Clinical trial site
A clinical trial site (investigational or investigator site) is the physical location, such as a hospital department, clinic, research centre, general practice or, increasingly, the participant's home in decentralised trials, where trial-related activities are performed under the responsibility of a principal investigator. Sites recruit and treat subjects, collect source data, report adverse events and maintain the investigator site file.
The relationship between the sponsor and the site is governed by a clinical trial agreement, which allocates responsibilities, budget, insurance and data protection roles. Site selection, initiation, monitoring and close-out visits are conducted by the sponsor or its CRO in line with GCP.
Under the GDPR the site is generally a controller in its own right for the medical care and for the directly identifying source data it holds, while the sponsor is controller for the pseudonymised trial dataset; some jurisdictions and the EDPB have also considered joint controllership for certain activities. The site holds the key linking subject codes to identities, which is why the sponsor's data is pseudonymised rather than anonymous. Site staff personal data (CVs, training records, financial disclosures) is also processed by the sponsor and requires its own information notice.
