Privacy Policy and Cookies

Privacy Policy and Cookies

TFS PRIVACY POLICY
Version 1.0 - Date effective 10 July 2015

1. INTRODUCTION

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.

This privacy policy outlines TFS general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This privacy policy applies to all personal information received by TFS whether in electronic, paper or verbal format.

2. DEFINITIONS

Agent 
Any third party that uses personal information provided by TFS to perform tasks on behalf of and under the instructions of TFS. 

Individual
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.

Principles
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. 

3. PRINCIPLES

3.1 Notice

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.

Web visitors
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. 

3.2 Choice

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. 

3.6 Access

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. 

3.7 Enforcement

TFS uses a self-assessment approach, by TFS Data Protection Officer, to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information in accordance with the principles. 
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. 

3.8 Amendments

This privacy policy may be amended from time to time consistent with the requirements of the privacy laws. We will post any revised policy on this website.

3.9 Contact Information

Questions, comments or complaints regarding TFS’s Privacy Policy or data collection and processing practices can be sent by email to: data.protection@tfscro.com

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Our sites use a number of different cookies. Below we explain the cookies we use and why we use them.

TFS Cookie POLICY

The purpose of this cookies policy is to provide clear and precise information about the cookies used on our website.

We use own and third-party cookies to improve our services, customise our website, make it easier for our users to browse, offer an improved experience when using the website, identify problems and thereby improve the website, carry out measurements and usage statistics and show you advertising related to your preferences by analysing use of the website.

We inform you that we can use cookies on your device provided you have given your consent, except in those cases where the cookies are necessary to browse our website. If you give your consent, we will be able to use cookies that will allow us to gather more information about your preferences and customise our website according to your individual interests.

WHAT ARE COOKIES?
Cookies and other similar technologies, such as local shared objects, flash cookies or pixels, are tools used by Web servers to store and recover information about website visitors, and also to ensure correct functioning of the website.

TYPES OF COOKIES
1ypes of cookies depending on the organisation managing them:

  • Own cookies: these cookies are sent to the user’s terminal from a computer or domain managed by the owner of the website from which the service requested by the user is provided.
  • Third-party cookies: these cookies are sent to the user’s terminal from a computer or domain not managed by the owner of the website from which the service requested by the user is provided, but by another organisation that processes the data obtained through the cookies. In addition, if the cookies are installed from a computer or domain managed by the Website owner but the information collected by them is managed by a third party, they will also be considered third-party cookies.

Types of cookies according to their purpose:

  • Technical cookies: these are cookies that allow the user to browse a website, platform or application and to use the different options or services thereon, including those that the editor uses to allow management and operation of the website and enable its functions and services. These include, for example, monitoring traffic and data communication, identifying the session, accessing restricted access areas, remembering the component elements of an order, carrying out the order purchase process, managing the payment, monitoring any fraud associated with the security of the service, dealing with an application for registration or participation in an event, counting the number of visits for the purposes of invoicing licences for the software with which the service operates (website, platform or application), using security elements during browsing, storing content for the dissemination of videos or sound, enabling dynamic content (for example, animation to load a text or an image) or sharing content on social networks.
  • This category also includes, because of their technical nature, those cookies that allow management, as efficiently as possible, of any advertising spaces that, as one more element of design or “layout” of the service offered to the user, the editor has included on a website, application or platform based on criteria such as the content edited, without compiling information about the users for other purposes, such as customising this advertising content or other content.
  • Preference or customisation cookies: these cookies are used to remember information so that the user can access the service with certain characteristics that differentiate his/her experience from that of other users such as, for example, the language, the number of results displayed when the user performs a search, the appearance or content of the service depending on the type of browser used by the user to access the service or the region from which he/she accesses the service, etc.
  • Analytics or performance cookies: these cookies allow the person or entity responsible for them to monitor and analyse the behaviour of users of the websites with which they are associated, including quantifying the impacts of adverts. The information collected by this type of cookies is used to measure activity on the website, application or platform, in order to introduce improvements according to the analysis of the users’ data usage.
  • Behavioural advertising cookies: these allow us to manage, as efficiently as possible, the advertising spaces on the website. These cookies store information on user behaviour obtained through continuous observation of his/her browsing habits, allowing us to develop a specific profile to show advertising adapted to that profile.
  • Geolocation cookies: these are used to find a user’s location when he/she requests a service. This cookies is anonymous and is used, for example, to offer you relevant information depending on the country where you are located.

Types of cookies according to the length of time they remain active:

  • Session cookies: these cookies are designed to collect and store data when the user accesses a website. They are generally used to store information that only needs to be kept for the provision of the service requested by the user on a single occasion (for example, a list of products bought) and disappear when the user logs off or ends the session.
  • Persistent cookies: with these cookies, the data continue to be stored in the terminal and may be accessed and processed for a period defined by the person/entity responsible for the cookie, which may range from a few minutes to several years.

COOKIES USED ON OUR WEBSITE

(List the names of the cookies, type, owner, function and expiry) for example:

Name Owner Duration Purpose
ci_session TFS Session Contains the session identifier. It is erased when the browser is closed.
csrf_cookie_name TFS Session Form protection. It is erased when the browser is closed.
cookieControl TFS 1 Month To store cookie preference
cookieControlPrefs TFS 1 Year To store cookie preference
_gat Google 1 Minute Used to throttle request rate
_ga Google 2 Years Used to distinguish users
_gid Google 24 hours Used to distinguish users

 

COOKIES USED ON OUR WEBSITE

The user can, at any time, allow, block or delete the cookies installed on his/her device by changing the settings on the browser installed on his/her computer:

  • Chrome Chrome Settings -> Advanced -> Privacy -> Content settings. For more information, consult Google support or your browser Help.
  • Explorer Explorer tools -> Internet options -> Privacy -> Settings. For more information, consult Microsoft support or your browser Help.
  • Firefox Firefox: Tools - > Options -> Privacy -> History -> Customised Settings For more information, consult Mozilla support or your browser Help.
  • Safari Safari Preferences -> Security. For more information, consult Apple support or your browser Help

If you deactivate the cookies, it will not prevent you from browsing the website, but the use of some services may be limited and, consequently, your browsing experience may be less satisfactory.

WITHDRAWING CONSENT

The user may withdraw his/her consent relating to the Cookies Policy at any time, and may delete the cookies stored on his/her device by adjusting his/her internet browser settings, as described above, and also by accessing our settings panel in the footer of every web page.

COOKIE SETTINGS

This Cookies Policy may be modified when required by the legislation in force at any time or when there is a change in the type of cookies used on the website. For this reason, we recommend that you review this policy every time you access our website, so that you are appropriately informed of how and why we use cookies.