R-TF-015-004 Clinical Investigation Plan Legit.Health_ICD_DXP
Scope
The purpose of this Clinical Investigation Plan (CIP) is to set out the rationale, objectives, design, methodology, conduct, implementation, record-keeping and the method of analysis for the clinical investigation.
CIP Identification
| CIP | |
|---|---|
| Title of the clinical investigation | Post-Market Non-Interventional Performance Analysis of Legit.Health Plus for Image-Based Dermatological Diagnosis |
| Device under investigation | Legit.Health Plus (version 1.1.0.0) |
| Protocol version | 1.0 |
| Date | To be determined (TBD) |
| Protocol code | PMCF-ICD-DXP-2026 |
| Sponsor | AI LABS GROUP S.L. |
| Coordinating Investigator | TBD |
| Principal Investigator(s) | TBD |
| Collaborating Investigator(s) | TBD |
| Investigational site(s) | TBD |
| Ethics Committee | TBD |
If the ethics committee has assigned a code, it must be indicated in this table in the protocol code field and in the header.
Table of contents
- Scope
- CIP Identification
- Compliance statement
- Abbreviations and Definitions
- CIP or protocol specifications
- Product Identification and Description
- Justification of the design
- Risks and benefits of the product in investigation and clinical research
- Hypothesis
- Objectives
- Summary of the study
- Design and Methods
- Ethical considerations
- CIP Modification
- CIP Deviations
- Start, follow-up and end reports
- Statements of compliance
- Informed Consent process
- Adverse events, adverse product reactions and product deficiencies
- Vulnerable population (if applicable)
- Suspension or early termination of clinical research
- Publication policy
- Bibliography
- Annexes
Compliance statement
The clinical investigation will be conducted according to the Clinical Investigation Plan (CIP) and other applicable guidances and regulations. This includes compliance with:
- The ethical principles originating from the
World Medical Association's Declaration of Helsinki - Harmonized standard
UNE-EN ISO 14155:2020 Regulation (EU) 2017/745 on medical devices (MDR), including the applicableGeneral Safety and Performance Requirements (GSPR)as outlined in Annex I, and the requirements ofAnnex XV(Chapter I and Chapter II, Section 3)- Harmonized standard
UNE-EN ISO 13485:2016 MDCG 2024-3for its structural and content expectations,MDCG 2021-8concerning application requirements, andMDCG 2020-10/1 Rev 1for safety reporting timelines and definitionsRegulation (EU) 2016/679(GDPR)- Spanish
Organic Law 3/2018on the Protection of Personal Data and guarantee of digital rights.
All data processing within the device is carried out in accordance with the highest standards of data protection and privacy. Patient information is managed in an encrypted manner to ensure confidentiality and security.
The research team assumes the role of Data Controller, responsible for the collection and management of study data. Legit.Health acts as the Data Processor and is not involved in the processing of patient data.
The storage and transfer of data comply with European data protection regulations. At the conclusion of the study, all information stored in the device will be permanently and securely deleted.
The device employs robust technical and organizational security measures to safeguard personal data against unauthorized access, alteration, loss, or processing.
This clinical investigation will be conducted in accordance with the ethical principles originating from the World Medical Association's Declaration of Helsinki, as well as the standard ISO 14155:2020 (Clinical investigation of medical devices for human subjects - Good clinical practice).
