Privacy Policy

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Innovate Clinical Research Pty Limited [ABN 87 672 332 562]: https://innovateclinical.com.au.

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This Privacy Policy was last updated on 31 March 2024.

General Approach and about this Privacy Policy

Innovate Clinical Research Pty Limited [ABN 87 672 332 562] (ICR, we, us or our) has implemented this Privacy Policy to provide information about what kinds of Personal Information we may collect or hold, how we collect, hold, use and disclose that Personal Information, choices you have regarding our use of that Personal Information, and your ability to access or correct that Personal Information. ICR places a high value on confidentiality and protecting the privacy of people who register with us or go on to participate in research studies. We have very strict procedures to protect people’s Personal Information and identities. If you wish to make any inquiries regarding this Privacy Policy, you should contact us in any of the ways specified at the end of this Privacy Policy.

From time to time, ICR may be related to other companies and entities (related entities). This Privacy Policy applies to the use of your Personal Information by us and by those related entities. Those related entities may also have their own privacy policies which set out additional detail or differences in their privacy practices. To the extent that those privacy policies are inconsistent with this Privacy Policy, those privacy policies will prevail over this Privacy Policy in relation to the actions of those related entities. A reference in this Privacy Policy to ICR, we, us or our is also a reference to those related entities.

Collection of Personal Information – Types of Personal Information we collect

“Personal Information” is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.

The types of Personal Information we may collect about an individual will depend upon the nature of our interaction with them. Personal Information that we collect may include (but is not limited to) the following:

  1. name
  2. age and/or date of birth
  3. contact details including telephone numbers (landline and/or mobile)
  4. current address (including postal address)
  5. email address
  6. gender
  7. identification information such as driving licence details, including driving licence number
  8. information about your health including information pertaining to your medical history
  9. information about the types of medications you receive
  10. payment details, such as your credit card or bank account details
  11. occupation and employment details including employment status and any previous work experience
  12. information from or in connection with your resume or job application if you apply for a position with us, and
  13. Australian Business Number (ABN)

We collect and record Personal Information about individuals such as:

  1. our clinical trial participants, potential clinical trial participants and their representatives
  2. our suppliers and potential suppliers and their representatives, directors, partners, proprietors and shareholders
  3. contractors and subcontractors and potential contractors and subcontractors and their representatives in relation to providing goods and services to us
  4. our employees past and present, including applicants, and
  5. any other person who comes into contact with ICR.

How and when we collect Personal Information

We collect your Personal Information to allow us to conduct our business functions, to provide, market and sell our products and services and for the specified purposes set out in this Privacy Policy including the section about how we use and disclose your Personal Information. In some circumstances the collection of Personal Information may be required by law.

We will only record your Personal Information if you send our website a message, if you post those details onto an electronic form available on this website or if you otherwise provide your Personal Information to us.

We may use visitor logs to collect statistical information, such as a user’s server address, top level domain name, the date and time of the visit, pages downloaded, and browsers used. This information is used for statistical purposes, and to update and improve this website. No attempt will be made by us or any third party on our behalf to identify users or browsing activity. Please see ‘Information collected via our Website’ for further information.

We may collect your Personal Information in the course of providing you with goods or services, or:

  1. when you register with us
  2. when you apply to participate in a research study
  3. when you use or engage in our services
  4. when you provide us, or you offer or apply to supply us, with goods or services
  5. when you provide information to us in any way (including by completing a form, disclosing information over the phone or via email, or providing us a business card)
  6. when you request information about us or our services
  7. when you provide feedback to us
  8. when you visit or fill in a form on our Website
  9. when you visit premises from which we operate
  10. when you (or your employer) provide that information to us in the course of conducting or administering our relationship with you, or when you are carrying out activities in connection with our business operations
  11. when you submit a job application to us
  12. when you otherwise contact us by telephone, fax, email, social media, post or in person, or
  13. where we are otherwise required or authorised by law to do so.

Generally, when providing our services, dealing with our personnel, or obtaining goods and services from our service providers, suppliers or contractors, we collect Personal Information directly from the relevant individual where reasonable and practicable. We may also collect Personal Information about you from third parties and other sources such as:

  1. your nominated representatives (eg spouse, carer etc.)
  2. publicly available sources of information, or
  3. related entities, companies and businesses of ICR.

However, we will only collect your Personal Information in this way if it is unreasonable or impracticable to collect this information directly from you or if we are otherwise permitted to do so.

Given the nature of our business, a lot of information we collect is sensitive. If the Personal Information we collect from you includes sensitive information, including health information and biometric information, we will ask for your consent to collect sensitive information, unless the law allows us to collect it without your consent.

Where we engage with you multiple times over a short period in relation to the same matter, we may not provide you with a separate notice about privacy each time we engage with you.

In most cases, if you choose not to provide your Personal Information to us for the purposes set out in this Privacy Policy, or if we do not or are unable to collect the Personal Information we require, we may not be able to provide you with requested information or services or to effectively conduct our relationship with you.

Information collected via our Website

Personal Information may be collected by us and by our third party service providers who assist us in operating our website at www.innovateclinical.com.au, including its subdomains and any other website we operate from time to time (collectively the Website).

We may use various technological methods from time to time to track the visiting patterns of individuals accessing our Website, including but not limited to the methods set out in this paragraph.

