VCT EU Privacy Shield Compliance Notice
VCT does not sell or share subject personal identifiable information with other people or non-affiliated companies and makes every reasonable attempt to safeguard subject privacy. Except where required by regulation, court order, official authority, or applicable law Verified Clinical Trials (VCT) will not make individual information or data available to any third party.
1. Verified Clinical Trials participates in Privacy Shield and has self-certified to theprivacy principles. VCT is committed to ensuring that all personal data received from the EU is subject to compliance with the Privacy Principles which may be accessed through the following link: (https://www.privacyshield.gov/EU-US-Framework)
2. What kind of personal information does VCT collect and hold? VCT will collect portions of your name, date of birth, gender, and portions of your ID numbers such as Driver’s license number, passport number, military ID number, government issued ID, and jurisdiction or country of issue. In some instances, a portion of your fingerprint may be obtained for biometric scanning. VCT also maintains a registry of clinical trial information to capture the screening dates, dosing dates, last blood draw dates, investigational drug used, and enrolment status of subjects.
3. What entities and subsidiaries will also have access to this information? Only the study centre and VCT personnel will be able to view your information in the database. VCT employees in the United States will have access to all your study information from all participating sites to make sure your enrolment information is correct and up to date. Site users enter the information provided by you which is immediately processed by the system to create a de-identified unique identifier code (UIC). This means that by looking at the code you would not be able to tell what the person’s name is or their private information. All other information is encrypted in the VCT database and password protected.
4. Why does VCT collect, hold, use and disclose this information? In order to determine if you may be eligible to participate in a clinical research study, it is necessary for the study centre to know if you are participating in another clinical research study or have recently participated in a clinical research study. It is important to know whether you are taking an investigational drug now, or have taken one within the restriction period of the new study because your health may be harmed if you start a new clinical research study with a new investigational drug or other investigational product while another investigational drug is still in your system.
5. How can I contact VCT with any inquiries or complaints? Are there any entities in the EU that can respond to such inquiries or complaints? You may inquire about your personal information in the database at any point in time by contacting Verified Clinical Trials at 1-888 960-3099, in writing at Verified Clinical Trials, 1305 Franklin Avenue, #150, Garden City, NY 11530, USA, or via email at info@VerifiedClinicalTrials.com. If you are concerned that the information in the Database about your participation in clinical research studies is not accurate, you can contact VCT at any time as directed above. You will be required to confirm your identity. VCT does not currently maintain any offices in the EU; all inquiries and complaints must be sent to VCT as directed above.
6. Is my personal information disclosed to any third parties and if so for what purpose? VCT does not disclose your personal information to third parties and makes every effort to prevent accidental disclosure by employing several layers of security. Except as required by law, VCT will not disclose your personal information to a third party.
7. How can I access my personal data? VCT does not provide study subjects direct access to the VCT database. You may contact VCT at any time to request your study history and to correct any information. You must be able to provide identification prior to the release of any information.
8. What are my choices to limit the use and disclosure of my personal information? To enroll in the clinical trial you will be required to provide the limited personal information described in item 2 above. If you choose not to participate, no personal information will be collected. Once your personal information has been entered, you may withdraw your personal identifiable information (name, date of birth, ID, and biometric information) from the VCT registry at any time without penalty or loss of benefits.
9. Is there an independent dispute and resolution body that will provide free of charge recourse to address any unresolved complaints I may have about VCT? The European data protection authorities (“DPAs”).
11. Can I invoke binding arbitration? Yes. In order to do so you must perform the following in accordance with the Privacy Principles: 1) first raise the issue directly with VCT and allow VCT 45 days to reply, 2) if the issue is not resolved by VCT you must then raise the issue with the Data Protection Authorities, 3) escalate the issue through the Data Protection Authority to the Department of Commerce and permit the Department of Commerce to resolve the issue. Arbitration may not be invoked if you have previously claimed the same violation and it has been subject to binding arbitration, was the subject of a final judgement, or if it was previously settled.
12. Can VCT disclose my personal information to law enforcement or similar agencies? Yes. Under various federal and state laws, VCT must share user information to comply with court orders and subpoenas. When possible, we notify the user in order to give them the opportunity to object. Under the Electronic Communications Privacy Act (ECPA), VCT may not voluntarily share most user information with law enforcement.
13. What is VCT’s liability when it comes to the transfer of my personal information? VCT does not transfer your personal information. Once obtained your personal information is de-identified upon entry into the VCT database. Reporting is in aggregate and de-identified form. De-identified information, including our anonymous logs data, is restricted to approved research site user access and cannot be shared with third parties. Research site users are within the same country as the study subjects. If a site user requires assistance that necessitates a member of VCT to review the personal information, this review occurs in the United States, but the data is not transferred.