Abbreviations and Definitions
- AE: Adverse Event
- AEMPS: Spanish Agency of Medicines and Medical Devices
- AEP: Adverse Reaction to Product
- AUC: Area Under the ROC Curve
- CAD: Computer-Aided Diagnosis
- CMD: Data Monitoring Committee
- CIP: Clinical Investigation Plan
- CUS: Clinical Utility Questionnaire
- DLQI: Dermatology Quality of Life Index
- GCP: Standards of Good Clinical Practice
- ICH: International Conference of Harmonization
- IFU: Instructions For Use
- IRB: Institutional Review Board
- N/A: Not Applicable
- NCA: National Competent Authority
- PI: Principal Investigator
- PPV: Positive Predictive Value
- NPV: Negative Predictive Value
- SAE: Serious Adverse Events
- SAEP: Serious Adverse Event to Product
- SUAEP: Serious and Unexpected Adverse Event to the Product
- SUS: System Usability Scale
CIP or protocol specifications
Principal Investigator
[To be determined]
Coordinating Investigator(s)
[To be determined]
Collaborating Investigator(s)
[To be determined]
Investigational sites
[To be determined]
Funding
[To be determined]
Product Identification and Description
| Information | |
|---|---|
| Device name | Legit.Health Plus (hereinafter, the device) |
| Model and type | NA |
| Version | 1.1.0.0 |
| Basic UDI-DI | 8437025550LegitCADx6X |
| Certificate number (if available) | MDR 792790 |
| EMDN code(s) | Z12040192 (General medicine diagnosis and monitoring instruments - Medical device software) |
| GMDN code | 65975 |
| EU MDR 2017/745 | Class IIb |
| EU MDR Classification rule | Rule 11 |
| Novel product (True/False) | TRUE |
| Novel related clinical procedure (True/False) | TRUE |
| SRN | ES-MF-000025345 |
Device Accountability (SaMD specific)
The sponsor (AI LABS GROUP S.L.) is responsible for product control. Access to the Legit.Health Plus software will be restricted via secure user credentials (username and password). The sponsor will establish procedures for tracking software usage. Access to unused, expired, or malfunctioning versions of the software will be immediately revoked by the sponsor.
Justification of the design
Background and rationale
This Post-Market Clinical Follow-up (PMCF) study addresses Gap 3 of the CER: Monitoring of Sustained Core Algorithmic Performance. The PMCF program must conduct formal, periodic monitoring to demonstrate the sustained stability and effectiveness of the device's core diagnostic algorithms (e.g., accuracy, AUC, Top-N metrics) in the post-market phase, ensuring continued acceptable performance over time.
This study ensures the stability of core diagnostic performance across all 239 ICD-11 categories supported by Legit.Health Plus in a multireader setting. On the whole, the objective of this study is to assess the Area Under the Curve ROC, Top-K metrics (Top-1, 3 and 5 in accuracy), sensitivity and specificity of the Legit.Health Plus medical device and Investigators when used on both malignant and benign skin lesions.
Risks and benefits of the product in investigation and clinical research
The subjects recruited in this study will not be exposed to any procedure that could endanger their safety. No adverse reactions related to the investigational product are expected.
Evaluation of preclinical and clinical data
These evaluations can be consulted in the T-015-005 Investigator's brochure.
Hypothesis
The use of Legit.Health Plus maintains stable core diagnostic performance across all 239 ICD-11 categories in real-world clinical settings, achieving consistent accuracy, sensitivity, and specificity thresholds when used by healthcare professionals.
Objectives
Primary objetive(s)
To evaluate the ongoing diagnostic performance (AUC and Top-N diagnostic accuracy) of Legit.Health Plus for image-based dermatological diagnosis across all 239 ICD-11 categories in a multireader setting.
Secondary objective(s)
[To be determined]
Summary of the study
This is an observational and prospective study using anonymised data to monitor the performance of Legit.Health Plus. Practitioners will assess cases with and without the device to confirm its sustained diagnostic accuracy.
Design and Methods
Type of clinical research
Observational and prospective study.
Population
[To be determined]
Duration
The study is intended to start in November 2026, with expected completion in March 2027.
Acceptance criteria
- AUC: > 0.8
- Top-5 Diagnostic Accuracy:
- Top-3 Diagnostic Accuracy:
- Top-1 Diagnostic Accuracy:
Inclusion and exclusion criteria
Inclusion criteria:
- Patients with skin lesions, which can be assessed by Legit.Health Plus according to its intended use.
- Men or women of any ethnic group.
- Patient is willing and able to read, understand, and sign the informed consent form (ICF)
Exclusion criteria:
- Patients who do not meet the inclusion criteria or cannot comply with the study procedures due to disability or other reasons.
Variables
- Principal: Area Under the Curve ROC, sensitivity and specificity in detecting malignant conditions, specially melanoma.
- Top-1, Top-3, and Top-5 diagnostic accuracy metrics in detecting different skin conditions representative of the dermatological consultation.
- Secondary: [To be determined]
Condition of interest
All 239 ICD-11 dermatological categories supported by the device.
