Privacy Notice

Who We Are

This Privacy Policy is issued on behalf of the TPS, which includes Transformative Pharmaceutical Solutions, LLC, headquartered in Pennsylvania and registered in the state of Delaware in the United States; Transformative Pharmaceutical Solutions UK Limited with registered offices in the United Kingdom; and Transformative Pharmaceutical Solutions Ireland Limited, with registered offices in Ireland.

TPS (which may be referred to as “we,” “us,” or “our” in this Privacy Policy) is the controller responsible for the personal data we collect and process directly from you in accordance with this Privacy Policy. TPS is the processor when TPS customers, as data controllers, use our services and direct processing of your personal data when using our products and services.  When you use the TPS website and communicate directly with TPS, personal data is processed as described in this Privacy Policy.  When TPS processes personal data on behalf of a data controller, TPS complies with the direction of the data controller as required by Applicable Data Protection Law.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set forth in the “Contact TPS” section below.

 

Collecting Personal Information

What is personal data?

Personal data is information that relates to an identified or identifiable natural person (this means an individual human being).  Anonymous information, where it is not possible to determine to whom the data relates, is not considered personal data.

What personal data do we collect about you?

In providing outsourcing and resourcing solutions for clinical and site operations, we collect, use, store, and transfer different kinds of personal data that are provided to us. In general, you can visit the TPS website without revealing who you are and without disclosing any of your personal information. However, there may be times when TPS will require personal information about you or when you wish to disclose such personal information to us. Such personal information is obtained when submitted by you and is subject to the provisions set out in this Privacy Policy.

TPS also provides specific information about the personal data collected in Appendix 1, which follows this Privacy Notice. The types of data we may collect can be grouped as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, title, education, work history, therapeutic experience, company name, Employee Identification Number (if applicable), and any other identity data potentially found on a curriculum vitae or resume provided to us.

As a clinical research resourcing company, we also collect personal data that is intended for use in support of research studies. This information is not generally collected through our website and will only be collected from those who participate in the staffing, resourcing, management, and oversight of personnel for research studies. This information is usually provided directly by the individual and may be provided by customers in order to conduct the legitimate interests of the business.

Contact Data includes address, email addresses, skype address and telephone numbers which you may provide to us. This data is generally in the form of a business contact.

Financial Data includes Employee Identification Numbers, Tax ID Numbers, social security numbers, bank accounts and wiring information used in order to pay employees and contractors who work for us.

Transactional Data includes details about payments to and from you and other details of services you have provided for us, including wiring information, if applicable.

Usage Data includes information about how you use our website and our services, if applicable.

Marketing and Communications Data includes your preferences in receiving marketing or job opportunity or company update information from us and our third parties, and your communication preferences (i.e., opting out). This information may be collected either online or offline.

Special Category Data includes data relating racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.  TPS will only process Special Category with the explicit consent of the individual or when required by applicable European Union or member state law.  TPS generally collects this type of data when an individual submits an application for employment. 

TPS strives to respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject (the individual).

Information you provide to us:  The information you provide to us may include part or all of the data categorized above under Identity Data, Contact Data, Financial Data, and Special Category Data, including personal data provided when you:

• Request information about TPS or inquire about a job opportunity or posting;

• Contact us, in writing, by email or other electronic means, TPS may keep a record of that correspondence;

• Inquire about a job opportunity from our site’s postings or via email;

• Subscribe or respond to our marketing campaigns, subscribe to TPS emails and/or newsletters;

• Speak with a TPS-representative to discuss relevant work experience and area of residence to ensure alignment with job opportunities and customer requirements;

• Provide feedback or contact us to discuss a clinical trial, project or assignment in which you are engaged with TPS;

• Engage with us and execute onboarding documents, including your curriculum vitae, executed contract agreements, emergency contact forms, banking data, wiring instructions and/or specifically required documentation as per applicable law.

Information we collect about you: With regard to each of your visits to our website or “Our Sites” (Our Sites can include our presence on social media platforms, including Facebook and LinkedIn, among others, which are governed by the Privacy Policies of their respective platforms), we may automatically collect the following information:

• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and

• Information about your visit, including the full uniform resource locators (URL) clickstream to, through and from Our Sites, (including date and time); pages you viewed or information for which you searched; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

• Information we receive from other sources, such as LinkedIn, or other publicly available websites or social media sites, prior to your engagement with us.

