Our evidence archive is written so that records cannot be altered or deleted once made. Access is limited to those who need it. Backups are encrypted.
If we change this notice we will tell you, and the version and date at the top will change. Where a change materially affects how we use your data we will tell you before it takes effect.
Tell us first, at legal@maisonmilentis.com, and we will try to put it right. You can also complain to the Commission nationale de l’informatique et des libertés (CNIL), the French data protection authority, at www.cnil.fr, or to the supervisory authority where you live or work.