Privacy Policy
Clinitrials recognizes the need for compliance with its obligations under the Privacy Act 1988 and the Australian Privacy Principles prescribed under that Act (“the Privacy Act”).
Introduction
Clinitrials provides support services for the conduct of clinical trials. We collaborate with clinicians, research organisations and research sites to facilitate the successful delivery of clinical trials/ research. The purpose of this document is to provide you with information about how Clinitrials collects, holds, uses and discloses personal information to carry out these functions.
When individuals register to participate in a clinical trial this information is held in a database by Clinitrials . We ask your permission to include your details. The database allows Clinitrials or its affiliates to contact those who register for a clinical trials to learn about potential clinical trials or medical research projects to which they may be suited to.
Definitions
In this privacy policy, personal information and sensitive information (a sub-set of personal information), have the same meanings as defined in subsection 6(1) of the Privacy Act.
Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
whether the information or opinion is true or not; and
whether the information or opinion is recorded in a material form or not.
Sensitive information is a type of personal information and includes information about an individual's:
health (including predictive genetic information)
racial or ethnic origin
political opinions
membership of a political association, professional or trade association or trade union
religious beliefs or affiliations
philosophical beliefs
sexual orientation or practices
criminal record
biometric information that is to be used for certain purposes
biometric templates.
Health information means:
information or an opinion about:
the health, including an illness, disability or injury, (at any time) of an individual; or
an individual’s expressed wishes about the future provision of health services to the individual; or
a health service provided, or to be provided, to an individual;
that is also personal information;
other personal information collected to provide, or in providing, a health service to an individual;
other personal information collected in connection with the donation, or intended donation, by an individual of his or her body parts, organs or body substances;
genetic information about an individual in a form that is, or could be, predictive of the health of the individual or a genetic relative of the individual.
De identified information means personal information that is no longer about an identifiable individual or an individual who is reasonably identifiable.
Personal information that has been de-identified is no longer considered to be personal information. Similarly, personal information that is in the public domain is no longer considered to be personal information.
Collection of Personal Information
This includes personal information provided by you directly (whether face-to-face, by telephone, email, online forms, post, through social media or by communicating with us in any way), when you make an enquiry through our Website or over the phone or when you communicate with us during an appointment, you are voluntarily giving us the personal information that we collect.
We collect personal information in a variety of ways, including:
Directly: We collect personal information which you directly provide to us.
Indirectly: information which you indirectly provide to us while interacting with us, such as when you use our Website, in emails, over the telephone and in your online enquiries.
From third parties: We collect personal information from third parties, such as details of your use of our Website from our analytics and cookie providers and marketing providers.
The collection of personal and sensitive information is a necessary part of ensuring that:
we are able to provide you with information about clinical trials at any of the Clinitrials sites;
keep you up to date with events or new clinical trial opportunities
only suitable participants are included in clinical trials;
we are able to communicate with you in a timely manner and answer questions you may have
we comply with our legal obligations
The type of personal information we collect includes
name
sex
date of birth
address
contact details - telephone numbers, email address
In addition to participate in a clinical trial or if you want information about a clinical trial, we may collect the following
Drivers license, Medicare number and other identifying documentation
your sensitive information including health information provided by you and /or requested by us and provided by you or a third party
The content of any electronic forms you submit by means of this website or social media requesting us to register your interest as
seek information or participate in a clinical trial(s)
health professional requesting information about clinical trials
health professionals referring an individual participant for a clinical trial ( who has consented to the referral )
whether general or in relation to a specific trial appearing on the Clinitrials website may include but is not limited to:Clinitrials may also collect personal information (including sensitive information) about you from publicly available sources.
Use and Disclosure of your Personal Information
Use of Your Personal Information
Clinitrials may use or disclose personal information to assists with an individual’s request to be considered for participation in a clinical trial or being referred for a clinical trial or as part of the business and as permitted by law. Such purposes include the following:
to verify your identity
establish and maintain a database of potential participants for clinical trials;
to provide a service to you , including matching potential participants with clinical trials and responding to enquires
to provide details to other consultants, health care providers, allied health providers, Clinitrials research sites or affiliate
to send you promotional information about our products and services and other information that we consider may be of interest to you
to establish and maintain a database listing of health professionals referring trial participants
for the specific purpose for which we have collected the information;
managing the services we provide;
enabling collaborators with Clinitrials to promote their clinical trials to those registered by means of the Clinitrials website;
purposes related to our research, planning, product and service development, security and testing;
purposes connected with the operation, administration, development or enhancement of this website;
where we suspect that fraud or unlawful activity has been, is being or may be engaged in;
meeting any legal and regulatory requirements we are subject to, or may be imposed upon Clinitrials;
Note; If you provide any Personal Information to us via our website or social media platforms (including email) or if we provide Personal Information to you by such means, all efforts will be made to maintain the privacy, security and integrity of your Personal Information, however this cannot be guaranteed during its transmission unless we have indicated beforehand that a particular transaction or transmission of information will be protected (for example, by encryption).
Disclosure of Your Personal Information
We will not disclose your personal information to unauthorised personnel at any time. Where the Privacy Act permits it, Clinitrials may disclose your personal information to third parties. Third parties that we may disclose your personal information to include:
entities providing services to Clinitrials including legal services, financial services, data providers, storage services and mailing houses;
Research sites affiliated with Clinitrials
Third parties who assisting with the conduct of clinical trials such as
· laboratory, imaging or other health care providers in order to complete request/ referral forms for the service to be provided for the trial
· pharmacy to complete details of your trial prescription(s)
· Government agencies as required by law e.g. If you participate in a vaccine trial, details may be submitted to the Australian Immunisation Register (AIR).
