Last Updated: May 24, 2021
Thank you for choosing to be part of our community at Clinical Consulting Services, LLC, doing business as CCS (“CCS”, “we”, “us”, “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org.
When you visit our website http://www.cssienroll.com (the “Website”), and more generally, use any of our services (the “Services”, which include the Website), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.
This privacy notice applies to all information collected through our Services (which, as described above, includes our Website), as well as, any related services, sales, marketing or events.
Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.
TABLE OF CONTENTS
- What Information Do We Collect?
2. How We Use Your Information
3. Will Your Information Be Shared with Anyone?
5. Is Your Information Transferred Internationally?
6. How Long Do We Keep Your Information?
7. How Do We Keep Your Information Safe?
8. Do We Collect Information from Minors?
9. What Are Your Privacy Rights?
10. Controls for Do-Not-Track Features
11. Do California Residents Have Specific Privacy Rights?
12. Do We Make Updates to This Notice?
13. How Can You Contact Us About This Notice?
14. How Can You Review, Update or Delete The Data We Collect From You?
- What Information Do We Collect?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Website or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. The personal information we collect may include the following:
Personal Information Provided by You. We collect names; phone numbers; email addresses; mailing addresses; contact preferences; health information; and other similar information.
On some Website pages and Apps you can register to receive customized information. This information is generally collected on ‘Contact Us’ forms where you may choose to be contacted by CCS. The personal information collected in these cases include your name, title, company, address, and contact details and e-mail address.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Website.
We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.
- How Do We Use Your Information?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
Investigators, clinical site study team members and other healthcare professionals (HCPs)
We collect the names, contact details, and professional information of clinical trial investigators, study researchers, and other HCPs for the purpose of identifying and assessing suitability to assist in clinical trials and research studies and to provide services. We collect your personal data when you provide it to us directly, for example such as when you express or register an interest to participate in a study through our Websites, and also, either directly or indirectly, from publicly available sources, such as websites, directories and industry networks etc. For further information on our collection activities and uses of personal information through our Websites please refer to “Website Visitors and Mobile Application Users”. If you subsequently participate in a trial or study CCS manages or provides services for, we will also collect information relating to the involvement and performance of HCPs. Further information is available in our Site Data Protection Notice and Consent Form available here .
Study Participants in Studies sponsored by CCS clients
CCS is a global Patient Recruitment Organization that provides services to support the clinical trials and medical research studies of Sponsors or CROs. Depending on the Recruitment services CCS is providing to a Sponsor or CRO we process personal data relating to study participants on behalf of our Sponsors and in accordance with contracts with and instructions from the Sponsor. CCS may also, to the extent necessary, process personal data relating to study participants’ spouses, partners, care givers, and relatives if they are involved in the participants’ participation in a study e.g. parents involved in decision making of child participants or spouses involved in the care of an incapacitated participant.
In relation to CCS’ delivery of Patient Recruitment services to Sponsors, the Sponsor is in control of how and why your personal data is processed and as such is the “controller,” and CCS is a “data processor”. CCS’ role as processor may include the transfer of such personal information to the applicable Sponsor, its corporate affiliates, business partners and third-party service providers performing services related to the study.
The purposes for which study participant personal data will be used by Sponsors and CCS will depend on the nature of the Sponsor’s study and will be addressed in study specific documentation and in particular in study participant consent documentation that is reviewed prior to participation in a study. As such, study participants should look to that documentation to understand how their personal data is processed in relation to a study. To provide a general overview, personal data will typically be processed for the purposes of assessing eligibility to participate in a study, administering the study, monitoring the study, analyzing data to assess the overall safety and effectiveness of the therapy that is the subject of the study, and drawing conclusions regarding the effectiveness and viability of the therapy that is the subject of the study.
Participants in CCS Patient Databases
Certain CCS services involve the development and maintenance of databases of persons who may be eligible to and may wish to participate in clinical trials and medical research studies (“Patient Recruitment Databases”) managed by Sponsors. Once a person is recorded in CCS’ Patient Recruitment Databases, CCS may contact them for further screening and potentially refer them to potentially suitable clinical trials or research studies matched to their areas of medical interest.
In order to match such persons’ entered into Patient Recruitment Databases to appropriate clinical trials or research studies CCS will, on a need to know basis, request, collect and process suitable personal data on the basis of the person’s explicit consent, such as names, addresses and contact information, which may be collected on voice recordings, as well as sensitive personal information.
Examples of sensitive personal data we collect include:
- Healthcare information e.g. height and weight, physical and mental health or conditions, medical records, disabilities
- Race and ethnicity information
- Areas of interest in medical research
- Genetic data
Your personal information may be collected through either volunteering it through one of our Websites or in the context of live interview or screening telephone calls or meetings with CCS representatives. Please be aware that by providing your personal information you consent to a member of our team contacting you directly by way of following-up with you, including contacting you directly by telephone or other means, including SMS text messages, and adding your personal information to our Patient Recruitment Databases.
