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Privacy Policy
This notice is effective as of 14 March 2001
PPD is committed to respecting the privacy of individuals. We recognize that
when you choose to provide us with information about yourself, you trust PPD
to act in a responsible manner. PPD has enacted internal procedures to repeatedly
review and monitor the use of this information to ensure it is used responsibly
and complies with internationally recognized standards of privacy protection.
Such international standards include but are not limited to the European Union
Data Protection Directive [EC/95/46] and the U.S. Department of Commerce Safe
Harbor Agreement. Internationally recognized standards require that the processing
of personal data, both automated and manual, meet the following data protection
principles:
- Data has fair and lawful processing
- Data is obtained only for specified and lawful purposes and is not processed
in any incompatible manner
- Data use is adequate and relevant but not excessive
- Data is kept current (where necessary) and accurate
- Data is not kept longer than necessary
- Data processing is in accordance with the rights of data subjects
- Data is protected by appropriate security measures
- Data is not transferred to third parties unless
adequate level of data protection exists
Purposes of Data Processing
PPD processes personal data for specific and limited purposes, which we inform
you about when we request information from you. Examples of different purposes
include, but are not limited to:
- Investigator data processed to allow PPD to identify and contact individual
investigators to ascertain their interest in participating in clinical trials
in accordance with their experience and specialty. Investigators selected
to conduct clinical trials may also be required to provide additional information
to allow for appropriate reimbursement for their participation.
- Individual subject data processed for participation in certain clinical
trials (studies conducted in PPD Phase I clinics), and in some instances,
in order to assist in patient recruitment.
- Applicant and employee data processed to enable accurate records to be maintained
on all applicants and employees documenting information for government reporting
requirements, performance, payroll and other items.
Prior to processing personal data, PPD will provide notice to data subjects in
a clear and conspicuous language. Dependent on the type of data processing, notice
maybe given in person, by e-mail, post, telephone or by posting on our Web site.
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Data Collection
PPD may collect information on its Web pages for reasons such as processing
newsletter requests, job applications processing and providing investor information.
Categories of collected information (if provided by you) include contact information,
company information and job search/application information. For example, name
address, phone number, e-mail address, company name, position, resume, desired
compensation and/or "cookie" information may be collected
to process your request.
Every effort is made to ensure that the information is accurate and up-to-date
and all communications with individuals provide easy means of validating, correcting
errors and updating information.
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Data Processing
All processing of personal data is, by consent, for the purposes listed above
and under the control of the data controller. Individuals have the right to:
- Obtain copies of their data
- Correct their data
- Prevent processing for direct marketing
- Withdraw consent to processing with its consequential effects
- Prevent non-core purpose disclosures
- Prevent trans-border disclosures to third parties where there are inadequate
data protection arrangements.
To access personal information held and request corrections, amendments and/or
delete that information where it is inaccurate, please refer to the "Inquiries,
Complaints and Subject Access Requests" section of this policy.
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Data Security
PPD maintains a high level of security, particularly in relation to data.
Computer equipment, networks, programs, data and documentation is maintained to
a high standard, and access to data and equipment is at all times restricted to
appropriate staff.
The handling of medical information obtained in clinical research is governed
by national and international data protection regulations and medical confidentiality.
Any medical information collected will be maintained under these regulations.
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Release, Sharing or Transference of Data
The information you provide to us will be available to PPD, Inc., its subsidiaries
and companies working as agents of PPD. Access to data and equipment is at all
times restricted to appropriate staff. PPD will not trade, sell, release, share
or transfer your personal information for use by any business outside the PPD
organization without your consent, or in a form other than what was disclosed
to you at the time the information is collected, unless permitted or required
by law.
Under some circumstances PPD may be required by law enforcement or judicial
authorities to provide personal information as required by law to the appropriate
government authorities.
Companies working as agents of PPD or clinical trial sponsors (such as pharmaceutical
companies) are required to sign confidentiality agreements or provide assurance
agreeing to handle all confidential information containing personal data in
accordance with applicable law, including but not limited to, the European Data
Protection Directive [EC/95/46].
PPD is a global company and has information databases in different offices
throughout the world. PPD may transfer your data to one of its databases outside
your country of domicile. If the level of privacy protection in a country
does not comply with recognized international standards, PPD will ensure that
data transfers to PPD databases in that country are adequately protected.
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Links to Third Party Web Sites
Some of our Web pages may contain links to Web sites outside of the PPD,
Inc. organization. Linked Web sites are not under the control of or endorsed
by PPD. This policy does not apply to linked Web sites outside the PPD organization.
It is recommended that you review the privacy policy of each individually
linked Web site that you choose to visit.
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Cookies
A cookie is a piece of data stored on the hard drive of your computer. PPD
enables temporary cookies (a.k.a. session-only cookies) to allow site visitors
to easily move from one interactive feature to another, offering visitors a
better experience while navigating the PPD corporate Internet site. However,
use of a cookie does not link to or reveal personally identifiable information
while on our site, unless you explicitly provide that information to us. Furthermore,
the cookie will automatically expire after a short period of time and will automatically
be removed completely when the Web browser is closed.
Cookies can also enable us to track and target your interests to enhance the
experience on our site. They are used to create a profile and can be used for
such purposes as notifying you of relevant trade shows or symposia, but only
if you opt-in to this feature. Visitors will always be given the choice and
the information will not be sold to other organizations.
We receive IP addresses in the normal course of the operation of our Web site.
An IP address is a number assigned to you by your Internet service provider
so you can access the Internet. We do not use them to personally identify
you or disclose them to others.
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Children's Online Privacy Protection
PPD does not collect or maintain information from our Web site from individuals
we actually know are under the age of 13, and no part of our Web site is structured
to attract anyone under 13 years.
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Training
PPD has provided its employees with appropriate training to ensure that
all those who process personal data are fully aware of their individual responsibilities
and of management's objectives with respect to data protection.
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Inquiries, Complaints and Subject Access Requests
All communications, queries and subject access requests related to data
protection issues, should be addressed to
Attention: Data Privacy Officer
PPD, Inc.
929 North Front Street
Wilmington, NC 28401-3331
U.S.
You may also submit an electronic
request for action or response on behalf of PPD. Using reasonable efforts,
PPD will promptly respond to any communications regarding our use of personal
information. For unresolved disputes between PPD and complainants, PPD has agreed
to co-operate with the European Data Protection Authorities (DPAs) dispute resolution
procedures. In addition, specific PPD Internet (external) and Intranet (internal)
Web pages enable you to access and update your profile or other personal information
online or provide further instruction on how individuals may obtain copies and
update their data via various department resources. Examples would be:
- Investigators entering and maintaining profiles via the PPD Web site,
and
- Employees wishing to obtain and update their personal training records
through the PPD Global Learning and Performance department's Intranet page.
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Privacy Policy Changes
PPD reserves the right to modify or amend this privacy policy. For instance,
this privacy policy may need to change as new legislation is introduced or as
it is amended. Changes to PPD's privacy policy will be posted on this Web site.
We recommend that you review this policy from time to time.
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