Concrete CSV patterns, audit lessons and GAMP-5 critical-thinking — direct from active Pharma projects.
Daniel Herrmann Consulting
Owner: Daniel Herrmann
Enzweilerweg 3a
66709 Weiskirchen
Germany
Phone: +49 170 7878065
Email: info@daniel-herrmann.io
Web: daniel-herrmann.io
VAT identification number pursuant to § 27a German VAT Act (UStG):
DE328451232
In accordance with § 36 VSBG: we are neither willing nor obliged to participate in dispute resolution proceedings before a consumer arbitration board.
We are responsible for our own content on these pages under the general laws. Under Articles 4 to 8 of Regulation (EU) 2022/2065 (Digital Services Act, DSA), as a service provider we are not obliged to monitor transmitted or stored third-party information or to investigate circumstances that indicate unlawful activity.
Note: The §§ 7–10 of the previous Telemedia Act (TMG) on the liability for digital services have not been transferred to the German Digital Services Act (DDG). Liability for digital services is now primarily regulated by Regulation (EU) 2022/2065 (DSA), in particular Articles 4–8 — referenced above. The §§ 7–10 DDG cover other subjects (limited responsibility under DSA Articles 4–8 + Wi-Fi access, blocking claims under copyright law, lists of audiovisual-media-service and video-sharing-platform providers, and information-request rights of the competent authorities under state law).
The content and works on these pages created by the site operator are subject to German copyright law. Reproduction, processing, distribution and any kind of exploitation outside the limits of copyright require the written consent of the respective author.
The following information gives a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to identify you personally.
The controller responsible for data processing on this website pursuant to Art. 4 (7) GDPR is:
Daniel Herrmann Consulting
Daniel Herrmann (sole proprietor)
Enzweilerweg 3a · 66709 Weiskirchen · Germany
Phone: +49 170 7878065
Email: info@daniel-herrmann.io
A data protection officer has not been appointed; the controller is your point of contact for all data protection matters.
When you visit this website, the hosting provider automatically collects technical information in server log files: IP address (anonymised after 7 days), date and time of access, page accessed, referrer, user agent. Legal basis: Art. 6 (1) (f) GDPR — legitimate interest in technically reliable operation. Retention: 7 days, then automatic deletion. No merger with other data sources.
If you contact us via form, email or phone, we store the information you provide (name, email, company, message content) to process the enquiry and for follow-up questions. Legal basis: Art. 6 (1) (b) GDPR (pre-contractual measures) and Art. 6 (1) (f) GDPR (legitimate interest in answering enquiries). Retention: deletion as soon as the enquiry has been finally processed, at the latest after 12 months, unless statutory retention obligations apply. Data is not shared with third parties.
To request our practical guides (e.g. Strategy Guide, Compliance-Gap Analysis, Execution Playbook) we ask for your email address and, optionally, your name and company. The data is stored solely to provide the requested material and for documentation of consent. Legal basis: Art. 6 (1) (a) GDPR (consent). Retention: until your withdrawal, at most 24 months. The newsletter subscription is offered as a separate, opt-in checkbox on the lead-magnet form (no coupling — you can request the material without subscribing). No marketing emails are sent without separate consent.
If you sign up for our newsletter, we use the double-opt-in procedure: after entering your email and name you receive a confirmation email with a verification link. Only after you click the link do we activate the subscription and document your consent.
Data: email, name, consent timestamp, confirmation IP.
Purpose: sending the monthly dhc newsletter with practice insights, plus documentation of the consent process (Art. 7 (1) GDPR).
Legal basis: Art. 6 (1) (a) GDPR (consent), § 7 (2) Nr. 3 UWG.
Retention: for as long as your subscription is active; consent logs retained for 3 years after the end of the subscription as evidence in the event of complaints.
Withdrawal: every newsletter contains a one-click unsubscribe link in the footer. Alternatively a short email to info@daniel-herrmann.io is sufficient.