In this context, CCS is the controller of the personal data.
Uses of your personal data. As discussed earlier, the main purpose of collecting personal data in Patient Recruitment Data Bases is to match patients to suitable clinical trials and research projects based on the individuals’ areas of medical interest. For example, if an individual with Alzheimer’s expresses a desire to participate in clinical research or avail of novel treatments for Alzheimer’s or associated symptoms:
- they may volunteer their contact information and relevant health information to CCS for inclusion in a Patient Recruitment Database
- an CCS client or Sponsor who is developing new treatments may engage CCS to help refer interested potential patients who are willing to try an experimental treatment in a controlled clinical trial environment
- if the CCS client’s or Sponsor’s clinical trial eligibility criteria align with the individual’s information stored in our Patient Recruitment Database and it is being conducted within their geographical reach, we can contact the individual and refer them to a suitable clinic where medical screening of potential clinical trial participants is being performed. Please be aware the screening process is generally done face-to-face and will require you to supply additional personal information to us and/or the parties managing the study and separate privacy terms may apply to additional personal information collected at that stage.
CCS may use your Personal Information to respond to subsequent requests you may make of us, and from time to time, we may refer to your personal information to better understand your needs and how we can improve our websites, products and services on the basis of our legitimate interests in doing so. We may enhance or merge your personal information with data obtained from third parties for the same purposes. Any other information transferred by you which cannot be used to identify you (and which, therefore, does not constitute personal information) may be included in databases owned and maintained by CCS. CCS may also use anonymized personal data to run general statistical analysis in support of patient recruitment and similar analytical purposes.
- Will Your Information Be Shared with Anyone?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Is Your Information Transferred Internationally?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in United States. If you are accessing our Website from outside United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above), in United States, and other countries.
If you are a resident in the European Economic Area, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.
European Commission’s Standard Contractual Clauses:
We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA in accordance with European data protection laws and regulations. Our Data Processing Agreements that include Standard Contractual Clauses can be provided upon request/are available here. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.
WHAT INFORMATION DO WE COLLECT? To learn more about the types of personal data Clinical Consulting Services, LLC collects.
HOW DO WE USE YOUR INFORMATION? To learn more about the purposes for which Clinical Consulting Services, LLC collects and uses personal information about you.
WILL YOUR INFORMATION BE SHARED WITH ANYONE? To learn more about the type or identity of third parties to which Clinical Consulting Services, LLC discloses personal information, and the purposes for which we do so.
WHAT ARE YOUR PRIVACY RIGHTS? To learn more about the right of individuals to access their personal data.
- How Long Do We Keep Your Information?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than 1 year.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
- How Do We Keep Your Information Safe?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.
- Do We Collect Information from Minors?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at email@example.com.
- What Are Your Privacy Rights?
In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website. To opt-out of interest-based advertising by advertisers on our Website visit http://www.aboutads.info/choices/.
- Controls for Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
- Do California Residents Have Specific Privacy Rights?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a “resident” as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as “non-residents.”
If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name
B. Personal information categories listed in the California Customer Records statute
Name, contact information, education, employment, employment history and financial information
C. Protected classification characteristics under California or federal law
Gender and date of birth
D. Commercial information
Transaction information, purchase history, financial details and payment information
E. Biometric information
Fingerprints and voiceprints
F. Internet or other similar network activity
Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements
G. Geolocation data
H. Audio, electronic, visual, thermal, olfactory, or similar information
Images and audio, video or call recordings created in connection with our business activities
I. Professional or employment-related information
Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us
J. Education Information
Student records and directory information
K. Inferences drawn from other personal information
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at firstname.lastname@example.org, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.
Clinical Consulting Services, LLC has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding 12 months. Clinical Consulting Services, LLC will not sell personal information in the future belonging to website visitors, users and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data – Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.
Right to be informed – Request to know
Depending on the circumstances, you have a right to know:
- whether we collect and use your personal information;
- the categories of personal information that we collect;
- the purposes for which the collected personal information is used;
- whether we sell your personal information to third parties;
- the categories of personal information that we sold or disclosed for a business purpose;
- the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
- the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
- you may object to the processing of your personal data.
- you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data.
- you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- you may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.
- To exercise these rights, you can contact us by email at email@example.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
- Do We Make Updates to This Notice?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
- How Can You Contact Us About This Notice?
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Data Protection Officer, by email at firstname.lastname@example.org, by phone at 866.277.4888, or by post to:
- Clinical Consulting Services, LLC
- Data Protection Officer
- 1099 Winterson Road, Suite 136
- Linthicum, MD 21090
- United States
- How Can You Review, Update, Or Delete the Data We Collect From You?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here. We will respond to your request within 30 days.