Our Commitment to Privacy
WCCT Global, Inc.
WCCT and its subsidiaries, Medelis, Inc., and clinCORE, have determined that the protection of personal information is critical for our company and our clients. Accordingly, this policy has been designed and adopted effective April 12, 2017 to implement a consistent and comprehensive policy on the protection of personal information.
The Company’s EU-US Privacy Shield and Swiss-US Privacy Shield sets forth the privacy principles that it has committed to follow with respect to transfers of personal information from the European Union and Switzerland to the United States. WCCT adheres to the Privacy Shield Principles in connection with the transfer of all personal data from the EU and Switzerland to the US. The Company understands the importance of protecting information of all kinds, especially individual personal information.
This Policy applies to all personal information, either in electronic or paper format, received by WCCT in the United States from the EU.
For purposes of this Policy, the following definitions shall apply:
“Agent” means any third party that uses personal information provided to it by WCCT to perform tasks on behalf of and under the instructions of WCCT.
“WCCT” means WCCT Global, Inc., its successors, subsidiaries, divisions and groups in the United States.
“Personal Data” or “Personal information” are data about an identified or identifiable individual that are within the scope of the Directive, received by WCCT in the United States from the European Union, and recorded in any form.
“Processing” of personal data means any operation or set of operations which is performed upon personal data, whether or not by automated means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure or dissemination, and erasure or destruction.
“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of personal data.
PRIVACY SHIELD PRINCIPLES
WCCT adheres to the following EU-US and Swiss-US Privacy Shield Principles:
This notice must be provided in clear and conspicuous language when individuals are first asked to provide personal information to WCCT or as soon thereafter as is practicable, but in any event before WCCT uses such information for a purpose other than that for which it was originally collected or processed by the transferring organization or discloses it for the first time to a third party.
The personal data or personal information collected by WCCT or Agents of WCCT (that WCCT is under contract with) is intended for clinical research use. This information will only be collected if you consent to studies managed by WCCT. Your express permission for WCCT or its Agents to use sensitive personal information (such as medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual) is included in the consenting process of the clinical trials that we manage. You have the choice at any time before, during, or after the study to discontinue such consent via written notice, which would render your data ineligible for use (unless study reports have already been created with the consenting data). Your personal data or personal information will not be used for anything except the clinical trials that you provided consent to participate in.
ACCOUNTABILITY FOR ONWARD TRANSFER
WCCT may be liable for the onward transfer of the personal data of EU and/or Swiss individuals.
WCCT, or Agents that WCCT contracts with (and acts as Controller, if applicable), maintains consistent security of personal data or personal information provided by individuals consenting to have their data/information used in specific clinical trial research studies. The systems that hold this data during and after clinical trial research are routinely audited to ensure that data/information stored remains secure. Any unauthorized access, disclosure, alteration or destruction of personal data or personal information is immediately investigated, all applicable parties notified, and a Corrective Action Plan is set forth to ensure that security continues to provide the highest level of protection of patient personal information. For EU countries that do not permit initials, dates of birth, etc., such information would be included in any plans for the clinical trial and would not be entered into the data system (and therefore transferred from the EU to the US). Permitted personal data or personal information will be input into data system and transferred securely as necessary in order to facilitate the clinical trial being managed by WCCT.
DATA INTEGRITY AND PURPOSE LIMITATION
Personal information collected after a patient has consented to a specific clinical trial will only be used for that specific clinical trial, for the duration of time during and after the study that the information is necessary to maintain. WCCT will not process personal information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual. WCCT will adhere to the Principles for as long as it retains such information.
An individual has the right to correct, amend, or delete personal information where it is inaccurate, or has been processed in violation of the Principles, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated. While individuals will not have direct access to the data systems that WCCT or Agents of WCCT house such personal information on, a patient can either contact WCCT directly or the physician that consented them during the process to provide updates to their personal information as necessary. As long as the information is retained by WCCT or its Agents, the applicable organizations will make the requisite changes as instructed by the individuals whose data requires updating, as long as such changes do not affect the overall results of the ongoing or completed clinical trial of the pharmaceutical company for whom WCCT manages its trial(s). For example, an individual has the right to correct, amend, or delete personal information where inaccurate, but does not have the right to correct, amend, or delete any data relating to the compound or device that the individual consented to using/obtaining/testing.