We collect the following information only when you contract to provide services to TPS:

• Reference checks from individuals you refer;

• Debarment Status – we perform debarment checks to ensure you have not been debarred from regulatory authorities;

• Per our customer’s hiring requirements and based on a signed acknowledgement form you provided for release: background check data which could include criminal, employment, education and drug testing;

• Your Good Clinical Practice (GCP) scores, if applicable to the position, from the GCP test you were asked to complete and successfully pass;

• Contract services agreement and addendum outlining the terms of assignment or scope of work;

• Emergency contact information;

• Direct deposit and bank information, International Payment Wiring form;

• Your address;

• Employee Identification Number/Social Security Number;

• Company/Corporation Name and registration information.

 

Using Your Personal Information

How will we use the information about you?

We use the personal data you provide, and that we collect about you in order to:

• Manage our relationship and engagements with you before, during, and after being engaged by TPS;

• Communicate with you in response to queries, or to check in with you if you are actively on assignment;

• Provide you with information about us and our services, including job opportunities (“Services”),

• Provide the Services to you on request, and to fulfil our obligations in respect of the same;

• Ensure appropriate, timely and accurate compensation and payment logistics should you be engaged by us;

• Maintain and administer our website and any other online or social media channels, platforms or Our Sites that we operate, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

• Improve Our Sites, to ensure content is presented in the most effective manner for you and for your computer or device;

• As part of our efforts to keep Our Sites safe and secure, and to prevent fraud;

• Measure or understand the effectiveness of marketing activities we serve to you and others, and to deliver relevant marketing to you;

• Provide suggestions and recommendations to you and other users of Our Sites about services and opportunities which may interest you or them.

We may collect details about your use of Our Sites for the purposes of aggregate statistics or reporting purposes. Aggregated information (your data combined with other people’s data) may come from your personal data.  To the extent the aggregated information could still be considered personal data, we will continue to process it in accordance with this Privacy Policy.

Our legal basis for processing your data. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where the processing is necessary for the performance of a request or contract you have entered into with us, including a request for one of our Services;

• Where we need to comply with a legal or regulatory obligation: (i) to assist the EMA, FDA or other public authority upon inquiry (ii) to identify you when you contact us; or

• Where the processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Such legitimate interests may include:

  • Correspondence or communication with you, i.e. keeping you up to date on the latest announcements, updates, job opportunities, events;

  • Improving our candidate or user relations;

  • Compliance with a request from you in connection with the exercise of your rights;

  • For the management of queries, complaints or claims; and

• For the establishment and defense of our legal rights.

TPS may process personal data using more than one legal basis.  However, only one legal basis will be relied upon depending on the specific purpose for which we are using your data. Please contact TPS using the details provided in the “Contact TPS” section below if you require details about the specific legal ground upon which TPS is relying to process your personal data on any given occasion.

TPS will only use any of your special categories of personal data in the following circumstances:

• When you have provided your explicit consent;

• When processing of your data is carried out in the course of legitimate activities with appropriate safeguards;

• When the processing relates to special categories of personal data that you have made public;

• If processing is necessary for establishing, exercising, or defending legal claims; or

• If the processing is necessary for reasons of substantial public interest as provided in or EU or EU member state (European Union country) law.

Considering the purposes for which TPS intends to use your personal data, with due regard to Applicable Data Protection Law, TPS does not anticipate being required to obtain your consent to process your personal data.  Instances where TPS will obtain consent, as necessary, may include where TPS intends to use your personal data to provide you with marketing or information about services which may be of interest to you. For more information on this please see the “Marketing” section below. In the event TPS intends to use your personal data for other specific purposes requiring your consent, TPS will contact you to request your consent.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note, we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by Applicable Data Protection Law.

 

Website Cookies

TPS’s website utilizes cookies. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies:

• A persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by you before the expiry date;

• A session cookie, on the other hand, will expire at the end of your session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies you, but personal information that TPS stores about you may be linked to the information stored in and obtained from cookies.

Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

For further explanation of cookies, see https://gdpr.eu/cookies/.

We recommend all users clear cookies and cache regularly as a matter of good computer practice and to avoid browser/security issues.

 

 

 

What types of cookies do we use?

We use cookies on our website for two primary purposes:

• Functionality — We use cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and the location you are in. A mix of first-party and third-party cookies may be used.

• Advertising — We use cookies to collect information about your visit to our website, the content you viewed, and the links you followed, and we collect information about your browser, device, and your IP address. We sometimes share some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

 

Marketing

If you provide your prior consent, or where we are otherwise permitted to do so under Applicable Data Protection Law, we may also use your personal data to contact you by email and mail with details of services, including job opportunities, publications and related materials we think may be of interest to you.