Quality control
The principal investigator will be responsible for reviewing and approving the protocol, guaranteeing data confidentiality, and approving the final report. Inconsistencies will be controlled during data tabulation by executing computer filters and manual review.
Limitations of clinical research
[To be determined]
Ethical considerations
This study adhered to international Good Clinical Practice (GCP) guidelines, the Declaration of Helsinki in its latest amendment, and applicable international and national regulations. As applicable, approval from the relevant Ethics Committee was obtained prior to the initiation of the study. When applicable, modifications to the protocol were reviewed and approved by the Principal Investigator (PI) and subsequently evaluated by the Ethics Committee before subjects were enrolled under a modified protocol.
This study was conducted in compliance with European Regulation 2016/679, of 27 April, concerning the protection of natural persons with regard to the processing of personal data and the free movement of such data (General Data Protection Regulation, GDPR), and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights. In accordance with these regulations, no data enabling the personal identification of participants was collected, and all information was managed securely in an encrypted format.
Participants were informed both orally and in writing about all relevant aspects of the study, with the information being tailored to their level of understanding. They were provided with a copy of the informed consent form and the accompanying patient information sheet. Adequate time was given to patients to ask questions and fully comprehend the details of the study before providing their consent.
The PI was responsible for the preparation of the informed consent form, ensuring it included all elements required by the International Conference on Harmonisation (ICH), adhered to current regulatory guidelines, and complied with the ethical principles of GCP and the Declaration of Helsinki.
The original signed informed consent forms were securely stored in a restricted access area under the custody of the PI. These documents remained at the research site at all times. Participants were provided with a copy of their signed consent form for their records.
Data confidentiality
Current legislation will be complied with in terms of data confidentiality protection (European Regulation 2016/679, of 27 April, on the protection of natural persons with regard to the processing of personal data and the free movement of such data and Organic Law 3/2018, of 5 December, on Personal Data Protection and guarantee of digital rights). For this purpose, when applicable, each participant will receive an alphanumeric identification code in the study that will not include any data allowing personal identification (coded CRD). The Principal Investigator will have an independent list that will allow the connection of the identification codes of the patients participating in the study with their clinical and personal data. This document will be filed in a secure area with restricted access, under the custody of the Principal Investigator and will never leave the centre.
Once the paper CRDs are completed and closed by the Principal Investigator, the data will be transferred to a database.
As in the CRDs, the Database will comply with current legislation in terms of data confidentiality protection (European Regulation 2016/679, of 27 April, on the protection of natural persons about the processing of personal data and the free movement of such data and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights) in which no data allowing personal identification of patients will be included.
This study uses anonymised data.
Information to subjects and informed consent
It is the investigator's responsibility to obtain the patient's written informed consent before inclusion, after objectively explaining the objectives, methods, risks, and benefits in non-technical language.
Bias minimization measures
[To be determined]
Calendar
- Intended Start: November 2026
- Expected Completion: March 2027
Monitoring plan
[To be determined]
Completition of the investigation
After obtaining the study conclusions, a final report will be prepared in collaboration with the sponsor, based on the objectives outlined in the protocol.
Subject follow-up procedures
In the event of early termination, temporary suspension, or completion of the clinical investigation, subjects will continue to receive the standard of care as determined by their treating physician. If a subject withdraws their consent, no further data will be collected, but previously collected data will be processed according to data protection regulations, and the patient's routine medical care will not be affected. For subjects lost to follow-up, the investigating site will make reasonable attempts to contact the subject before officially recording them as lost. After the clinical investigation, subjects will return to their regular clinical care pathways without any alteration to their healthcare provision caused by the study.
Statistical analysis
[To be determined]
Procedures
[To be determined]
Data management
The data will be managed and tabulated with consistency rules and logical ranges to control inconsistencies during data tabulation. A validation process of the clinical data will be carried out by running computer filters based on validation rules, which will automatically identify missing values or inconsistencies of clinical data according to the protocol. Additionally, manual editing and validation will be performed using descriptive and exploratory statistical techniques to complement the detection of logical errors and inconsistent values.
The database will be considered closed upon completion of all data management processes and satisfactory resolution of discrepancies and errors in the data. Any changes in the database after its closure can only be made after written agreement between the Principal Investigator and the technical coordinators of the project.