RECOURSE, ENFORCEMENT, AND LIABILITY
WCCT is subject to the jurisdiction and enforcement authority of the US Federal Trade Commission (FTC). If WCCT becomes subject to a Federal Trade Commission (FTC) order or court order based on noncompliance, WCCT shall make public any relevant Privacy Shield related sections of any compliance or assessment report submitted to the FTC, to the extent consistent with confidentiality requirements. The FTC will give priority consideration to referrals of non-compliance with the Principles from the Department and EU Member State authorities, and will exchange information regarding referrals with the referring state authorities on a timely basis, subject to existing confidentiality restrictions.
TYPES OF DATA COLLECTED
WCCT, or Agents of the organization, collect personal data or personal information for the purpose of managing clinical research trials for pharmaceutical companies in the United States, Europe (including the European Union and Switzerland), and other countries across the world. Personal data types may include: individual’s full name, address, phone number, medical or health conditions, racial or ethnic origin, or information specifying the sex life of the individual.
CONTACT INFORMATION FOR PRIVACY SHIELD INQUIRIES OR COMPLAINTS
Any inquiries or complaints regarding WCCT, or Agents of the organization, violating the Principles of the EU-US Privacy Shield or Swiss-US Privacy Shield Framework should contact firstname.lastname@example.org. Once verified, a response to your inquiry or complaint will be sent within 10 business days by an authorized representative of WCCT.
WCCT DISCLOSING PERSONAL INFORMATION TO AGENT(S)
In order to conduct the management of clinical trial research, WCCT may contract with Agent(s) to complete the services on behalf of pharmaceutical companies with which WCCT is contracted. These parties can include: advertisers, vendors, or contractors. The purpose of sharing personal information with these Agent(s) is to facilitate clinical trial research on behalf of the pharmaceutical companies with which WCCT is contracted. These Agent(s) provide a service necessary to clinical trial research projects that we are contracted to manage, and thus need to share personal information with these Agent(s) in order to complete work for ongoing projects.
PERSONAL DATA PROTECTION
WCCT, or Agents of the organization, take the protection of personal data or personal information for individuals participating in clinical trial research very seriously. WCCT (or Agent(s)) ensure that all employees with access to this information are properly trained under company Standard Operating Procedures (SOPs) to protect such data/information, ensuring the safekeeping of such information. The systems in which personal data or personal information is stored are subject to Quality Audits, ensuring that this data is continually protected and maintained appropriately. Employees with access to personal data and personal information are also subject to Quality Audits to ensure their training maintains the high standards set forth in this policy.
EU-US, SWISS-US PRIVACY SHIELD AFFIRMATIVE COMMITMENTS, INDEPENDENT DISPUTE RESOLUTION MECHANISM
WCCT has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Under certain conditions, EU and Swiss individuals can invoke binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission. This binding arbitration is through a Privacy Shield Panel, which is an arbitration mechanism made up of three arbitrators. This panel settles disputes out of court and its decisions are binding in U.S. courts. Should WCCT or the BBB fail to resolve your complaint, you will need to formally notify WCCT of your intent to invoke binding arbitration and include a summary of steps already taken to try and resolve your complaint, as well as description of the alleged violation. Such arbitration procedures are resolved within 90 days of formal notice to WCCT. If the result of the outcome during arbitration is unsatisfactory, you have the option to challenge it under U.S. law under the Federal Arbitration Act.
ENFORCEMENT AUTHORITY, LIMITED LIABILITY STATEMENTS
The FTC has enforcement authority jurisdiction over the EU-US Privacy Shield and Swiss-US Privacy Shield Frameworks. Under certain conditions, WCCT may be required to disclose personal information in response to a lawful request by public authorities, including the FTC, to meet national security or law enforcement requirements. In such cases where WCCT is required to disclose personal information in response to a request by a governmental authority, WCCT will strive to limit such personal information to the least amount of information as possible to remain in legal compliance with such disclosure and will disclose the information in accordance with the terms of this policy, as applicable.
