Quintiles is a fully integrated biotechnology and pharmaceutical services provider offering clinical, commercial, consulting and capital solutions. Quintiles complies with both the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Quintiles has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Quintiles' certification, please visit http://www.export.gov/safeharbor/. Quintiles intends that its corporate privacy policy and standard practices and procedures will ensure timely compliance with all international laws and regulations, including, for example, the European Union’s Data Protection Directive (EUDP), Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), Japan’s Personal Information Protection Action (PIPA), and the U.S. Health Insurance Portability and Accountability Act (HIPAA), as applicable. To monitor implementation of the company's global policy for the protection of individually identifiable information, Quintiles has chartered the Council on Data Protection (CODP), which serves as Quintiles’ “privacy office” and internal privacy board. The Council includes members and advisors from a representative cross-section of operations and across global geographies and lines of business, including the company's Chief Privacy Officer, the European Data Protection Compliance Officer, and the Global IT Security Officer. In addition, the Council is charged with monitoring the company's compliance with applicable data protection laws and regulations. The CODP also functions as Quintiles’ privacy inquiry office and has established the Privacy Incident Response Team (PIRT) to receive, investigate, track and guide resolution of any incidents / complaints that Quintiles may receive or identify regarding data privacy. Further, the Council has established an ongoing privacy awareness training program which is required globally for all Quintiles employees. * * * Quintiles’ U.S.-EU Safe Harbor Privacy Statement sets forth the privacy principles that Quintiles follows with respect to transfers of personal information from the EU to the U.S. Quintiles adheres to the U.S.-EU Safe Harbor Privacy Principles in connection with the transfer of all personal data from the EU to the U.S. Quintiles values the confidence of its customers and respects individual privacy, including personal information of employees, consumers, healthcare professionals, medical research subjects, clinical investigators, customers, business partners and investors. Not only does Quintiles strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. Quintiles’ Safe Harbor certification can be found at http://safeharbor.export.gov/companyinfo.aspx?id=10938. For more information about the Safe Harbor Principles, please visit the U.S. Department of Commerce’s Website at http://export.gov/safeharbor/ Quintiles Safe Harbor Privacy Policy (the “Policy”): SCOPE: This Policy applies to all personal information, either in electronic or paper format, received by Quintiles in the U.S. from the EU. DEFINITIONS: For purposes of this Policy, the following definitions shall apply: “Agent” means any third party that uses personal information provided to it by Quintiles to perform tasks on behalf of and under the instructions of Quintiles. “Quintiles” means Quintiles Transnational Corp., its successors, subsidiaries, divisions and groups in the United States. “Personal information” means any information or set of information that identifies or could be used by or on behalf of Quintiles to identify an individual. Personal information does not include information that is encoded or anonymized or publicly available information that has not been combined with non-public personal information. “Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, Quintiles will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive. PRIVACY PRINCIPLES:The privacy principles in this Policy are based on the Safe Harbor Privacy Principles.NOTICE: Where Quintiles collects personal information directly from individuals in the EU, it will explain the purposes for which it collects and uses personal information about the individuals, the types of non-agent third parties to which Quintiles discloses that information, and the choices and means, if any, Quintiles offers individuals for limiting the use and disclosure of personal information about them. This explanation will be provided as soon as practicable and, in any event, before Quintiles uses the information for a purpose other than that for which it was originally obtained. Where Quintiles receives personal information from its subsidiaries, affiliates or other entities in the EU, it will use such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates. Quintiles may not need to furnish notice where the processing in question is necessary to respond to a government inquiry; is required / authorized by applicable laws, court orders or government regulations; or is necessary to protect Quintiles’ legal interests and providing notice would interfere with the above requirements. CHOICE: Quintiles will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Unless required or authorized by law, Quintiles will not process sensitive personal information about individuals for purposes other than those for which the information was originally obtained or subsequently authorized by the individual unless the individual affirmatively and explicitly consents to the processing (“opt-in”). Quintiles will provide individuals with reasonable mechanisms to exercise their choices. DATA INTEGRITY: Quintiles will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Quintiles will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, current, and otherwise reliable in relation to the purposes for which the information was obtained. Quintiles employees have a responsibility to assist Quintiles in maintaining accurate, complete and current personal information. TRANSFERS TO AGENTS: Quintiles may share an individual's information with agents, contractors or partners of Quintiles in connection with services that these individuals or entities perform