Processor: the newsletter is sent via our hosting provider's SMTP infrastructure; we currently do not use a third-party email-marketing tool. As soon as we transition to a dedicated newsletter-tool (e.g. Brevo), we will update this section and conclude an additional data-processing agreement.
To understand which content in our lead-magnet emails and newsletter issues is actually useful, we route outbound links through an internal redirect endpoint (`/t/
A consolidated view of all retention periods with the rationale behind each one — the principle: minimal storage, clear purpose, documented basis.
This website uses analytics and tracking tools that go beyond pure reach measurement and create usage profiles. Personal data may be processed (in particular IP address, device and browser information, behaviour data) and transferred to third countries (including the USA). Legal basis is your consent pursuant to § 25 (1) TTDSG and Art. 6 (1) (a) GDPR. The consent is granted on first visit via our cookie banner and can be withdrawn at any time with effect for the future — see section 6.10 below. Withdrawal is as simple as granting consent (Art. 7 (3) GDPR); the lawfulness of processing carried out on the basis of consent prior to withdrawal remains unaffected.
Provider: Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark (a Usercentrics company) — EU-based.
Purpose: Cookiebot is the consent management platform (CMP) we use to document your consent in line with § 25 TTDSG and Art. 7 GDPR and to block analytics / tracking tools until you opt in.
Data: Cookiebot stores a ‘CookieConsent’ cookie containing your consent state (categories, timestamp, anonymous identifier) and a server-side consent log.
Retention: up to 12 months from the moment consent is given; renewed on each new visit after expiry.
Legal basis: the processing of consent itself rests on Art. 6 (1) (c) GDPR (legal obligation to document consent).
Third-country transfer: primary processing in the EU; sub-processors may include service providers outside the EEA under EU Standard Contractual Clauses.
Data processing agreement: concluded with Cybot A/S.
More info: Cookiebot Privacy Policy.
Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (parent company: Google LLC, USA).
Purpose: Tracking tool that goes beyond pure reach measurement. Google uses the collected data for the operation of GA4 and partly for its own purposes (no commissioned processing in the narrow sense for these purposes).
Data: pseudonymous identifiers (client ID), IP address (shortened on EU server, see below), page views, dwell time, scroll depth, click events, device and browser information, approximate location (country / region from IP).
Retention: up to 14 months for event-level data, then automatic deletion.
IP shortening: The IP address is shortened on an EU server before being forwarded to the USA (‘_anonymizeIp’ equivalent in GA4 is active by default).
Third-country transfer: data is processed on servers in the USA. Safeguards: EU Standard Contractual Clauses and the EU-US Data Privacy Framework (Adequacy Decision of 10 July 2023). Note that the supervisory authorities point out that the legal certainty gained may only be temporary; previous adequacy regimes (Safe Harbor, Privacy Shield) were invalidated by the CJEU.
Data processing agreement: concluded with Google Ireland Ltd.
More info: Google Privacy Policy, Browser opt-out.
Provider: Microsoft Ireland Operations Ltd., One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland (parent: Microsoft Corporation, USA).
Purpose: Session recordings and heatmaps to improve usability. Note: session recordings are a particularly intensive form of processing — they can capture sensitive content even though input fields are masked by default. We have configured the strictest masking level (‘Strict’) for all form fields.
Data: mouse movements, clicks, scroll behaviour, page views, device and browser information, shortened IP address, country.
Retention: up to 12 months from the last recorded session.
Third-country transfer: Microsoft is a US group; data may be processed on servers in the USA. Safeguards: EU Standard Contractual Clauses and the EU-US Data Privacy Framework. The reservations noted above for GA4 apply analogously.
Data processing agreement: Microsoft Online Services DPA concluded.
More info: Microsoft Privacy Statement.
Provider: Dealfront Germany GmbH (Leadfeeder), Markgrafenstraße 36, 10117 Berlin, Germany — EU-based provider.
