Emerald ROW Newco Pte Ltd together with its subsidiaries worldwide (“George Clinical”, “We”, “Us” or “Our”) is committed to protecting and handling your (“Your” or “You”) Personal Information (including health and other sensitive information) in accordance with applicable privacy and data protection laws and regulations. We also comply with the International Conference of Harmonisation (ICH) Guidelines for Good Clinical Practice with respect to the use, protection and security of health information collected
This Privacy Policy – Public Statement (“Privacy Policy”) addresses the Personal Information We collect and how We process, handle and treat that information.
As a global business, George Clinical uses its best endeavours to collect, use, store, share, transfer, delete, and process Personal Information in a manner consistent with the laws and regulations of countries in which it does business.
Personal Information means any information about an identified or identifiable person. A reference to Personal Information includes “personal data” as defined in relevant privacy laws including the EU General Data Protection Regulation ((EU) 2016/679) (GDPR).
Sensitive or Health Information is a type of Personal Information.
When we collect information that is not Personal Information or we aggregate or anonymise Personal Information such that it can no longer be used to identify you, we may use and disclose that information for any purpose, as unidentifiable data is not covered under privacy or data protection laws.
We may collect Personal Information when you request information from us, when you provide us your information, when you access our website and when you enquire or apply for career opportunities.
We only collect Personal Information reasonably necessary for one or more of Our functions or business activities.
We do not sell Your Personal Information.
More details about the Personal Information We collect (and why) are provided below.
Investigators, Clinical Site Team Members and other Healthcare Professionals (HCPs)
We collect names, contact details, and professional information (for example resumes) of clinical trial investigators, researchers, consultants, and other HCPs for the purpose of identifying and evaluating Your suitability to assist in clinical trials and human research studies and to provide related services and for the evaluation and operation of clinical trials or human research studies You are working on with Us.
Clinical Trial Participants in Clinical Trials Sponsored by Clients
We provide services to sponsor’s clinical trials and human research studies. We process Personal Information of subjects participating in these clinical trials on behalf of sponsors in accordance with their written instructions and Our legal contracts with them. The purposes for which clinical trial participant Personal Information will be used by sponsors and Us will depend on the nature of the clinical trial and will be more specifically dealt with in the specific clinical trial documentation.
In general, any Personal Information is collected and processed for the purposes of assessing eligibility to participate in a clinical trial, administering and monitoring the clinical trial, medical research and analysis related to the clinical trial, to comply with laws and regulatory guidelines, or to substantiate the findings and publication of research results.
We may collect Personal Information from You when You enquire or apply for career opportunities with Us, either as an employee, contract staff, intern, or as a professional working with Us.
Such Personal Information may include Your name, address, contact information, photo, education history, past work experience, references, copies of identification documents, professional qualifications, and registrations. We will generally collect Personal Information directly from You, however We may use other sources such as recruitment agencies, publicly available websites, business partners, or institutions that You are affiliated with. We may also collect Your Personal Information from third-parties (e.g. referees) as part of Our assessment and recruitment process.
We may hold and use Your Personal Information for administrative, human resources and management purposes, complying with Our legal and regulatory obligations, recordkeeping in relation to hiring and recruiting and conducting background history and criminal checks as permitted by applicable law.
We may also use Your Personal Information to consider You working or collaborating with Us for future opportunities, or to recommend You to other organisations, research institutions, collaborators or sponsors only if You consent to this.
You may request that We do not contact You and delete Your Personal Information if You are no longer interested in opportunities with Us.
As part of the ordinary course of Our business operations, We may collect and record Personal Information from Our dealings with partners, business alliances and service providers. Such information is collected for administrative, management, and audit purposes.
We may collect Personal Information (e.g. name and contact details) from those who contact Us (by phone or in person) or access Our websites Personal Information. Such information is collected in order to communicate with you and improve Our services.
When accessing Our websites, We may make a record of part of Your user service address and internet provider name and address, the date and time of Your visit, the pages You accessed and any documents downloaded, any website visited prior to accessing Our site and the type of browser used. We do not record Your IP address.