for, or with, Quintiles. Quintiles may, for example, provide an individual's personal information to agents, contractors or partners for hosting our databases, for data processing services, or to send to that individual the information that he or she requested. Quintiles will obtain assurances from these third parties that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided include: a contract with provisions obligating these third parties to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to the EU Data Protection Directive, Safe Harbor certification by these third parties, having Binding Corporate Rules approved by the European Commission, or being subject to another European Commission adequacy finding (e.g., Argentina, Canada, Guernsey, Jersey, Isle of Mann, Israel, Switzerland). Where Quintiles knows that an agent, contractor or partner is using or disclosing personal information in a manner contrary to this Policy, Quintiles will take reasonable steps to prevent or stop the use or disclosure. ACCESS AND CORRECTION: Upon request, and as required by law, Quintiles will provide individuals with reasonable access to the personal information that Quintiles holds about them, subject to permitted exemptions. In addition, upon request, Quintiles will take reasonable steps to provide individuals with a means to correct, amend, or delete information that is found to be inaccurate or incomplete. Due to regulatory, statistical, and contractual requirements, Quintiles is unable to grant direct access to research data to research participants or clinical investigators. SECURITY: Quintiles will employ reasonable safeguards to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. ENFORCEMENT: Quintiles’ internal privacy board, the Council on Data Protection (CODP), has implemented internal, self-assessment procedures for periodically conducting random reviews of compliance of its relevant privacy practices to verify adherence to the company's Safe Harbor Privacy Policy. Quintiles encourages individuals covered by this Policy to raise concerns about the processing of personal information about them by contacting Quintiles CODP through the contact information provided below. Any employee that Quintiles determines is in violation of this Safe Harbor Privacy Policy will be subject to disciplinary action up to and including termination of employment. DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to Quintiles’ Council on Data Protection through the contact information given below. Quintiles will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy. For complaints involving all other personal data other than human resources data that cannot be resolved between Quintiles and the employee, such disputes will be referred to the American Arbitration Association for resolution. For internal complaints by individuals involving human resources data that cannot be resolved between Quintiles and an employee after following the internal review, complaint, and appeal procedures, Quintiles has agreed to participate in the dispute resolution procedures of the applicable national data protection authority and Swiss Federal Data Protection and Information Commissioner to resolve disputes pursuant to the Safe Harbor Principles. CONTACT INFORMATION: Questions or comments regarding this Policy should be submitted to Quintiles’ Council on Data Protection by e-mail as follows: data.protection@quintiles.com or Quintiles’ Business Ethics HelpLine: Inside of the U.S. at 1-866-Q-ETHICS (738-4427) or Outside of the U.S., dial the country access code, then 866-738-4427. RESERVATION OF RIGHTS: Quintiles reserves the right to share an individual’s information as required or authorized by law or in response to duly authorized information requests of government authorities. CHANGES TO THIS SAFE HARBOR PRIVACY POLICY: This Policy may be amended from time to time, consistent with the requirements of the U.S.-EU Safe Harbor Privacy Principles. Appropriate public notice will be given concerning such amendments. * * * If you feel that Quintiles may not have abided by the U.S.-EU Safe Harbor Privacy Principles, you may contact Quintiles or the U.S. Federal Trade Commission. SAFE HARBOR POLICY PRIVACY POLICY - EFFECTIVE DATE: JANUARY 5, 2005; last updated December 15, 2011 * * * In addition to this Privacy Policy Statement, which includes the U.S.-EU Safe Harbor Privacy Policy Statement, Quintiles’ “Privacy Policy for Web Site” is available on this Internet site at www.quintiles.com/privacy. Quintiles sees the Internet and the use of other technologies as valuable tools for communicating and interacting with consumers, employees, healthcare professionals, business partners, and others. Quintiles recognizes the importance of maintaining the privacy of information collected online and has created a specific “Privacy Policy for Web Site” governing the treatment of personal information collected through web sites that it operates. With respect to personal information that is transferred from the European Economic Area (EEA) to the U.S., the “Privacy Policy for Web Site” is subordinate to the U.S.-EU Safe Harbor Privacy Statement. However, the “Privacy Policy for Web Site” also reflects additional legal requirements and evolving standards with respect to Internet privacy. Information about how Quintiles Japan protects privacy is available on Quintiles’ Japan Internet site in Japanese at http://www.quintiles.co.jp/privacy.html. * * * Should you have other questions or concerns about these privacy policies, please contact us at 919-998-2796 or toll free at 877-988-2100 or send an email to the Council on Data Protection in care of data.protection@quintiles.com. Version 5.0 December 15, 2011. Quintiles’ Privacy Policy Statement and Safe Harbor Privacy Policy is reviewed periodically by Quintiles’ Council on Data Protection and amended or updated as appropriate. The Council reserves the right to change or alter this Statement without notice. | We self-certify compliance with:
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