Version 1.0 - Date effective 10 July 2015
TFS is a global contract research organisation. TFS provides a broad range of professional services, information and partnering solutions to the pharmaceutical, biotechnology and healthcare industries.
Any third party that uses personal information provided by TFS to perform tasks on behalf of and under the instructions of TFS.
Any natural person located in the European Union or Switzerland whose personal information is shared with TFS in the United States.
Personal Information or Information
Information that (1) is transferred from the EU or Switzerland to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual. Personal information does not include information that is anonymized or pseudonymized such that an individual cannot be identified.
The enumerated principals outlined in the GDPR.
Sensitive Personal Information
Personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.
TFS shall inform an individual of the purpose for which it collects and uses the personal information and the types of non-agent third parties to which TFS discloses or may disclose that information. TFS shall provide the individual with the choice and means for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to TFS, or as soon as practicable thereafter, and in any event before TFS uses or discloses the information for a purpose other than for which it was originally collected.
Where TFS receives personal information from its subsidiaries, affiliates or other entities in the EU or Switzerland, including when acting as a CRO processing personal information under the direction of a customer, it will use such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
TFS may not need to furnish notice where the processing in question is necessary to respond to a government inquiry; is required / authorized by applicable laws, court orders or government regulations; or is necessary to protect TFS’ legal interests and providing notice would interfere with the above requirements.
What types of personal information does TFS collect and handle and for what purposes?
Clinical and Medical Information
As a global contract research organization, we collect, host and analyse health data relating to clinical trial subjects, on behalf of our clients. To enhance privacy, consistent with GCP, subjects’ names and other direct identifiers are not attached to any records collected by TFS for research purposes. Instead, subjects are only identified by a code (information is anonymized or pseudonymized). Only study doctors and authorized personnel, including TFS monitors and TFS auditors, may access named subject records at the investigational site. In certain cases where local law allows, TFS may collect full date of birth attached to study records. We maintain that this indirect identifier can on occasion serve to verify subject identity to the benefit of patient safety. All clinical and medical information processed by TFS is done so under contract with our clients. In terms established by the Directive (95/46/EC), TFS considers that the sponsor/client is ultimately in control of how and why clinical and medical data are processed within our services and as such is the “controller,” whilst TFS and its affiliates are “processors.”
Health professional information
TFS collects the professional profiles (CVs) of doctors and other health care providers for the purpose of identifying potential investigators to assist in clinical and medical research on specific indications. TFS will use available contact information, including email addresses, for the purpose of inviting potential investigators to apply to participate in research. TFS will source health professional information from its own databases and also indirectly from public sources and referrals. For operational purposes, TFS will also collect information relating to the involvement and performance of investigators and supporting study staff. TFS will also process financial information of investigators to support payment for services.
Employee and Human Resource data
TFS collects personal information from applicants to open positions within TFS, including private contact details, professional qualifications and previous employment history to inform employment decisions. TFS conducts various background checks on applicants, including, where law allows, on criminal history and professional disbarment. Once employed, TFS collects information on staff for human resource, performance, payroll and tax purposes. Various TFS internal systems will collect and record employee information consistent with standard business operations. TFS processes similar information relating to consultants contracted on a freelance basis.
TFS collects named information about visitors to TFS websites where this is voluntarily provided to meet a request from those individuals, for example where a client requests information on a TFS service, a health care professional is interested in participating in a clinical trial or where someone wants to apply for a vacant position with TFS. Through the use of cookie-based technologies, TFS may collect various data linked to virtual identities allocated to visitors when they access our websites. This data is used for various purposes, including site analytics and first party marketing. In certain cases, these virtual identities are linked to the real world identities of visitors when they provide their named information as described above.
TFS will offer individuals the opportunity to choose whether their personal information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Unless required or authorized by law, TFS will not process sensitive personal information about individuals for purposes other than those for which the information was originally obtained or subsequently authorized by the individual unless the individual affirmatively and explicitly consents to the processing (“opt-in”). In some cases, even if an individual opts-out of disclosures of their personal information, TFS may still disclose such personal information if required to do so by law, if disclosure is required to be made to law enforcement authorities, if we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. TFS also may transfer personal information in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, TFS will direct the transferee to use personal information in a manner that is consistent with this Policy.
3.3 Onward Transfers
Transfers to third parties are covered by the provisions in this policy regarding notice and choice. TFS may also share an individual's personal information with agents, contractors or partners of TFS in connection with services that these individuals perform for, or with, TFS. TFS shall ensure that any third party for which personal information may be disclosed subscribes to the principles or are subject to law providing the same level of privacy protection as is required by the principles and agree in writing to provide an adequate level of privacy protection.
3.4 Data Security
TFS will employ reasonable physical, electronic and managerial procedures to safeguard and secure the personal information from loss, misuse, unauthorized access or disclosure, alteration or destruction. TFS cannot guarantee the security of information on or transmitted via the Internet.
3.5 Data Integrity
TFS shall only process personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, TFS shall take reasonable steps to ensure that personal information is accurate, complete, current and reliable for its intended use.
Upon request, and as required by law, TFS will provide an individual reasonable access to their personal information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.
If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using (EU data Protection Authorities (DPAs) and Swiss Federal data Protection and Information Commissioner (FDPIC)) as a third party resolution provider.
3.9 Contact Information
Our sites use a number of different cookies. Below we explain the cookies we use and why we use them.
What is a cookie?
A cookie is a small text file that may be placed on your device when you visit our sites. When you next visit our sites the cookie allows us to distinguish you from other users.
There are two broad categories of cookies:
Persistent cookies remain on your device until deleted manually or automatically.
Session cookies remain on your device until you close your browser when they are automatically deleted.
Cookies we use and why we use them
Essential cookies are technical cookies that are required for the operation of our sites. Without essential cookies our sites can't operate properly. Essential cookies include, for example, cookies that enable you to log into secure areas.
Performance cookies allow us to recognise and count the number of visitors to our sites and to see how visitors move around them. This helps us to improve the way our sites work by enabling us to tailor our sites to the way visitors use them. The information we collect from performance cookies is aggregated which means that we cannot identify you from it.
Experience cookies allow our sites to remember the choices you make. Our sites use experience cookies to provide you with enhanced and personalised features. For example, we use information collected through what are known as "web-analytic" cookies to compare the choices you make to those of our other customers so that we can learn from those choices. Information collected by experience cookies cannot track your browsing activity when you leave our sites to browse other sites.
Marketing cookies record your visits to our sites, the pages you have visited and the links you have followed. We use this information to make our sites and the advertising displayed on them more relevant to your interests. For example sometimes we use marketing cookies to limit the number of times that you see an advert. Sometimes we share information about your browsing activity, (which we have collected from cookies), with our advertising partners. They may use this information to advertise products, which may interest you, on other sites.