What we Collect
We may collect “Personal Information” about you in a variety of ways. The information we may collect can include:
- Any information that is directly or indirectly referable to an identifiable individual when used on its own or when combined with other information and that is protected by applicable privacy legislation. It includes factual or subjective information, recorded or not. Such information may include business contact information (which includes but is not limited to name, title, contact information, work experience, qualifications, publications, résumé, educational background, performance information, facilities, staff capabilities, and other similar information in relation to your employment or profession), any assigned identifying number or symbol, private or confidential correspondence sent to a government institution, as the case may be.
- Survey Data: If you choose to participate in one of our surveys or research initiatives, we collect your answers and use the information and survey results to help us understand our clients and/or business partners and tailor our service offerings.
- Derivative/Browsing data: Information our server automatically collects when you access our website, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the website.
- Career Data: If you apply for employment with Scimega, we will collect the employment information you submit, including name, contact information, and résumé.
Why we Collect
We collect Personal Information related to the performance of our activities to ensure proper conduct of our clinical trials in accordance with the services we provide to our clients and in accordance with the standards of good clinical practices and regulatory authorities’ requirements.
We also collect Personal Information for administrative and commercial purposes including disclosure to Sponsor/Scimega representatives for the purposes of trial management (i.e. auditing and monitoring a study) as well as for the identification of investigators for the conduct of further trials or any other future project for which Sponsor/Scimega would request to collaborate with healthcare professionals in specific specialties (such as advisory boards or other scientific meetings).
Other reasons for collection of Personal Information would include certain internal processing purposes for our clients, investigative sites and Regulatory Authorities. Disclosures of such Personal Information would include its transfer to certain regulatory agencies and to clients, in accordance to our respective agreements with them, you and/or your organization and applicable law.
Personal information (such as name and site location) may be included in results information of some clinical trials we are conducting. The Food and Drug Administration Amendments Act of 2007 (FDAAA) requires that the “Responsible Party” for certain clinical trials register with, and submit the results information of some trials to, the ClinicalTrials.gov databank (www.ClinicalTrials.gov).
Data Protection Officer
Scimega Research has designated a Data Protection Officer, as required by the Canadian Personal Information Protection and Electronic Documents Act, Schedule 1 – Principles Set Out in the National Standard of Canada Entitled Model Code for the Protection of Personal Information, CAN/CSAQ830- 96, subsection 4.1 Principle 1 – Accountability’s. Scimega’s CEO holds the responsibility of the Data Protection Officer.
Should anyone at Scimega become aware of a potential or actual privacy breach, the Data Protection Officer will be notified as soon as possible, within 24 hours. The concerned parties will be notified of the breach and of the action we have taken. Scimega employees are to follow Scimega’s internal CAPA process for any privacy incident they are aware of.
How we Collect Information
Scimega only collects Personal Information from consenting individual and partners (clients, investigative site personnel, vendors) in relation to our business activities. When the other party voluntarily submits Personal Information to Scimega, this party freely consents to sharing this information with Scimega and the Personal Information collected will be governed by this Policy.
Scimega is committed to protecting the privacy of individuals who visit our website, our partners, clients and our employees. Scimega does not collect, trade, sell, release, share or transfer your Personal Information for use by any business outside the Scimega organization without your consent, or in a form other than what was disclosed to you at the time the information was collected, unless permitted or required by law.
Scimega does not hold or manage a transactional website. When you visit Scimega’s website to request or to access information, you may be asked to provide Personal Information. By providing your Personal Information to Scimega via its website, you agree to the terms of this Policy and to receive communications from Scimega
The following statements discloses the information gathering and dissemination practices for our website:
- We use your IP address to help diagnose problems with our server and to administer our website.
- We use IP addresses to analyze trends, administer the site, track users’ movements, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.
- We do not share any Personal Information with any third parties nor do we use any Personal Information for other purposes than to provide the request information or requested technical support to our clients or visitors on our website.
- This site may contain links to other sites. Scimega Research is not responsible for the privacy practices or the content of such websites.
- This site has security measures in place to protect the loss, misuse, and alteration of the information under our control.
- Scimega is the sole owner of the information collected on our website.
Removal of Consent:
If you provide us with your Personal Information, you have the rights to request how your Personal Information is handled and retained at Scimega; to review the Personal Information that you have supplied to us; to correct any errors or update information regarding this Information. You also have the right to request that Scimega removes your Personal Information from our records or to opt out from any further communication by Scimega.
Should you receive any marketing communications, you may unsubscribe by clicking on the “unsubscribe” link located on the bottom of our e-mails, or by contacting us directly as detailed below. Clients cannot opt out of receiving transactional emails related to their account with us.
You can also at any time contact Scimega’s Data Protection Officer for any question about your rights with respect to this Policy.
