Effective Date: September 2018
Information Collected in our Pre-Screening Process
When you visit our Site or contact us or we contact you, we collect personal information that you provide voluntarily. Most of our websites contain a Pre-Screening Questionnaire (PSQ) where we collect personal information when you answer questions on the website or we may collect personal information when we contact you by telephone or email. During Pre-Screening, MD Connect only collects personal information that is limited and necessary to evaluate your eligibility and qualifications for participation in our Sponsor’s current Study.
In the provision of our services, MD Connect (Data Processor) processes Personal Data on behalf of its Client(s) (Data Controllers). Personal Data means any information relating to an identified or identifiable natural person (data subject).
Personal Data includes direct and indirect identifiers such as:
- E-mail address
- Phone number
- IP address
- Identification Number
- Location Data (e.g. zip or postal codes)
- On-line Identifier
- Sensitive Data that may include one or more factors specific to physical, psychological, genetic, mental, economic, cultural or social identity of a natural person.
In the provision of our services, MD Connect (Data Processor) may process Sensitive Data on behalf of its Client(s) (Data Controllers). Sensitive Data is a special category of Personal Data that requires additional privacy and security protections. The collection of Sensitive Data is done at the direction of our Client(s) and is limited to specific and necessary Sensitive Data of potential clinical trial participants needed to determine eligibility for specific clinical trials.
Our Pre-Screening webpages require express consent of potentially eligible participants (e.g., website check box, participant voluntarily clicking ‘Submit’ button) before collection of any Personal Data that will be linked to any Sensitive Data (thereby making it identifiable).
Sensitive personal information that may be collected includes:
- Medical conditions
- Severity of condition
- Medical test results
- Height & Weight
- Lifestyle/habits (e.g. exercise, smoking)
- Prior medical procedures
- Medical symptoms
- Existing participation status or willingness to participate in a clinical trial
- Choice of physician or medical clinic
- Requested or actual appointment date and time
Uses and Disclosures of Information Collected in Pre-Screening
MD Connect uses and discloses Personal Data (including Sensitive Data) for a variety of purposes that are limited and necessary to the operation of our business and the delivery of services to you. These purposes include to:
- Determine whether you may be eligible to participate in Sponsor’s Study. During the recruitment period for the Study, we may provide your screening information and contact information to one of our Sponsor’s investigator sites nearest to you;
- Provide our services and generally manage and administer our business including required records retention processes;
- Develop and improve our services;
- Reply to your requests, inquiries and comments;
- Contact you via land line phone, cell phone, email, text message (cell and data charges may apply);
- Respond to circumstances permitted or required by law, including defending and bringing legal actions; and
- Ensure the security and integrity of our websites and operations.
MD Connect may disclose personal information collected through this Site to affiliated third party service providers, such as IT support services, customer service providers, and other services providers that support us and facilitate the services we provide to you. These companies are authorized to use your Personal Data only as necessary to provide these services to us. For example, we use Google Analytics, a web analysis service provided by Google. Google utilizes the data collected to track and examine the use of our Sites, to prepare reports for us on website activities and share them with other Google services. However, Google Analytics offers an opt-out provision for website visitors who do not want their data to be collected. You can access more information about this option at http://tools.google.com/dlpage/gaoptout.
MD Connect may disclose information to a third party in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). You will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data. Further, we may use and disclose information collected through the Site as we believe to be necessary or appropriate, including: (a) as permitted by applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit damages that we may sustain. We may also disclose your Personal Data to any other third party with your prior consent.
MD Connect reserves the right to compile and use the Personal Data collected as described above, in a de-identified or anonymized format, i.e. no longer personally identifiable as defined by data privacy regulations, for data aggregation and data analytics purposes.
Passive Information Collection and Use
MD Connect websites use a passive technology called “cookies” and other similar technologies. With cookies, we collect the IP (Internet protocol) addresses of all visitors to our websites and other related information such as browser type, operating system and average time a visitor spends on our websites. MD Connect uses this information to help us understand our website activity and to monitor and improve our websites. Cookies also provide information about you and your preferences, and help us personalize your experience on our Site. You can set your web browser to notify you when cookies are being placed on your system or to not accept cookies. However, if you decide not to accept cookies from our websites, you may not be able to take advantage of all of the features available to you on our websites.
Our Site uses another passive technology called “internet tags” or “web beacons”. This technology allows us to understand which webpages you visit and helps us optimize and tailor our websites to you and other future visitors. You can set your browser to notify you when these passive technologies are being placed on your system to not accept them.
Mobile Device Information
MD Connect also collects information from and about your mobile device, such as a unique device identifier.
Unaffiliated Third Party Sites and Services
Use of Site by Minors
Use of this Site or our services is not generally directed to individuals under the age of 18, and we request that these individuals not provide Personal and/or Sensitive Data through the Site or through our service providers unless identified as appropriate in the Pre-Screening criteria. However, there may be some Sponsors of clinical trials that are specifically seeking this age group. In such clinical trials, parental consent may be required as part of the Pre-Screening process.
If personal information related to individuals under the age of 18 is identified and deemed inappropriate, reasonable steps will be taken to delete the information.
Choices and Access
Upon request MD Connect will provide you with information about whether we hold any of your personal information. If you wish to change your preferences about the personal information you provided to us or wish to withdraw your consent to its retention, use or disclosure, please contact us at firstname.lastname@example.org or by faxing to 781-235-0929.
If you would like to review, correct, update, or delete the personal information that you have provided via the Site, please contact us at email@example.com or by faxing to 781-235-0929. We will reply to your request in a reasonable period of time not to exceed 60 days.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Platform Data Collection
MD Connect (Data Processor) collects information under the direction of its Client(s) (Data Controller(s)) and processes information on our Client(s)’ behalf. We have no direct relationship with the individuals whose Personal Data we process. If you are a customer of our Client(s) or are a participant in a Client(s)’ clinical trial and would no longer like to participate and/or be contacted by our Client, please contact the Client directly.
MD Connect acknowledges that you have the right to access your personal information. Individuals who seek access, or who seek to correct, amend, or delete inaccurate data should direct their query to MD Connect’s Client or MD Connect directly. If requested to remove data we will respond within a reasonable timeframe.
MD Connect will retain Personal Data we process on behalf of our Client(s) for as long as needed to provide services to our Client(s). MD Connect will retain this personal information for as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
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