AI Labs Group, S.L. (hereinafter, the manufacturer) is the owner of the device. During the period of validity of this study, the manufacturer will grant a license to use the device by the research team free of charge. The research team will be the administrator of the account. Both patients and members of the medical team will have login credentials. The manufacturer will not have access to the account or patient information.
According to the definitions and roles set out in Regulation (EU) 2016/679 (GDPR), the Data Controller is the research team and the manufacturer is the Data Processor.
The storage of data and photographs will be in line with the European Regulation 2016/679 (GDPR) and the Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights. At the end of the study, all information stored in the device will be totally and permanently deleted.
The device complies with current legislation on the protection and confidentiality of personal data European Regulation 2016/679 (GDPR). Appropriate technical and organizational security measures are adopted to ensure the security of personal data and prevent its alteration, loss, unauthorized processing or access, given the state of technology, the nature of the data and the risks to which they are exposed, whether from human action or the natural physical environment.
CIP Modification
As indicated in the UNE-EN ISO 14155:2021 standard, the Clinical Investigation Plan (CIP) may be modified as necessary during the clinical investigation. The changes made must be described, along with their justification, potential impact on clinical performance, efficacy, safety, or other evaluation criteria, and identification of other affected documents.
CIP modifications will be prepared by the sponsor and agreed upon and accepted between the sponsor and the principal investigator. The modifications will be recorded with a justification for each one in the form of an amendment or addendum.
The required regulatory authority (AEMPS) and the Ethics Committee or Institutional Review Board (IRB) will be notified, if necessary. Modifications to the clinical investigation may only be implemented once favourable feedback and the corresponding approval have been obtained.
In accordance with Article 75 of Regulation (EU) 2017/745, substantial modifications to the clinical investigation must be approved by both the Ethics Committee for investigation with medicines (CEIm) and the Competent Authority (AEMPS) prior to their implementation.
- In the case of substantial modifications to authorized clinical investigations, a request must be submitted to the AEMPS and the CEIm.
- For non-substantial modifications to authorized clinical investigations, until the corresponding module is available in the EUDAMED database, the updated documentation will be sent to the AEMPS for inclusion in their file.
Any substantial modification must be approved by both the Ethics Committee (CEIm) and the Competent Authority (AEMPS) before implementation, as required by Article 75 of MDR 2017/745.
CIP Deviations
As indicated in the UNE-EN ISO 14155:2021 standard, the investigator may not deviate from the Clinical Investigation Plan (CIP), except in emergencies (section 4.5.4.b of the standard). In such cases, the investigator may proceed without prior approval from the sponsor and the Ethics Committee to protect the rights, safety, and well-being of human subjects. The use of waivers from the Clinical Investigation Plan is strictly prohibited.
These deviations must be documented by the principal investigator and notified to the sponsor and the IRB as soon as possible, and always within a maximum of 15 days. Immediately after receiving the notification, the sponsor will record and analyze the deviations carried out and their potential impact. Depending on the findings, the sponsor will take the necessary corrective and/or preventive measures.
In other circumstances, when deviations affect the rights, safety, and well-being of the subject or the scientific integrity of the clinical investigation, deviation requests and reports must be provided to the IRB if required.
The use of waivers from the Clinical Investigation Plan is strictly prohibited. The sponsor will establish clear measures for tracking and managing any deviations from the CIP.
Start, follow-up and end reports
The start of the study will be notified to the ethics committee. Annual follow-up reports will be submitted thereafter.
The sponsor will comply with the obligation to notify Member States of the end, temporary halt, or early termination of the investigation within the legal timeframes (15 days for end, 24 hours for safety-related halts) as per Article 77 of MDR 2017/745.
Upon obtaining the study conclusions, a final report (T-015-006 Clinical Investigation Report (CIR)) will be prepared and submitted to the ethics committee. The study must be registered in a public database (e.g., EUDAMED), and the CIR will be published within 1 year of completion (or 3 months in case of early termination) as per Annex XV of MDR 2017/745.
Statements of compliance
The present clinical investigation will be conducted following the ethical principles originating from the Declaration of Helsinki.