Purpose: B2B identification of visiting companies based on commercially licensed IP-address databases (e.g. RIPE, ARIN, public corporate IP ranges). We use this to inform our sales outreach. The aim is identification of the company, not of an individual user. Important note from a data protection perspective: IP addresses can constitute personal data, particularly when combined with other data. We therefore treat Leadfeeder processing as relevant under GDPR.
Data: IP address, page views, timestamp, dwell time, referrer.
Data sources: Dealfront enriches IP data with publicly available company information and licensed B2B databases.
Retention: up to 12 months on visit level; aggregated reports may be retained longer.
Third-country transfer: Dealfront operates primarily on EU infrastructure; sub-processors may include US service providers under EU Standard Contractual Clauses.
Data processing agreement: concluded with Dealfront Germany GmbH.
More info: Dealfront Privacy Policy.
Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (parent: Google LLC, USA).
Purpose: We use Google Ads conversion tracking and (where activated) remarketing to measure the success of advertising campaigns and to address visitors with relevant ads.
Data: pseudonymous click ID (gclid), conversion event, conversion timestamp, device and browser information. Cookies used include `_gcl_au` (conversion linker) and `test_cookie` (doubleclick.net technical test cookie).
Retention: `_gcl_au` up to 90 days, conversion logs in the Google Ads account according to Google retention settings.
Third-country transfer: data is processed on Google servers including the USA. Safeguards: EU Standard Contractual Clauses and the EU-US Data Privacy Framework.
Data processing agreement: concluded with Google Ireland Ltd.
More info: Google Privacy Policy, Ad personalisation settings.
Provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland (parent: LinkedIn Corporation, USA).
Purpose: The LinkedIn Insight Tag enables campaign measurement, audience analytics and (where activated) retargeting for LinkedIn ad campaigns.
Data: IP address (truncated), timestamp, page URL, device characteristics, LinkedIn member ID where the visitor has been logged in to LinkedIn. Cookies used include `bcookie`, `lidc`, `bscookie`.
Retention: up to 6 months for direct identifiers; aggregated campaign reports may be retained longer.
Third-country transfer: data is processed on LinkedIn servers including the USA. Safeguards: EU Standard Contractual Clauses and the EU-US Data Privacy Framework.
Data processing agreement: concluded with LinkedIn Ireland Unlimited Company.
More info: LinkedIn Privacy Policy, LinkedIn opt-out.
Provider: Google Ireland Limited (see 6.1).
Purpose: Google Tag Manager (GTM) is a tag-management system that loads other tracking tags (e.g. Google Analytics, Google Ads, LinkedIn Insight Tag) on this website. GTM itself does not set any cookies and does not collect personal data per se; it only orchestrates the tags loaded after consent.
Data: technical request data (IP address, timestamp, user agent) is briefly seen by Google’s GTM-loader server. No persistent identifier is set by GTM itself.
Third-country transfer: the GTM loader is hosted on Google infrastructure including the USA. Safeguards as in 6.1.
Note: we have configured GTM so that no measurement tag fires before you have given consent via our Cookiebot banner.
More info: Google Privacy Policy.
Provider: Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA, with EU representative Cloudflare Germany GmbH, Rosental 7, c/o Mindspace, 80331 Munich.
Purpose: Cloudflare is used by our hosting provider as a Content Delivery Network (CDN) and security layer. The ‘__cf_bm’ cookie is set by Cloudflare’s bot-management to distinguish humans from automated traffic and to mitigate DDoS attacks and content scraping in real time.
Why we consider this technically necessary: Without bot-mitigation our website would be vulnerable to credential-stuffing, scraping and DDoS attacks that compromise availability, integrity and the security of the personal data we process (e.g. lead-magnet form submissions, newsletter signups). Bot-mitigation is therefore a technical security measure within the meaning of Art. 32 GDPR (security of processing). Cloudflare itself classifies ‘__cf_bm’ as ‘strictly necessary’ (Cloudflare cookie documentation). Replacing Cloudflare bot-management would weaken the security of personal data on this site.
Data: IP address, request headers, technical fingerprint of the request. No persistent identifier across sites.
