CRF Bracket is committed to transparency when it comes to its collection and use of personal data. This notice sets out CRF Bracket’s commitment to privacy, data protection, and individual rights and obligations in relation to personal data.
This notice applies to all personal data of clients, clinical trial participants, vendors, job applicants, employees, contractors, former employees, and visitors to CRF Bracket’s website (such as cookies and internet tags) which is provided to, or collected and processed by CRF Bracket.
CRF Bracket respects individual privacy and values the confidence of its customers, employees, clinical trial participants, consumers, business partners and others. CRF Bracket strives to collect, use and disclose Personal Data in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices.
CRF Bracket has appointed Thomas Barlow as its Data Protection Officer. His role is to inform and advise CRF Bracket on its data protection obligations. He can be contacted at firstname.lastname@example.org. Questions about this notice, or requests for further information, should be directed to the Data Protection Officer. We self-certify compliance with: EU-U.S. Privacy Shield
This notice may occasionally be updated. When material updates are made, the date of the last revision will be reflected at the end of the page.
“CRF Bracket” is Signant Health and its successors and subsidiaries.
“data controller” is a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
“data subject” is an identified or identifiable natural living person.
“GDPR” is the European Union’s General Data Protection Regulation
“personal data” is any information that relates to a living individual who can be identified from that information. Under GDPR this data is known as “Personally Identifiable Information”.
“processing” is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.
“data processor” is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller.
“special categories of personal data” means information about an individual’s racial or ethnic origin, criminal records data, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.
“criminal records data” means information about an individual’s criminal convictions and offences, and information relating to criminal allegations and proceedings.
Data Protection Principles
CRF Bracket processes personal data in accordance with the following data protection principles:
- CRF Bracket processes personal data fairly, lawfully, and in a transparent manner.
- CRF Bracket collects personal data only for specified, explicit and legitimate purposes.
- CRF Bracket processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
- CRF Bracket keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
- CRF Bracket keeps personal data only for the period necessary for processing.
- CRF Bracket adopts appropriate measures to make sure that personal data is secure, and protected against unauthorized or unlawful processing, and accidental loss, destruction or damage.
- CRF Bracket takes responsibility for how it acquires, processes and disposes of personal data, and for ensuring compliance with the above principles.
Where CRF Bracket is considered the data controller, CRF Bracket tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons. Where CRF Bracket relies on its legitimate interests as the basis for processing data, it will carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of individuals. CRF Bracket will update personal data promptly if an individual advises that his/her information has changed or is inaccurate.
Where CRF Bracket is considered the data processor or sub-processor, CRF Bracket unconditionally relies on the data controller to obtain the clear, lawful consent of the data subject. In such cases, CRF Bracket will only process the personal data in accordance with the applicable laws, rules, regulations, and as specifically directed by the data controller.
Personal data gathered during employee and contractor relationships is held in the individual’s personnel file, in hard copy or electronic format and on CRF Bracket HR systems. The periods for which CRF Bracket holds such HR-related personal data are contained in its privacy notices issued to individuals.
CRF Bracket operations and maintenance contractors sometimes have limited access to personal data in the course of providing products or services to CRF Bracket. Access to personal data by these contractors is limited to that which is reasonably necessary for the contractor to perform its limited function for CRF Bracket. CRF Bracket requires its operations and maintenance contractors to: (1) protect the privacy of any personal data consistent with this notice, and (2) not use or disclose personal data for any purpose other than providing CRF Bracket with products and services, as required by law.
CRF Bracket keeps a record of its personal data processing activities in accordance with the requirements of the GDPR.
As a data subject, individuals have a number of rights in relation to their personal data:
Subject Access Requests
Individuals have the right to know what personal data about them is being controlled and processed by CRF Bracket and to ensure that such personal data is accurate and relevant for the purposes for which CRF Bracket collected it. If an individual makes a reasonable request, CRF Bracket will tell him/her:
- whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
- to whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
- for how long his/her personal data is stored (or how that period is decided);
- his/her rights to rectification or erasure of data, or to restrict or object to processing;
- his/her right to complain to the Information Commissioner if he/she thinks CRF Bracket has failed to comply with his/her data protection rights; and
- whether or not CRF Bracket carries out automated decision-making and the logic involved in any such decision-making.
CRF Bracket will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless the individual requests otherwise.
If the individual requires additional copies, CRF Bracket may charge a reasonable fee, which will be based on the administrative costs of providing the additional copies.
To make a subject access request, the individual should use CRF Bracket’s contact page https://signanthealth.com/contact-us/. In almost all cases, CRF Bracket is legally required to ask for proof of identification before the request can be processed. Also, in some cases, CRF Bracket may need to contact the sponsor of the study in which you are participating, if applicable.
CRF Bracket will normally respond to a request within a period of one month from the date it is received. In some cases, such as where CRF Bracket processes large amounts of the individual’s data, it may respond within three months of the date the request is received. CRF Bracket will write to the individual within one month of receiving the original request to tell him/her if this is the case.
If a subject access request is manifestly unfounded or excessive, CRF Bracket is not obliged to comply with it. Alternatively, CRF Bracket can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. An example of when a subject access request is likely to be considered manifestly unfounded or excessive is where a request is repeated for which CRF Bracket has already responded. If an individual submits a request that is unfounded or excessive, CRF Bracket will notify him/her that this is the case and whether or not it will respond to it.