Additionally, the clinical investigation will comply with the harmonized standard UNE-EN ISO 14155:2021 and the European Regulation MDR 2017/745. The statement specifying compliance with the general safety and performance requirements in accordance with MDR can be found in the document Manufacturer's Declaration of Compliance with Requirements.
As appropiate, clinical investigation will not commence until approval/favourable opinion has been obtained from the Clinical Research Ethics Committee (CREC) and the required regulatory authority (Spanish Agency for Medicines and Medical Devices, AEMPS), and it must comply with any additional requirements imposed by the CREC and/or AEMPS.
Informed Consent process
The patient, or in their absence, the family member or legally authorized representative, must provide written consent before their inclusion in the clinical investigation. This will occur after they have understood, through a prior interview with the principal investigator or a member of the research team, the objectives of the investigation, its risks, inconveniences, and benefits, as well as the conditions under which it will be conducted, and after being informed of their right to withdraw from the investigation at any time without explanation and without incurring any responsibility or prejudice.
The principal investigator will discuss the study with the subject and provide the information objectively, without coercion or influence, and without offering any inappropriate or undue incentive. The principal investigator will use non-technical language in the subject's native language (or that of the spouse/closest relative or legally authorized representative) for better understanding and will allow sufficient time for reading and comprehending the information.
Each participant will document their informed consent by signing and dating the informed consent form. Each signed and dated consent will be kept by the principal investigator, and a copy of the informed consent will be provided to the subject.
If new important information arises that could affect the subject's willingness to continue participating in the clinical investigation, it will be provided in any case. If necessary, their continued informed consent will be confirmed in writing.
Adverse events, adverse product reactions and product deficiencies
Adverse Events (AE) and Adverse Event to Product (AEP)
An AE is any unintended medical event, unanticipated illness or injury, or unintended clinical signs (including abnormal laboratory findings) in subjects, users, or other persons, whether or not related to the investigational product and whether intended or unintended.
A AEP is an adverse event related to the use of an investigational medical device.
Given these definitions, potential AEPs or AEs are documented in the product's IFU.
Product deficencies
Possible inadequacies of a medical device may relate to its identity, quality, durability, reliability, safety, or performance.
Considering this definition, the following issues could arise:
- Malfunctions, such as application crashes or failure to process images.
- Use errors, such as capturing poor quality photographs or incorrect data entry.
- Inadequate information provided by the manufacturer, such as a complex IFU and/or labeling.
Product deficiencies in the investigation will be managed by the sponsor according to non-conforming product control procedures. When appropriate, corrective and/or preventive actions will be taken to protect the safety of subjects, users, and other individuals.
Serious Adverse Events, serios adverse events to product and serious and unexpected adverse event to the product
According to UNE-EN ISO 14155:2021:
- A Serious Adverse Product Reaction (SAEP) is a SAE that has produced any consequence characteristic of a serious adverse event.
- A Serious Adverse Event (SAE) is an AE that resulted in any of the following events: death, serious deterioration of the health status of the subject, users or other persons, or fetal distress, fetal death, congenital anomaly or birth defect.
- A Serious Unexpected Adverse Event to the Product (SUAEP) is a SAE that, due to its nature, incidence, intensity or consequences, has not been identified in the updated risk assessment.
Taking into account these definitions, there are no SAEP, SAEs or SUAEPs related to the use of the product.
Non-reportable Adverse Events
List non-reportable adverse events, if applicable, including justification.
Incidents related to the patient's underlying disease will not be reported. Incidents such as falls will also not be reported, as they are considered irrelevant to the study's objectives.
Notification Process
Any SAEP, product deficiency or finding related to the above will be duly documented and reported in accordance with the provisions of document MDCG 2020-10/1 “Safety reporting in clinical investigations of medical devices under the Regulation (EU) 2017/745”
In the situations detailed in the previous paragraph, the principal investigator must notify the sponsor immediately (but no later than 3 days after becoming aware of the event). The sponsor will then use the form published as an annex to said document, MDCG 2020-10/2 “Guidance safety report form”.
This form must be completed or updated for each reportable event or for new findings or updates of events already reported. It will be transmitted to all National Competent Authorities (NCA) where the clinical investigation is being conducted. In this case, the AEMPS. Once EUDAMED is available and fully operational, the obligations and requirements related to the preparation of safety reports through EUDAMED will apply from six months after the date of publication of the notice in the Official Journal of the European Union.