Our Commitment to Privacy
This website located at www.WCCT.com and related web pages (collectively, the “website”) is provided by WCCT Global, Inc., and its affiliates (collectively sometimes referred to as “we,” “us” or the “Company”). The term “you” refers to the customer visiting the website and/or contributing content on this website.
We do not sell or rent personally identifying information collected during your use of our website without your permission.
The Information We Collect
Personal Identification Information. We may collect personal identification information from you in a variety of ways, including, but not limited to, when you visit our website, register on the website, subscribe to the newsletter, fill out a form, and in connection with other activities, services, features or resources we make available on our website. If you avail yourself of some of these features in our website, you may be asked for, as appropriate, name, email address, mailing address, phone number, credit card information and other similar personal identification information. If you choose, however, you may visit our website anonymously. We will collect personal identification information from you only if you voluntarily submit such information to us. You can always refuse to supply personal identification information; however, such refusal may prevent you from engaging in certain website-related activities. The personal identification information we collect is categorized as follows:
(a) Application or Registration Information – This is information that you provide to us through our website and through other means. Examples include your physical address, zip code, email address and phone number.
(b) Transaction and Experience Information – This is information about your transactions with us, as well as information about our communications with you. Examples include your account history, subscriptions to our newsletter, requests for information and our responses.
(c) Information from Outside Sources – This is information we may collect from time to time from outside sources regarding your credit, background and other relationships. Examples include your employment history and public record information.
We may also share the information we collect about you with third parties from one or more of the following categories: (i) other service or goods providers, (ii) credit card companies, (iii) banks and (iv) governmental agencies. If you obtain goods or services provided by one of our partners or service providers, we may exchange with the vendor personally identifying information about you for purposes of your transaction.
Non-Personal Identification Information. In addition, we automatically gather general statistical information about our website and visitors, such as IP addresses, browsers, pages viewed, number of visitors, goods and services purchased, etc., but in doing so, we do not reference you by individual name, email address, home address or telephone number. We use this data in the aggregate to determine how much our customers use parts of our website so we can improve our website. We may provide this statistical information to third parties, but when we do so we do not provide personally identifying information without your permission.
The Way We Use Information
We use your personally identifying information as follows:
(a) To improve our marketing and promotional efforts, to statistically analyze website usage, to improve our content, service, and product offerings, and to customize our website’s content, layout and services.
(b) We may use your information to deliver information to you that, in some cases, is targeted to your interests, such as targeted banners, new services and promotions. We may ask you to provide us voluntarily with additional information regarding your interests, experience or requests, which we may use to customize our service for you.
(c) We use your email address, mailing address and phone number to contact you regarding administrative notices, new product or service offerings, and communications relevant to your use of the website.
(e) We use your IP address to help diagnose problems with our server, to manage our website and to enhance our website based on the usage pattern data we receive.
(f) If you place a request for products or services we may offer from time to time, either through the Company or through our service and product vendors and partners, we may use information to ship your order, and we may provide your relevant information to that vendor or partner for purposes of the transaction. If you establish a credit account with us or our providers, we collect additional information, including billing information, credit card number and expiration date, and tracking information from checks or money orders.
We employ reasonable and current security methods to prevent unauthorized access, maintain data accuracy and ensure correct use of information. If you sign up as a registered user on our website, your account information and profile are password-protected. We recommend that you do not divulge your password to anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited email. Remember to sign out of your account and close your browser window when you have finished your session. This is to help ensure that others cannot access your personal information and correspondence if you share a computer with someone else or are using a computer in a public place where others may have access to it. Whenever you voluntarily disclose personal information online (for example, on message boards, through email or in chat areas), that information can be collected and used by others. No data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect your personal information, we cannot ensure or guarantee the security of any information you transmit to us, and you do so at your own risk.
How You Can Update, Correct or Delete Your Information
You can access the information that we collect online and maintain through normal updating methods. To update, correct or delete this information, you can contact mgr@WCCT.com. Your account can be deleted or deactivated, but doing so will result in your not being able to access member services.
Children Under 13
Changes to Our Policy
By using our website, you consent to the collection and use of this information in the manner we describe.
If you have any questions about this Policy, the practices of this website or your dealings with this website, please contact us at:
3545 Howard Way, Costa Mesa, CA 92626
This document was last updated on March 22, 2017.