Individuals have a number of other rights in relation to their personal data. They can require CRF Bracket to:
- inform them about the collection and use of their personal data;
- rectify inaccurate personal data;
- stop processing or erase personal data that is no longer necessary for the purposes of processing;
- continue to store their personal data but not use it;
- respect an individual’s right to object to the processing of their personal data in certain circumstances such as for direct marketing;
- provide them with their personal data in a portable form, so that it can be easily transferred to another IT environment. We would usually fulfil this request by providing the data in the form of a “comma-separated-values” (csv) file;
- respect an individual’s rights related to automated decision making based on their personal data;
- stop processing or erase personal data if the individual’s interests override CRF Bracket’s legitimate grounds for processing personal data (where CRF Bracket relies on its legitimate interests as a reason for processing personal data);
- stop processing or erase personal data if processing is unlawful; and
- stop processing personal data for a period if data is inaccurate or if there is a dispute about whether or not the individual’s interests override CRF Bracket’s legitimate grounds for processing personal data.
To ask CRF Bracket to take any of these steps, the individual should use CRF Bracket’s contact page https://signanthealth.com/contact-us/, or contact a CRF Bracket HR representative, as the case may be.
EU Persons (EU Data Subjects) may complain to their home data protection authority and can invoke binding arbitration for some residual claims not resolved by other redress mechanisms (please see the following for more additional information: https://www.privacyshield.gov/article?id=ANNEX-I-introduction)
If you have a comment or concern that cannot be resolved with us directly, you may also contact the competent local data protection authority.
CRF Bracket takes the security of personal data seriously. CRF Bracket has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties. CRF Bracket complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union to the United States. CRF Bracket has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
Where CRF Bracket engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
CRF Bracket recognizes potential liability in cases where personal data may be transferred to third parties. CRF Bracket will not transfer any personal data to a third party without first ensuring that the third-party adheres to the Privacy Shield principles or similar laws providing an adequate and equivalent level of protection. CRF Bracket does not transfer personal data to unrelated third parties, unless lawfully directed by a client or another data controller, or in certain limited or exceptional circumstances in accordance with the EU-U.S. Privacy Shield Framework. For example, such circumstances would include disclosures of a client’s personal data required by law or legal process, or disclosures made in the vital interest of an identifiable person such as those involving life, health or safety. In the event that CRF Bracket is requested to transfer personal data to an unrelated third party, CRF Bracket will ensure that such party is either subject to the EU-U.S. Privacy Shield Agreement, or subject to similar laws providing an adequate and equivalent level of protection. If neither condition is applicable to the unrelated third party, CRF Bracket will enter into a written agreement with the third party requiring them to provide protections consistent with the EU-U.S. Privacy Shield Framework and this notice. Should CRF Bracket learn that an unrelated third party which received personal data from CRF Bracket is using or disclosing personal data in a manner contrary to this notice, CRF Bracket will take reasonable steps to prevent or stop the use or disclosure.
Some of the processing that CRF Bracket carries out may result in risks to privacy. Where processing would result in a high risk to individual’s rights and freedoms, CRF Bracket will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.
If CRF Bracket discovers that there has been a breach of personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. CRF Bracket will record all data breaches regardless of their effect.
If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.
International Data Transfers
Personal data may be transferred to countries outside the EEA. CRF Bracket complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union to the United States. CRF Bracket has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. Further, CRF Bracket is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
CRF Bracket assures compliance with this notice and the EU-U.S. Privacy Shield Framework by fully investigating and attempting to resolve any complaint or dispute regarding the use and disclosure of personal data in violation of this notice.
Vice President, Quality Management
1150 Northbrook Drive
Trevose, PA 19053
Phone: +1 215-504-7855
CRF Bracket has further committed to refer unresolved Privacy Shield complaints to the American Arbitration Association/International Centre for Dispute Resolution, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit http://go.adr.org/privacyshield.html for more information or to file a complaint. The services of the American Arbitration Association/International Centre for Dispute Resolution are provided at no cost to you.
CRF Bracket Employee Responsibilities
CRF Bracket employees may have access to the personal data of other individuals and of our customers and clients in the course of their employment. Where this is the case, CRF Bracket relies on individuals to help meet its data protection obligations to staff and to customers and clients.
Employees who have access to personal data are required:
- to access only data that they have authority to access and only for authorized purposes;
- not to disclose data except to individuals whether inside or outside CRF Bracket who have appropriate authorization;
- to keep data secure for example by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction;
- not to remove personal data, or devices containing or that can be used to access personal data, from CRF Bracket premises without adopting appropriate security measures such as encryption or password protection to secure the data and the device;
- not to store personal data on local drives or on personal devices that are used for work purposes; and
- to report data breaches of which they become aware to Thomas Barlow, email@example.com data protection officer immediately.
Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under CRF Bracket’s disciplinary policies and procedures.
CRF Bracket will provide training to all employees about their data protection responsibilities as part of the induction process and at regular intervals thereafter.
Employees whose roles require regular access to personal data, or who are responsible for implementing this notice or responding to subject access requests under this notice, will receive additional training to help them understand their duties and how to comply with them.
CRF Bracket may collect personal data through its website and visitors’ interactions with elements of its website, which are also subject to this notice. Such personal data can be collected when an individual submits his or her name and/or address. CRF Bracket can also collect information about visits to the CRF Bracket website without an individual actively submitting information through various automated digital means, such as cookies and internet tags. Although the information collected by such automated digital means does not directly identify specific individuals, internet web browsers automatically transmit information to the CRF Bracket website regarding the software a user’s computer is operating, such as IP address and browser version. Information collected by these technologies cannot be used to identify individuals without additional identifiable information.