Where it is required to do so, Covance is registered as a data controller under the data protection laws of each of the countries where it operates. Covance takes all reasonable care when dealing with personal information and we are committed to ensuring that the collecting and processing of data complies with the following Data Protection Principles:
Personal data must:
- Be fairly and lawfully processed.
- Be processed for specified and lawful purposes.
- Be adequate, relevant and not excessive.
- Be accurate and where necessary kept up to date.
- Not be kept longer than necessary.
- Be processed in accordance with the data subject's rights.
- Be secure.
- Not to be transferred to countries without adequate protection.
1. Information Collected.
By Personal Information we mean information which identifies or is capable of identifying an individual, including our clients, volunteers or patients in clinical studies (research subjects), employees, vendors and clinical investigators with whom we work. Personal Information may include, but is not limited to, first and last name, date of birth, company information, home or other physical address, email address, phone number or other contact information and medical information.
You may be asked to provide Personal Information when you use our website, or volunteer for clinical studies or otherwise work with Covance.
In addition, if you become a volunteer, we will (with your consent) collect information in relation to your medical history which we will retain and/or dispose of or transfer in accordance with both the relevant protocol for the clinical study for which it was gathered and applicable local law. During a clinical study we will also collect certain information such as blood test results, however this data will be held in a format from which the individual cannot be recognised (see below).
From time-to-time, we may request information from you via surveys. Participation in these surveys is completely voluntary, and, therefore, you have the choice of whether or not to disclose such information. Information requested may include contact information (such as name, correspondence address and telephone number), and demographic information (such as zip or postal code or age).
2. Means of Collecting & Processing Data.
We may automatically collect certain data and receive Personal Information about you where you provide such information through our website or other communications and interactions with Covance. We may also receive Personal Information from service providers that refer you to the Covance site, and from customer/volunteer lists lawfully acquired from third party vendors. This information may be disclosed only to our staff and to third parties involved in any clinical studies as described under section 3 below.
We do not collect Personal Information about you without your knowledge. All data collected (and transferred if necessary to third parties during a clinical study (for example blood test results)) will only be collected with your express consent.
For volunteers in clinical studies, prior to the commencement of a clinical study, the primary care, secondary care or other institution ("Research Institution") must obtain signed informed consent (in a format approved by Covance and the "Sponsor" of the study and the applicable ethics committee) from you. This consent will include information and permissions relating to data protection and regarding access to your medical records by authorised personnel from Covance, the Sponsor of the study, their agents, regulatory authorities as well as other information and permissions that may be required under applicable local laws. It will also establish consent for research data to be used for the applicable study analysis and future submissions to regulatory authorities for product marketing approval.
All research data is held in an anonymised format from which you cannot be directly identified. The anonymisation of data is done by assigning a code to each section of data. Only the research institutions and possibly the "Sponsors" will keep the coding which means only they will know which data relates to which individual.
3. Information Use.
We use the Personal Information we collect from you to carry out our clinical studies, to provide volunteer support, to undertake necessary security and identify verification checks, to meet certain business requirements and for other purposes related to the operation of our services. Sometimes we may need to share your Personal Information with other Covance businesses and third parties. This may happen, for example, where it is necessary for the purposes of our own legitimate interests or for those of a third party. Covance may make the data we hold available to the following:
- Sponsor of the clinical study for all the purposes attached to its position as Sponsor, and those related to the clinical study;
- Regulatory agencies as required by law;
- Health authorities as required by law; and
- Covance affiliate companies, which may be involved in the clinical study.
Except where local laws entitle the Sponsor of the study or regulatory authorities to view patient records, all data is released in the coded form that will not identify research subjects.
Disclosure of information to the above mentioned recipients may involve disclosure outside the country in which you reside and/or European Economic Area. Covance endeavours to ensure, as far as they are able, that the third party provides an equivalent level of protection for your privacy.
4. Keeping information up to date.
We will only retain information about you which is necessary for purposes as described above and will take all reasonable steps to ensure that it is kept up to date and accurate. From time to time we may ask you to review and update the information in accordance with this policy. We will only hold this information for as long as it is appropriate to your relationship with Covance, or as long as it is necessary to comply with any legal obligation.
You may contact us at Covance Inc., 210 Carnegie Center, Princeton, New Jersey 08540, United States of America, c/o General Counsel if you: 1). want to confirm the accuracy of the Personal Information we have collected about you; 2). would like to update your Personal Information or delete your Personal Information; and/or 3) have any complaint regarding our use of your Personal Information. If requested, we will change any information you have provided to us or mark any information to prohibit future use, provided that you provide evidence as we may reasonably require for such changes and sufficient information to enable us to locate your Personal Information.
Volunteers in clinical studies or their legal representatives also have the right to view the data held on them by making a request directly to the Research Institution. Local laws may provide that volunteers may access this data through their physician.
If having seen the information, you find that it is inaccurate you can notify the Institution or Covance who will make the necessary amendments and confirm to you that these have been made.
If in the event that you withdraw your consent for either your participation in the study or for your Personal Information to be processed, no further data that includes your Personal Information will be collected or processed by the Research Institution or Covance. Personal Information collected to date may continue to be processed to protect the integrity of the study and your safety.
Covance holds data securely in a form that does not directly contain Personal Information, and in addition Covance invests in the following forms of security:
- employees/workers who have access to the information are aware of their obligations when handling the data, in accordance with employee privacy and confidentiality policies;
- hard copies of the data are kept in a secure filing area with restricted access;
- a multi-tiered approach to computer security which works on the following levels:
- multiple levels of firewall and intrusion protection solutions from multiple vendors;
- a managed approach to network access;
- a structured approach to permission to network;
- regular testing to ensure integrity and security of network;
- printed material is disposed of securely, for example, by shredding; and
- information is only kept for limited and legitimate purposes and only until such time as it is no longer relevant to the business.
All employees of Covance who deal with research data and other personal information in connection with volunteers will be required to comply with the Covance policies and procedures. Breaches of security are properly investigated and remedied. Any employee handling data in connection with volunteers, who knowingly or recklessly discloses that information outside the Covance policies and procedures, will be subjected to disciplinary action and may also be held criminally liable.
8. International Transfers.
Personal Information collected by Covance may be stored and processed in any country in which we or our affiliates, suppliers, subsidiaries or agents maintain facilities, and by using the Covance website or otherwise engaging in business with us or volunteering for a clinical study, you consent to any transfer of information outside of your country (including to countries which may not have been assessed as having adequate privacy laws). Nevertheless, we take steps to ensure that our affiliates, agents, subsidiaries and suppliers comply with our standards of privacy regardless of their location.
If we should ever file for bankruptcy or be acquired by a third party, merge with a third party, sell all or part of our assets, or otherwise transfer substantially all of our relevant assets to a third party, we are entitled to share the Personal Information and all other information you have provided to us through to potential and subsequent business and merger partners.
Last Updated: December 27, 2006