Retention: ‘__cf_bm’ cookie expires after at most 30 minutes of inactivity. Aggregated security logs at Cloudflare are retained briefly under Cloudflare’s standard retention.
Legal basis: § 25 (2) Nr. 2 TTDSG (technically required to operate the requested service) and Art. 6 (1) (f) GDPR (overriding legitimate interest in a secure, available website).
Third-country transfer: Cloudflare is a US group; data may be processed on servers in the USA. Safeguards: EU Standard Contractual Clauses and the EU-US Data Privacy Framework (Adequacy Decision of 10 July 2023). Please note that the legal certainty of the framework may be limited; the General Court of the EU has annulment proceedings pending (case T-553/23).
Data processing agreement: concluded as part of the hosting contract.
More info: Cloudflare Privacy Policy.
Provider: Google Ireland Limited (see 6.1).
Purpose: Google Search Console (GSC) lets us monitor how the site performs in Google’s search results — indexing status, search queries that lead to the site, click-through rates, technical crawl errors.
Cookies / tracking on visitors: GSC itself sets no cookies on visitors of this website and runs no client-side script. The site ownership is verified by a static HTML meta tag and / or a DNS TXT record.
Data: aggregated search analytics from Google’s side (search queries, impressions, clicks); these are not directly linked to individual visitors. The data is made available to us only in aggregated form.
Legal basis: Art. 6 (1) (f) GDPR — legitimate interest in monitoring the site’s search visibility.
Third-country transfer: the aggregated reporting is generated on Google infrastructure including the USA. Safeguards as in 6.1.
More info: Google Privacy Policy.
Session cookies are deleted when the browser is closed. Permanent cookies have the following maximum lifetimes: Google Analytics 4 — up to 14 months (data retention shortened to 14 months in GA4 settings); Microsoft Clarity — up to 12 months; Google Ads (`_gcl_au`) — up to 90 days; LinkedIn (`bcookie`) — up to 6 months; Cloudflare (`__cf_bm`) — at most 30 minutes of inactivity; Leadfeeder — typically session-based, not stored on the device; CookieConsent (Cookiebot) — up to 12 months from the moment consent is given.
You can withdraw your consent at any time with effect for the future — withdrawal is as easy as granting consent:
1. Open cookie settings: click the ‘Cookie settings’ link in the footer to re-open the banner and adjust your choice (this controls all of GA4, Clarity, Google Ads, LinkedIn and Leadfeeder).
2. By email: send a short message to info@daniel-herrmann.io — we will block the relevant tools for you.
3. Per tool: for Google Analytics the official browser opt-out is available; for Google Ads under Ad personalisation settings; for LinkedIn under LinkedIn opt-out. Microsoft Clarity and Leadfeeder are controlled exclusively via our cookie banner.
The lawfulness of processing carried out on the basis of consent prior to withdrawal remains unaffected (Art. 7 (3) GDPR).
This website loads Google Fonts. Connection data (in particular the IP address) is transmitted to Google. Provider: Google Ireland Limited (see section 6.1). Legal basis: Art. 6 (1) (f) GDPR — legitimate interest in a consistent typographic presentation. As an alternative, fonts are also held in a local fallback so that font loading can fail safely without breaking the layout.
To protect your data we implement appropriate technical and organisational measures pursuant to Art. 32 GDPR — among them: TLS encryption (HTTPS) for the entire site, encrypted database connections, server hosting in the EU (Kinsta / GCP Frankfurt), restricted admin access via individual accounts with strong passwords and 2FA, regular automatic backups, role-based access controls, a documented record of processing activities pursuant to Art. 30 GDPR, and data minimisation at the application level. We continuously review and update these measures.
Under the GDPR you have the following rights:
Requests regarding these rights are to be directed to: info@daniel-herrmann.io. We will respond within the statutory period (usually one month).
Last updated: 29 May 2026. We reserve the right to adapt this policy so that it always meets current legal requirements. The current version is always retrievable from this website.
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