Privacy Policy
Effective Date: 01 December 2022
1. Cliniverse's Approach to Privacy
Clinical and medical research are founded upon the collection and analysis of the most confidential information about people. Individuals will only share their sensitive information where there is a culture of trust and where stakeholders implement safe data handling practices. Cliniverse is committed to safeguarding your privacy. Cliniverse has enacted internal policies, procedures, and training programs designed to support compliance with these laws and this Notice. Our policies, procedures and training programs are reviewed on a regular basis and managed by a team of qualified professionals with executive oversight.
The Policy explains in general terms how we seek to comply with data privacy laws and regulations, including but not limited to General Data Protection Regulation 2016/679 (“Regulation”), the US Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), state security breach laws in the United States, data protection legislation adopted by increasing numbers of other jurisdictions globally, and the privacy and confidentiality requirements of ICH Good Clinical Practice (GCP).
2. Definitions
“Data Subject” – The person whose personal information is being held or processed by Cliniverse for the purpose of managing clinical trials or contacting individuals about future clinical trial opportunities.
“Personal Data” – Information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier – e.g. name, unique identifier, contact details and/or email address. It does not include information about organizations, companies and agencies but includes information relating to identified or identifiable individuals such as individual volunteers or employees within an organization, company, or agency.
“Sponsor” third party entity financing or organizing the clinical trial.
3. What Types of Personal Information Does Cliniverse Handle and How Do We Use It?
Cliniverse collects the following types of personally identifiable information (“Personal Information”) through our websites including but not limited to: name, title, contact details, including email address and telephone numbers provided by you.
Health Professional Information
Cliniverse analyzes the professional profiles of doctors and other health care providers for the purpose of identifying potential investigators to assist in clinical and medical research on specific indications. Cliniverse will use available contact information, including email addresses, for the purpose of inviting potential investigators to apply to participate in research. Cliniverse will source health professional information from its own databases and also indirectly from public sources, data brokers, and referrals. For operational purposes, Cliniverse will also collect information relating to the involvement and performance of investigators and supporting study staff. Cliniverse will also process financial information of investigators to support payment for services.
Industry Professional Information
In the course of conducting our business, Cliniverse will interact with employees, consultants, contractors and other third parties employed or engaged by our Sponsors involved in clinical and medical research. Cliniverse will record and use the names, contact details and other professional information on these individuals for legitimate business-related purposes, including project and financial administration. We may use the information we obtain, including email addresses, to provide relevant information on Clinverse’s services to our Sponsors.
Employee and Human Resource Data
Cliniverse e-collects personal information from applicants seeking employment with the company, including private contact details, professional qualifications and previous employment history to inform employment decisions. Cliniverse conducts various background checks on applicants, including where law allows on criminal history and professional disbarment. Once employed, Cliniverse collects information on staff for human resource, performance, payroll and tax purposes. Cliniverse will collect and record employee level information in various company systems, consistent with standard business operations. Cliniverse processes similar information relating to consultants, contractors and other third parties engaged by the company to provide products or services to it.
Web Visitors
Cliniverse collects named information about visitors to company websites where this is voluntarily provided to meet a request from those individuals, for example where a client contact requests information on a company service, a health professional is interested in participating in a clinical trial or where someone wants to apply for a vacant position with the company.
4. Internal and External Disclosures of Personal Information
Personal information will be shared within Cliniverse and its affiliated companies and with third parties, including our agents and service providers, on a “need to know” basis to meet stated legitimate business purposes. Access to databases and folders containing personal information is restricted to appropriate staff. Cliniverse does not trade or sell personal information.
Under some circumstances, Cliniverse may be required by law enforcement or judicial authorities to disclose certain personal information as part of investigations or for litigation purposes. Cliniverse may disclose personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of Cliniverse or some or all of its assets.
Companies working as vendors of Cliniverse are required to sign “processor” and/or confidentiality agreements whereby they will commit to only process personal information consistent with contracted purposes and apply appropriate organizational and technical security safeguards.
4. Internal and External Disclosures of Personal Information
Personal information will be shared within Cliniverse and its affiliated companies and with third parties, including our agents and service providers, on a “need to know” basis to meet stated legitimate business purposes. Access to databases and folders containing personal information is restricted to appropriate staff. Cliniverse does not trade or sell personal information.
Under some circumstances, Cliniverse may be required by law enforcement or judicial authorities to disclose certain personal information as part of investigations or for litigation purposes. Cliniverse may disclose personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of Cliniverse or some or all of its assets.
Companies working as vendors of Cliniverse are required to sign “processor” and/or confidentiality agreements whereby they will commit to only process personal information consistent with contracted purposes and apply appropriate organizational and technical security safeguards.
5. Wil Cliniverse Share Personal Data It Receives?
Internal and External Disclosures of Personal Data
Personal Data about our users is an integral part of Cliniverse’s business. Personal Data will be shared within CLINIVERSE, companies working as agents of Cliniverse, and third parties only on a “need to know” basis to meet stated legitimate business purposes. Cliniverse does not trade or sell Personal Data.
Agents and Service Providers
We contract with other companies and people to perform tasks on our behalf and may share your Personal Data with them to provide products or services to you, or to otherwise communicate with you. Examples may include removing repetitive information from customer lists, analyzing data, conducting billing, processing credit card payments, engaging technical support for our services, providing customer service, and performing analyses related to our products or services. We may also provide your Personal Data to agents and service providers to verify or compile aggregate usage data that we provide to our business partners. When we share this information in this way, we contractually require the agent or service provider to maintain the privacy, confidentiality and security of the Personal Data.
Protection of Cliniverse and Others
Under some circumstances, Cliniverse may be required to disclose your Personal Data (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates, and (f) as part of investigations or for litigation purposes.
Companies working as vendors of Cliniverse are required to sign data protection and/or confidentiality agreements whereby they will commit to only process Personal Data consistent with contracted purposes and apply appropriate organizational and technical security safeguards.
Databases
Access to databases and folders containing Personal Data is restricted to appropriate employees, agents, consultants, and service providers with whom CLINIVERSE contractually requires maintaining the privacy, confidentiality and security of the Personal Data.
6. Data Quality and Record Retention
Data quality and accuracy are fundamentally important principles to Cliniverse. Crucial to the integrity of clinical research is the accuracy of data relating to Data Subjects. Consistent with regulatory requirements, Cliniverse employs a professional quality assurance department. In general, our privacy notices provide individuals easy means of validating, correcting errors and updating information. Cliniverse retains Personal Data in accordance with contractual, legal and regulatory requirements.
7. Information Security
We have implemented organizational, technical, and administrative measures in an effort to protect Personal Data within our organization, including security controls that are intended to prevent unauthorized access to our systems, including standard operating procedures, firewalls and restricted access. While we take these reasonable steps to secure your Personal Data from loss, misuse, interference and unauthorized access, modification and disclosure, you should be aware no security procedures or protocols are ever guaranteed to be 100 percent secure from intrusion or hacking, and there is therefore always some risk to sharing Personal Data online.
8. Legal Status of Notice and Notice Changes
This Notice is not a contract, and it does not create any legal rights or obligations. Cliniverse reserves the right to modify or amend this Notice. For instance, the Notice may need to change as new legislation is introduced or as it is amended.
Cliniverse will regularly assess and evaluate its methods and performance in relation to handling Personal Data. This Notice will be updated as necessary to reflect best practice in data management, security and control.
9. Questions, Concerns, or Complaints
Your privacy is important to us. If you have any questions, concerns, or complaints regarding the way we collect and handle your information, please contact us by email at mary@cliniverseresearch.com.