The notification period of the sponsor to the NCA(s) will be immediately (but no later than 2 days after becoming aware of the event) for reportable events that involve an imminent risk of death, serious injury or serious illness and that require immediate corrective action, or new findings or updates of related events. For the rest of reportable events or new findings or updates, the notification period will be immediately (but no later than 7 days after becoming aware of the event).
Likewise, as indicated in the UNE-EN ISO 14155:2021 regulation, the IRB must be notified of the SAEs, if the IRB so requires.
Foreseeable adverse events and adverse events to product
The foreseeable adverse events and expected adverse reactions to the product, as well as their incidence, mitigation and treatment are documented in the T-013-002 Risk management record of the product under study.
Vulnerable population (if applicable)
[To be determined]
Suspension or early termination of clinical research
As indicated in the UNE-EN ISO 14155:2021 regulation, the sponsor may suspend or terminate the clinical research early for significant and documented reasons. These are:
- If during the clinical research the suspicion of an unacceptable risk arises, including a serious threat to the health of the subjects. It must be suspended while the risk is determined.
- If an unacceptable risk that cannot be controlled is confirmed.
- Due to the impossibility of including a minimum number of subjects that allows the final assessment of the study within a reasonable period according to the characteristics of the study.
- When instructed by the IRB or the required regulatory authority (AEMPS).
- Due to non-compliance with the obligations assumed in the contract by any of the contracting parties.
- By mutual agreement between the parties, expressed in writing.
- By the will of one of the parties, expressed in writing at least one month in advance.
In the event of a suspension or early termination of the clinical research, the sponsor will inform the AEMPS. The sponsor must provide the resources to comply with the obligations of the CIP and with the existing agreements. The principal investigator must inform the subjects if so stipulated in the agreement between the sponsor and the research centre.
If the clinical investigation is resumed, the sponsor must inform the principal investigator and, where appropriate, the AEMPS. Approval from the IRB and, where appropriate, from the AEMPS will be required for such resumption. The principal investigator must inform the subjects.
In accordance with Article 77 of Regulation (EU) 2017/745, the sponsor must notify the Member States in which the clinical investigation is being conducted of the end of the clinical investigation, its temporary halt, or its early termination, within the deadlines specified by the regulation (within 15 days of the end, or within 24 hours in case of early termination or temporary halt for safety reasons). This notification must be accompanied by a justification in case of early termination or temporary halt.
Publication policy
Statement indicating the conditions and time periods in which the results of the clinical research will be offered for publication, including the role played by the sponsor and the criteria for authorship of the publication.
The description of the clinical research will be recorded in a publicly accessible database before the recruitment of the first subject. Its content will be updated during the conduct of the clinical research.
After the final closure of the clinical research, a Clinical Investigation Report (CIR: T-015-006 Clinical Investigation Report (CIR)) After the final closure of the clinical research, a Clinical Investigation Report, even if it has been suspended or terminated early. The CIR will be provided to the IRB and the AEMPS. The results obtained (positive, inconclusive or negative) will be incorporated into the registry of the aforementioned publicly accessible database.
In addition, if deemed appropriate, the results obtained will be published in scientific journals. The CEIC that has approved this clinical research will be mentioned, and the funds obtained by the author for or for its conduct and the source of funding will be stated. The anonymity of the subjects participating in the clinical research will be maintained at all times.
After the completion of the study, the results of the clinical utility and satisfaction surveys carried out according to the model in Annex I may be communicated at congresses and scientific meetings with prior authorization from both parties. Communications and press releases may also be made to communicate the results of the study. All publications and communications must be accepted and approved by the parties involved.
Bibliography
[To be determined]
Annexes
Annex I. Clinical Utility and Satisfaction questionnaire
Signature meaning
The signatures for the approval process of this document can be found in the verified commits at the repository for the QMS. As a reference, the team members who are expected to participate in this document and their roles in the approval process, as defined in Annex I Responsibility Matrix of the GP-001, are:
- Author: Team members involved
- Reviewer: JD-003 Design & Development Manager, JD-004 Quality Manager & PRRC
- Approver: JD-001 General Manager