TPS will only share your information with third parties for marketing purposes with your prior consent or where we are otherwise permitted to do so under Applicable Data Protection Law. In such cases, we may pass your personal data on to other companies, trade bodies or associations so that they may offer you their products and services.

You have a right at any time to stop us from contacting you or sharing your personal data for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us using the details set out in the “Contact TPS” section below.

Please note, where you opt out of receiving these marketing messages, this will not delete any personal data provided to us as a result of another transaction or interaction.

 

 

 

Disclosing Personal Information

We will not transfer, disclose, sell or distribute your personal data to third parties other than as set out in this Privacy Policy, unless we have your consent or are otherwise required or permitted to do so by Applicable Data Protection Law.

We may disclose your personal data:

• To any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) as reasonably necessary for the purposes set out in this Policy

• In connection with any ongoing or prospective legal proceedings

• To third parties as required for our everyday business purposes, including to our clients, related companies, our business partners, and technical services providers if applicable, including in order to provide you with the Services you request;

• to any of our employees, officers, insurers, professional advisers, agents, suppliers, or subcontractors as reasonably necessary for the purposes set out in this Policy

• Analytics and search engine providers that assist us in the improvement and optimization of the Sites;

• To third parties in the event we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

• If TPS or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;

• To competent authorities (including regulatory and tax authorities), courts and bodies as required by law; or

• To protect the rights, property, or safety of TPS and our members and non-members, or for internal investigations and reporting. This may include exchanging information with other companies and organizations for the purposes of fraud protection and reducing credit risk.

 

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Except as provided in this policy, TPS Global will not provide your personal information to third parties.

 

International Data Transfers

Where we are required to transfer your personal data out of the European Economic Area (“EEA”), we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries deemed to provide an adequate level of protection for personal data by the European Commission or the UK Government, whichever is applicable; or

• We will undertake the transfer on the basis of a specific contract approved by the European Commission/UK Government which give personal data the same protection it has in Europe/UK (“Model Form Clauses”). For further details, and a copy of the text of these Model Form Clauses see:

            For EEA: Standard Contractual Clauses (SCC) | European Commission (europa.eu)

            For UK: International data transfer agreement and guidance | ICO

 

Retaining Personal Information

How long will you use my personal data?

We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Notwithstanding the other provisions of this Section, TPS will retain documents (including electronic documents) containing personal data:

• To the extent that TPS is required to do so by law;

• If TPS believes that the documents may be relevant to any ongoing or prospective legal proceedings; and

• In order to establish, exercise, or defend TPS Global legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

For further information as to any specific retention periods that might apply to personal data we hold about you, please contact us using the details set out in the “Contact TPS” section.

In some circumstances you can ask us to delete your personal data: see the “Your Legal Rights” section below for further information.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research, marketing or statistical purposes. If we do that, we may use this information indefinitely without further notice to you.

 

Security of Your Personal Information

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, clients, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 

Your Legal Rights

In certain circumstances, you have rights under Applicable Data Protection Law in relation to your personal data.  In relation to certain rights we may ask you to confirm your identity and where applicable, to help us to search for your personal data.  Except in rare cases, we will respond to you within one month from either (i) the date we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request. 

You may have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the personal data’s accuracy; (b) where our use of the personal data is unlawful but you do not want us to erase it; (c) where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.  If you withdraw your consent, we may not be able to provide certain Services to you and we may need to suspend or terminate your access to Our Sites.  We will advise you if this is the case at the time you withdraw your consent.

• Complaining to the UK data protection regulator or the Data Protection Authority if you are concerned about the way we have processed your personal data. The Information Commissioner’s Office (“ICO”) website and the European Commission set out further details.

 

If you wish to exercise any of the rights set out above, please contact us using the details set out in the “Contact TPS” section below.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

Amendments

TPS Global may update this policy from time to time by publishing updates internally and on our website. You should check this page periodically to ensure they understand any changes to this policy.

 

Contact TPS

Transformative Pharmaceutical Solutions, LLC is based in the US and is the controller responsible for personal information that it collects and processes. If you have any questions or concerns regarding the way in which your personal information is used, please contact us via mail at 1777 Sentry Parkway West, Building 17, Suite 100, Blue Bell, PA 19422 marking your letter for the attention of the Privacy Officer. Our Privacy Officer can also be contacted at Privacy@tpsglobal.com.