Health care providers who provide a service to assist with the conduct of a clinical trials
IT service providers, data storage, web -hosting and server providers
government regulatory bodies in Australia and overseas;
entities who may wish to be involved in our business, or acquire an interest in our business;
third parties you authorise to act on your behalf or that are otherwise connected with you (such as your legal representative or other authorised agent or attorney); and
law enforcement agencies.
to provide access for an you to use an electronic device or app required as part of a clinical trial (name and email only) as part of the registration process.
How your data is collected, used and stored within the app or electronic device is outlined in the privacy statement and terms and conditions which you agree to within the app or electronic device. Clinitrials is not responsible for use of electronic devices or apps on your personal device. If you access electronic devices or apps, you do so at your own risk, and Clinitrials makes no representations or warranties regarding third parties’ privacy practice . Clinitrials encourages you to read the privacy collection statements and privacy policies of every electronic device or app you use.
A variety of external service providers assist Clinitrials to operate our business and to provide you or someone else on your behalf with the information and services sought. Some of these service providers may be located overseas, and they include Best Practice Software Pty Ltd (located in Australia), and Microsoft (located in the USA).
Some of these entities may not be located in Australia, and may not have an Australian link. Therefore, we may supply information to that provider who may be overseas. By providing Clinitrials with your personal information, you consent to the disclosure and transfer of your personal information outside Australia but only in the manner permitted under this Privacy Policy.
Access to Clinitrials records and disclosure of your personal information is limited as above and to those who have an operational need or who have legislative authority. These include but are not limited to:
Clinitrials personnel or clinitrials affiliate sites , medical staff and consultants , allied health providers, heath care providers required for a specific clinical trial such as pharmacy, laboratory staff.
auditors appointed by sponsors, certifying authorities or ethics committees;
the Commonwealth Ombudsman;
the Office of the Australian Information Commissioner;
Administering Institutions;
the Australian Taxation Office; and
the Australian Federal Police.
Clinitrials will not be taken to have breached its obligations under this policy or the Privacy Act where:
a person has consented to the use or disclosure of their personal information;
a purpose for which the personal information is to be used is directly related to the purpose for which it was collected;
a person would reasonably expect, or has been told, that personal information may be published or passed to other certain individuals, bodies or agencies (e.g. if requested by the Australian Taxation Office);
the disclosure of personal information:
is required or permitted by law; or
will prevent or lessen a serious and imminent threat to somebody’s life or health,
there is a reasonable belief that the disclosure of the personal information is for a purpose directly related to the enforcement or investigation of a possible breach of a Commonwealth, State or Territory law; or
the personal information is in the public domain.
Email addresses provided by means of this site will only be used to respond to specific user registrations by any of the Clinical affiliated sites and will not be disclosed to any other party without your knowledge, consent, or direction unless required by law.
Access, Correction and Removal of your Personal Information
Access to your Personal Information
You have specific rights under Australian Law to request access to and correction of personal information that Clinitrials holds about you.
You can request access to the personal information that Clinitrials holds about you subject to certain exceptions under the Privacy Act. You are also entitled to specify how you wish to access your personal information, so long as this is reasonable and practicable.
Given that the information we will have is of a sensitive nature we will need to verify the identity of anyone requesting access to your personal information, so as to ensure that we do not provide that information to a person or people who do not have the right to access that information. In furtherance of this objective we ask that any requests for information be as specific as possible so that we can accommodate your request. We will usually provide you with access within thirty (30) days of a request but in some circumstances it may take longer.
Please note that under Australian law, Clinitrials is entitled to refuse you access to your information in the following circumstances:
where access would be unlawful;
denying access is required or authorised by or under an Australian law or a Court / Tribunal order; or
access would prejudice enforcement activities or the taking of appropriate action in relation to unlawful activity or serious misconduct.
Correction or Removal of your Personal Information
Clinitrials takes every step that is reasonably practicable to ensure that the personal information we collect, use and disclose is accurate, complete and up to date. To facilitate this, please let us know if any of your details change or in the event you wish your personal information to be removed from our database as the Privacy Act gives you the right to request correction or removal of the personal information we hold or if that personal information is incorrect. In order to do so, please contact Clinitrials via our email at info@clinitrials.com.au.
Security and Storage of Personal Information
Clinitrials takes steps to protect the security of the personal information it holds. We may hold your information in paper or electronically.
Paper records are stored in locked rooms with limited access
Electronic database is stored on password protected servers
For further information on the way Clinitrials manages security risks in relation to personal information please contact us via email at info@clinitrials.com.au.
Internet and Marketing
Should you follow links to other sites from this website it is strongly recommended that you read the Privacy Policy of each site to familiarize yourself with its privacy practices. We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. We may use third parties to collect and process data, such as Google Analytics , Facebook Pixel or other relevant advertising / analytics businesses). To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us.
Updates
We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our Website. We recommend you check our Website regularly to ensure youare aware of our current Privacy Policy. Your continued use of our Services will indicate your acceptance of any amendments to this Privacy Policy.
Contact Us
If you have any queries, concerns or complaints about this Privacy Policy or the way in which we handle your personal information, or if you would like to make any recommendations to improve the quality of our Privacy Policy, please contact us via our email at info@clinitrials.com.au