This information (which is unlikely to contain Personal Information) is collected to monitor the activity on Our websites (including the popularity of certain pages and information presented on Our websites, and linkages to information), to consider improvements to the delivery, presentation and type of information on Our websites (including cost/benefit analysis) and ensure the protection of Our intellectual property and reputation.
Our websites do use cookies, which are small text files that are stored in Your local browser cache when You visit a website. Using cookies makes it possible to recognise the visitor’s browser in order to optimise the particular website and simplify its use. Information collected via cookies is not used by Us to determine the personal identity of a visitor. Most browsers are set up to accept these cookies automatically. You can deactivate the storing of cookies or adjust Your browser to inform You before a cookie is stored on Your computer.
We may share Your Personal Information with agents, contractors or partners of George Clinical in connection with services that these entities perform for, or with, George Clinical. These entities through Our contracts with them which offer an equivalent level of protection are prohibited from using the Personal Information in any manner other than to provide services to or for George Clinical, or services for the alliance in which they and George Clinical are engaged. For example, We may provide Your Personal information to these entities for data processing services, for hosting Our databases, such as SalesForce.com, IBM and other similar service providers.
We may store Your information locations where We or Our service providers maintain servers. These may include in Australia, the United States, European Economic Area (EEA). We partners to agree to standard contractual clauses and other mechanisms to protect such Personal Information in compliance with all applicable privacy and data protection laws.
We store Personal Information in paper-based and electronic records and systems.
Personal Information collected in paper-based documents may be converted to electronic form for storage (with the original paper-based documents either archived or securely destroyed).
We will only retain Your Personal Information for as long as reasonably necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain Your Personal Information for a longer period in the event of a complaint or if We reasonably believe there is a prospect of litigation in respect to Our relationship with You.
To determine the appropriate retention period for Personal Information, We consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of Your Personal Information, the purposes for which We process Your Personal Information and whether We can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Our staff must comply with privacy and confidentiality terms as part of their employment with us. To be an approved third-party of George Clinical, that party must be subject to similar privacy and confidentiality laws or have a professional and/or contractual obligation of confidence.
We may disclose Your Personal Information across international borders. As a global entity, we have employees, agents, service providers, collaborators and research partners in many countries including Canada, the United Kingdom, the European Union, Asia Pacific, China and the Americas.
George Clinical will comply with all legal obligations relating to cross border transfer of your Personal Information.
Your Personal Information may be disclosed to third parties as part of research trials and studies. Generally however, trial participant’s Personal Information will be de-identified (or aggregated with others) before disclosure. Where Personal Information is shared with third parties, this will be subject to contracts we have in place with those organisations offering an equivalent level of protection.
We will only use Your Personal Information when the law allows Us to.
Most commonly, We will use Your Personal Information in the following circumstances:
Please contact Us should You require any additional information about the legal bases We rely on for any specific processing activities that involve Your Personal Information.
We use appropriate physical, organisational, technical and security measures to protect Your Personal Information from misuse, interference, accidental loss and destruction, and from unauthorised access, alteration and disclosure.
In addition, we limit access (by physical and technical safeguards) to your Personal Information to those staff, related parties, and approved third-parties (e.g. agents, service providers, collaborators and research partners) who have a business or legal need to know.
We have also put in place procedures to deal with any suspected data breach and We will notify You and any applicable regulatory or supervisory authority of a suspected breach where We are legally obliged to do so.