To exercise any of these rights, please contact us at firstname.lastname@example.org or by mail to Scimega Research, 3055 Blvd Saint-Martin West, Suite T500, office 5123, Laval, Quebec, H7T 0J3 Attention: Data Protection Officer. We will respond to your requests regarding changes to, correction or deletion of your Personal Information or service changes promptly, but in any event within 30 business days of receipt of your request.
We use the information we collect in compliance with this Policy. We sign agreements with all of our partners and employees, which obligates all parties to comply with this Policy.
Upon implementation of this Policy, Scimega is to conduct yearly compliance verification to ensure we comply with the Canadian regulation regarding privacy as set forth by Canadian Personal Information Protection and Electronic Documents Act – Principles.
Use of Personal Information
We do not collect any more Personal Information than is necessary to provide our Services. We only use your Personal Information for the purposes we specify in this Policy and according to any agreements we have in place.
As part of Scimega’s business activities, we may obtain from our partners (clients,
investigative sites, vendors), Personal Information such as (but not limited to) the names, titles, contact information, CVs and other information to conduct our activities relevant to our mandate. Scimega will collect, hold, use and disclose such information in accordance with our respective agreements with each partner and in compliance with this Policy and applicable laws.
We also share certain information with service providers that carry out functions or services on our behalf that enable our business operations, including the protection and securing of our systems and services.
In addition to the uses identified elsewhere in this Policy, we may use your Personal Information to send information to you which we think may be of interest to you by post, email, or other means; or send you marketing communications relating to our business.
In case of third-party audits or inspections, the third party conducting the audit or inspection will be informed and will need to comply with the requirement that the documents available during the audit or inspection are Copyright of Scimega or of our partners and are shared for viewing purposes only. They cannot be reproduced, saved, printed or circulated, unless agreed upon by Scimega and any other concerned party.
In the context of our clinical trial management activities, Scimega does not hold information that would allow us to directly identify study subjects.
Scimega does not sell or rent to third parties Personal Information from our partners or employees.
Scimega does not collect or maintain information on its website or in our systems from those it knows are under 13 years of age, and no part of its business or website is structured to attract anyone under the age of 13.
On occasion, we post client/partner testimonials and comments on our website, which may contain Personal Information. We obtain each client’s consent via email prior to posting the client’s name and testimonial.
If you are interested in a career with Scimega and you choose to send your résumé to us by email, we will maintain and use the information contained in your résumé for recruiting purposes only. We may also retain some of your information for a reasonable period of time for purposes of considering you for future positions.
If you are an employee or former employee at Scimega, we will collect, use, retain and disclose your Personal Information according to your employment agreement with us and in accordance with applicable Canadian and Quebec law or governmental inspections. Scimega does not provide any performance references on any employee to third parties. For former employees, we provide employment verification to other employers only following written consent by the former or current employee.
In some specific cases during the conduct of a clinical trial we are managing, we may transfer Personal Information to the United States or another part of the World, according to the trial requirements and prior service agreements we have with our partners.
If necessary for the conduct of a clinical trial and performance of our services, Personal Information may be transferred and processed across borders, including without limitation, the transfer of Personal Information to the United States, or to third parties, including other companies related to Sponsor/Scimega in the form of a group and their advisors (such as external central labs, imaging facilities, IVRS, other pharmaceutical companies or CRO’s collaborating on the trial, etc.), as well as to certain regulatory authorities and to the public registry posting on the Internet (such as clinicaltrials.gov), as required by applicable law. You will always be informed of this requirement prior to our collaboration on that specific trial and you will have the right to refuse to participate/collaborate on the trial and to share Personal Information. This Policy shall apply even if we transfer Personal Information to other countries outside Canada.
If Scimega is involved in a merge, acquisition or sale of all or a portion of its assets, your Personal Information may be transferred to the acquiring person or entity and you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
Security of Your Personal Information
All of your Personal Information remains private and confidential. The security of your Personal Information is important to Scimega. We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on our systems in a controlled, secure environment, protected from unauthorized access, use or disclosure. When applicable, information is protected through the use of encryption and other security protocol that we test periodically. However, no method of transmission, or method of electronic storage, is 100% secure. Therefore, we cannot
guarantee its absolute security.
If you have any questions about security on our website, our systems or about security of our activities please contact us at email@example.com.
We post regularly on public forums, such as LinkedIn. Any information that you choose to disclose through our public forums may be collected and used by others. We will correct or delete any information you have posted on those forums if you request that we do.
Retention of Personal Information
We retain Personal Information that you provide us as long as required by the agreements we have with clients/partners and in accordance with applicable Canadian law and this Policy. We will delete this information from our systems at an earlier date if requested, as permitted by law.
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights or to comply with a law, court order, or legal process. If Scimega is required by law or an order of a court of competent jurisdiction to disclose your information, Scimega will promptly notify you of this requirement so that you may take any specific actions on your end as required.