1.1 Conditional Use of this Site
1.2 Type of Personal Information Collected
The purpose of this Policy is to protect all personal information received or gathered by WEP Clinical. This applies to patients, healthcare professionals, customers, suppliers, vendors, business partners, and all other persons from which personal information is collected. WEP Clinical takes the stance of minimizing unnecessary collection and sharing of any personal information.
1.3 Commitment to Only Collect Data for Legitimate Purposes
As part of our commitment to only collect personal information for legitimate purposes, the WEP Clinical Security Team reviews all personal information collected and determines whether data collection is appropriate. These legitimate purposes include but are not limited to, management of expanded access/compassionate use programs, patient advocacy, clinical trials sourcing, and other key job functions at WEP Clinical. Further, when data is collected WEP Clinical maintains standards for assuring optimal security of all data maintained within our systems. The Security Team also utilizes pseudonymization and anonymization when possible, to minimize risks to individuals from whom data has been collected.
1.4 Individuals Right to Object
Individuals have the right to object to data collection at the point of first communication.
1.5 Individual Right to View, Change, and Delete Data
1.6 Individual Right to Restrict Data
Individuals have the right to request that WEP Clinical restrict their personal data, where the individual’s personal data is permitted to be stored but not processed. Restriction of data is not an absolute right and can only be requested in the event that the individual contests the accuracy of their personal data, the data has been unlawfully processed and the individual opposes deletion, the data is no longer required for processing but the data needs to be kept in order to establish, exercise, or defend a legal claim, or the individual refuses the processing of their information and WEP Clinical is verifying whether the company’s legitimate grounds override those of the individual. As restriction of processing is a temporary process, WEP will inform the individual before the restriction is lifted.
1.7 Clinical/Medical and Health Professional Information
All medical information collected from patients or shared with WEP Clinical by medical professionals, investigators, or any other parties, is performed under contract. WEP Clinical considers the entity generating protected healthcare information to be ultimately responsible for how health care information is shared and processed. Data may be transferred to sponsors of clinical trials, investigators of clinical trials, or other contracted organizations. All data collected by WEP Clinical is processed in accordance with HIPAA, GDPR, and GCP. Moreover, whenever possible individual or identifiable patient data will be pseudonymized.
WEP Clinical may obtain and analyze professional information from health care professionals for the purpose of assisting with identification and evaluation of investigators. WEP Clinical may use contact information for the purpose of inviting investigators to communicate with sponsors and participate in research. We will use public sources, internal databases, and referrals to obtain information. Financial information for payment of services may also be processed.
WEP Clinical utilizes surveys and other data collection platforms to collect information on patients that are currently enrolled in, or have completed, Clinical Trials or Expanded Access Programs (EAPs). From these surveys, WEP Clinical may generate protected information that includes, but is not limited to, names, emails, clinical diagnoses, and IP addresses. WEP Clinical only uses qualified survey providers, with applicable compliant security measures. All data generated from the surveys is stored in a password protected and encrypted fashion. Data is only sent out to third parties as required for data analysis, and data is de-identified prior to being sent out, unless specific permission to share PHI is granted by the patient or guardian. All survey patrons receive and sign an informed consent prior to beginning the survey.
1.8 Employee Data
WEP Clinical collects personal information from its employees. This information may include, but is not limited to, contact details, professional qualifications, employment history, background checks, payroll, tax information, and other human resource data. This is performed in accordance with standard business operations. WEP Clinical policy is not to share, or sell employee information without specific permission being granted. Where relevant WEP Clinical will share employee data to third parties (e.g. Tax authorities) for the sole purpose of maintaining legal compliance with such data controllers who WEP Clinical have a statutory legal obligation to comply with.
1.9 WEP Clinical Site Patrons
Due to our obligation to collect minimal personal information, WEP Clinical does not store any “cookies” information from Site patrons. Site patrons may opt to contact WEP Clinical via the “Contact Us” link. In this case, email and any other information the patron choses to provide, may be collected. WEP Clinical will not be share information unless the individual agrees to conditions and terms of information sharing.
The WEP Clinical Site contains links to other websites that we do not own or operate. We do not control, recommend, or endorse and are not responsible for these websites or their content, products, services or privacy policies. Downloading material from certain websites may risk infringing intellectual property rights or introducing viruses into your system. When you leave the WEP Clinical Site, you should read the privacy policies and terms of these other websites. You should also independently assess the authenticity of any website which appears or claims that it is one of our websites (including those linked to through an email).
WEP Clinical may use the information collected as defined herein to comply with legal and regulatory responsibilities, policies, and for administrative purposes.
1.10 Internal and External Sharing of Personal Information
As part of WEP Clinical’s effort to minimize data collection and sharing, we strive to only collect and share information when required for business purposes. The affiliates with whom data may be shared include sponsors of clinical trials, investigators of clinical trials, business associates, and other third parties.
Access to information is restricted to appropriate staff, both internally and externally. WEP Clinical does not sell or trade personal information. WEP Clinical will divulge information only to appropriate persons as required by law enforcement or judicial authorities as part of an investigation. WEP Clinical may share information with a buyer in the instance of a sale or transfer of WEP Clinical or its assets.
Companies working as agents of WEP Clinical are required to sign a confidentiality agreement, in which they commit to only process personal information for agreed upon purposes, and must adhere to organizational and security safeguards.
WEP Clinical is a provider of clinical supply and management services globally and may share information across international borders. WEP Clinical performs international sharing and hosting of data in accordance with appropriate regulatory processes where legally mandated.
Individuals may request to be informed as to what personal information WEP Clinical is currently keeping on file for them. WEP Clinical will provide this information to the individual and at the request of the individual, WEP Clinical will update and delete personal information, in accordance with appropriate regulations.
When appropriate, WEP Clinical will obtain consent to collect, use, and disclose information as required by law or to remain compliant with GCP.
All WEP Clinical policies utilize appropriate technical, administrative, and physical safeguards to protect personal information from unauthorized use, disclosure, alteration or destruction, and to adhere to required regulations. This includes limiting access to essential personnel, minimizing data sharing, and using password protection. However, WEP Clinical cannot guarantee the security of such information. To the fullest extent permitted by law, WEP Clinical disclaims all liability and responsibility for any damages you may suffer due to any loss, unauthorized access, misuse or alteration of any information you submit to our Site.
1.13 Data Integrity and Usage
WEP Clinical takes all reasonable precautions to ensure that information is accurate, complete, and up to date. Information is only to be used for purposes stated during information collection unless the other use is explicitly specified and consented to by the individual. WEP Clinical will take all steps to correct, amend, or delete information that does not meet the aforementioned criteria, except when in conflict with regulations. Data will be retained for durations required by appropriate regulations.
1.14 Reservation of Rights
WEP Clinical reserves the right to share personal information as defined in our contracts, as authorized by law, or in response to requests by government authorities.
1.16 Contact Information