You have rights in respect of your Personal Information. These may include:
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Rights |
What does this mean? |
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The right of access |
You have the right to request access to your Personal Information that we hold about you. |
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The right to rectification |
You are entitled to request corrections to the Personal Information that we hold about you if it is inaccurate or incomplete. |
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The right to erasure |
This is also known as “the right to be forgotten” and enables you to request the deletion or removal of your Personal Information if there is no compelling or legal reason for us to keep using it. |
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The right to restriction of processing |
You have the right to ask us to suspend the processing of Personal Information about you, for example if you want us to establish its accuracy or the reason for processing it. |
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The right to object to processing |
You have the right to object and ask us to stop processing your Personal Information. |
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The right to lodge a complaint |
You have the right to lodge a complaint about the way we process your Personal Information with the relevant supervisory authority. |
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The right to request transfer |
You have the right to request us to transfer Personal Information that we hold about you to another party, in a machine readable format. |
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The right to withdraw your consent |
You have the right to withdraw your consent to us processing your Personal Information. |
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The right to seek explanation of how we process your Personal Information |
We will explain how your Personal Information is processed, however if you do not understand, you have the right to seek further explanation |
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The right to opt out of sale |
We do not sell identifiable information about individuals involved in clinical research studies |
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The right to non-discrimination |
We will not discriminate against you for the exercise of your privacy rights |
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The right to automated decision making |
You have the right to not be subject to a decision based solely on automated processing (ie processing without human intervention). |
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The right to know |
You have the right to request that we disclose certain information about our collection and use of your Personal Information over the past twelve months |
Please note, these rights are not absolute and may not apply in all circumstances, but We will do Our best to assist You.
Where lawful and practical, You will be given the option to deal with Us without identifying yourself or by using a pseudonym (e.g. when inquiring about the activities that George Clinical undertakes).
You may request access to, or seek correction of, Your Personal Information that is held by George Clinical, or exercise other rights, by writing to gcprivacy@georgeclinical.com, or if You are located in the European Union You may also write to the Data Protection Officer at George Clinical Netherlands BV of Jan van Galenstraat 335 1061AZ Amsterdam, Netherlands.
You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, We may charge a reasonable fee if Your request is unfounded, repetitive or excessive. Alternatively, we may also refuse to comply with your request in these circumstances.
We will confirm receipt of your request and provide an estimate of when We will respond. We will respond to Your request within one (1) calendar month.
Please set out Your complaint in writing to: gcprivacy@georgeclinicalcom.
Please provide sufficient information, so that the Data Protection Officer or the Privacy Officer can consider Your concerns and contact You. We will respond to Your complaint within one calendar month.
If You are located in the European Union you may also write to the Data Protection Officer:
Address: George Clinical Netherlands BV of Jan van Galenstraat 335 1061AZ Amsterdam, Netherlands
Email: DPO@georgeclinical.com
If You are not satisfied with Our response, or You consider that We may have breached our legal obligations, You are entitled to make a complaint to the competent authority in the country in which You are located.
This Policy was last updated in July 2024. We may amend this Privacy Policy from time to time.
The following information supplements the Privacy Policy and applies solely to consumers who reside in the State of California (“California Privacy Statement”). For this purpose, a “consumer” is a natural person who resides in California.
The purpose of this California Privacy Statement is to provide You specific information required by, and ensure Our compliance with, the California Consumer Privacy Act of 2018 (CCPA). For the purpose of the CCPA, any information which identifies or is reasonably capable of being linked, directly or indirectly, with a particular consumer is Personal Information. Personal Information does not include de-identified or aggregated information. Any terms defined in the CCPA have the same meaning when used in this California Privacy Statement. This statement does not apply to any workforce related Personal Information collected from George Clinical employees in the State of California.
Most of the Personal Information that We capture in the course of Our business operations is not subject to the CCPA. As a CRO, We are not a Business Associate under the Health Insurance Portability and Accountability Act (HIPAA). Where we collect and maintain Personal Information in connection with human research or clinical trials, this information is subject to informed consent being provided by You, and is not subject to CCPA.
In particular we may have collected the following information from You in the last 12 months:
We may use this Personal Information as set out in our Privacy Policy. We will not collect additional Personal Information or use the Personal Information we have for unrelated or different purposes without first obtaining Your consent.
We may share Your Personal Information with third parties as set out in Our Privacy Policy. Where Personal Information is shared with third parties, this will be subject to contracts we have in place with those organisations offering an equivalent level of protection.
We do not sell any Personal Information.
Over the last 12 months, We may have disclosed Personal Information for a business purpose to the following categories of third parties:
You are entitled to exercise any of the rights set out above in the Privacy Policy in relation to Your Personal Information. We will not discriminate against You for exercising any of those rights.
Under the CCPA, requests for Personal Information may only be made a maximum of twice per 12 months period.
If you have any questions or concerns about George Clinical’s Privacy Policies and practices, please contact us at:
