Privacy Policy

Advance Research Associates Notice of Certification Under the EU-­US and Swiss-US and Privacy Shield Frameworks

Policy

Protecting privacy is critical to our business. Advance Research Associates (ARA) complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of information transferred between the European Union and Switzerland and the United States. Advance Research Associates adheres to the Privacy Shield Principles as certified under the Department of Commerce. ARA’s certification can be viewed here: https://www.privacyshield.gov/.

Scope

This Policy outlines our practices for implementing the Privacy Shield Principles and applies to all personal information received by Advance Research Associates in providing services as a Clinical Research Organization “CRO”. This includes clinical trial data and data collected from employees, customers, business partners and the Advance Research Associates website.

Privacy Principles

Notice

Advance Research Associates, as a CRO, may receive information from its clients within the EU or Switzerland when providing collection and analysis of clinical trial data. ARA processes pseudonymized data only and does not collect or control clinical trial data.

Personal information related to clinical trial participation

Advance Research Associates as a CRO provides data analysis services for our clients. In the performance of these services, Advance Research Associates may be the recipient of medical and health information pertaining to test trials. Personal information from research subjects may be transferred to Advance Research Associates in a pseudonymized form. The data is collected in accordance with the notice provided to the individual, choices made by the Individual or to comply with the legal obligations, policies, procedures, and internal administrative purposes of the sponsor (not ARA).

Employees

Advance Research Associates may collect information from their employees and job applicants to perform Human Resource functions. Individuals will be informed of the purposes for which Advance Research Associates collects and uses the information. Advance Research Associates will provide the choice and means for limiting the disclosure of personal information if requested. Advance Research Associates will notify employees in advance of using or disclosing the information for a purpose other than for which it was originally collected.

Choice

Advance Research Associates requires sponsors to remove any information that would identify a subject’s name with their data, before ARA will process that data. The sponsors (not ARA) are responsible for ensuring whether a study subject’s personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals.

Accountability for Onward Transfers

Advance Research Associates does not share personal information with contracted third parties. Any information requests by third parties are deferred to the sponsors.

Compelled Disclosure

Advance Research Associates may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Security

Advance Research Associates takes precautions through physical, technical, and administrative procedures to safeguard and secure personal information in its possession from loss, misuse, unauthorized access or disclosure, alteration and destruction.

Data Integrity & Purpose Limitation

Advance Research Associates will only use personal information in a way that is consistent with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, Advance Research Associates will take reasonable steps to ensure that personal information is accurate, complete, current and reliable for its intended use and for the duration it is held by Advance Research Associates.

Access

On request, Advance Research Associates will provide employees with access to their personal information, and in doing so allowing individuals the opportunity to correct, amend or delete inaccurate information, or has been processed in violation of the Principles, 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. Advance Research Associates, as a CRO, does not have direct relationships with study participants and as such, these individuals seeking access to their personal information must direct inquiries to their clinical investigator or study sponsor which transferred the personal information to Advance Research Associates for processing.

Recourse, Enforcement & Liability

Advance Research Associates will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information in accordance with the Privacy Principles. Advance Research Associates will respond to a complaint within 45 days of receipt. For complaints that cannot be resolved, Advance Research Associates commits to cooperate with the panel established by the EU data protection authorities (DPAs) or the Swiss Federal Data Protection and Information Commissioner, as applicable, and comply with the advice given by the panel or Commissioner with regard to personal data transferred from the EU or Switzerland. This independent dispute resolution process is provided at no cost to you. Under the Privacy Shield Principles, you may choose to invoke binding arbitration via ARA’s arbitration provider, the International Centre for Dispute Resolution (ICDR/AAA) to resolve any residual complaints not resolved by any other means. Access the ICDR/AAA site here: http://go.adr.org/privacyshield.html.

Advance Research Associates commitments under this policy are subject to the enforcement powers of the U.S. Federal Trade Commission (FTC).

Contact Information

Advance Research Associates
2350 Mission College Boulevard, Suite 825
Santa Clara, CA  95054
voice: (650) 810-1190
fax: (650) 810-1195

Effective date: 10/18/2018