Google Analytics

Our Website may use Google Analytics from time to time to help analyse how you use our Website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated is used to create reports about the use of our Website. Google will store this information.

If you do not want your Website visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at https://tools.google.com/dlpage/gaoptout.

Cookies

Our Website may use ‘cookies’ from time to time. Cookies are small text files that are transferred to a user’s computer hard drive by a website for the purpose of storing information about a user’s identity, browser type or website visiting patterns. Cookies may be used on our Website to monitor web traffic, for example the time of visit, pages visited and some system information about the type of computer being used. We use this information to enhance the content and services offered on our Website.

Cookies are sometimes also used to collect information about what pages you visit and the type of software you are using. If you access our Website or click-through to our Website from a link in an email we send you, a cookie may be downloaded onto your computer’s hard drive.

Cookies may also be used for other purposes on our Website but in each case none of the information collected can be used to personally identify you.

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.

If you disable the use of cookies on your web browser or remove or reject specific cookies from our Website or linked sites then you may not be able to gain access to all of the content and facilities in those websites.

Third party content (eg social media links)

Some of the content on our Website may include applications made available by third parties, such as social media buttons or links that allow you to share content or links to our Website through the relevant third party platforms. These third party applications themselves may facilitate collection of information by those third parties, through your interaction with the applications and sometimes even if you do not interact directly with them. We are not responsible for the technical operation of these applications or the collection and use practices of the relevant third parties. Please visit the relevant third party websites to understand their privacy practices and options they may make available to you in relation to their collection of your Personal Information.

Use and Disclosure of Personal Information

ICR will use your Personal Information for our business functions and activities, in order to operate of business efficiently, to market our services on behalf of our clinical trial participants, and for the purposes for which you provide it, or for a related purpose. We may collect, hold and use your Personal Information:

  1. to identify and communicate with you
  2. to enable us to provide you with requested information or services
  3. to facilitate the operation and research of clinical trials
  4. to otherwise assist clinical trial participants by providing them with information and support
  5. to collect and process payments
  6. to help us to manage and enhance services we provide to you
  7. to help us to manage and enhance services we procure from our suppliers and subcontractors
  8. to personalise and customise your experiences on our Website
  9. to provide you with information that we believe may be of interest to you or that you may be interested in receiving, including advertising material
  10. to protect you and us from fraud
  11. to provide for the safety and security of workers and onsite visitors
  12. to help us manage our business operations
  13. for business support purposes including maintenance, backup and audit
  14. to process any job application submitted by you
  15. to respond to any queries or complaints you may have
  16. to investigate, review, mitigate risks associated with, and inform you of, a data or other security breach involving your Personal Information, or
  17. to comply with our statutory and legal obligations.

We may aggregate Personal Information for reporting, statistical and analysis purposes, and for business, product and service improvement purposes. This allows us to better inform ourselves and anticipate our clinical trial participants’ preferences and requirements, and to monitor and improve the effectiveness of our business, products and services. We may also de-identify information for inclusion in such aggregated databases or reports.

We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but we have no obligation to monitor the use of the Website or to retain the content of any user session.

You consent to us using your Personal Information in the above ways and as set out in this Privacy Policy.

We may otherwise collect, use or disclose your Personal Information where the collection, use or disclosure is:

  1. in accordance with this Privacy Policy or any agreement you enter into with us, or
  2. required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth).

We may disclose, or provide access to, your Personal Information to third parties in connection with the purposes described in this Privacy Policy including the above paragraphs. Depending on the circumstances and the nature of your engagement with us, we may disclose your Personal Information to our

related entities, to third parties that provide products and services to us or through us, or to other third parties (such as your referee(s) in connection with a job application you have submitted).

We may also disclose your Personal Information to:

  1. any of our internal divisions, business units or departments
  2. your nominated representatives
  3. other organisations or individuals who assist us in providing our services to you
  4. professional service providers and advisors who perform functions on our behalf, such as lawyers
  5. medical providers including medical and rehabilitation practitioners for assessing insurance claims
  6. representatives, agents or contractors who are appointed by us in the ordinary operation of our business to assist us in providing our services or administering our business (such as for data storage or processing, printing, mailing, marketing, planning and product or service development)
  7. insurers, auditors, business consultants and IT service providers, and
  8. Government, regulatory authorities and other organisations as required or authorised by law.

We may also disclose your Personal Information to our Website host or software application providers in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.

In order to ensure we can carry out clinical research trials effectively and to obtain appropriate assistance to undertake these, we may disclose your Personal Information to our research trial and project sponsors. The research trial and project sponsors may use the Personal Information or may de-identify any data they collect from us during and after your clinical trial, depending on the nature of the information. Any Personal Information disclosed by us to our research trial and project sponsors will be collected and handled by them in accordance with their own privacy policies and collection statements, which will be notified to you at the time you sign up to the relevant clinical trial or which you can obtain details about by contacting us as set out below in this Privacy Policy.

As we continue to develop our business, we may buy, merge or partner with other companies or organisations, and in so doing, acquire customer Personal Information. In such transactions, Personal Information may be among the transferred assets. Similarly, in the event that a portion or substantially all of our business or assets are sold or transferred to a third party, we may also disclose certain information including your Personal Information to a purchaser or potential purchaser in connection with the sale or potential sale of us, our business or any of our assets, including in insolvency.

Interstate and Overseas disclosures

Generally, we do not send or disclose your Personal Information to overseas recipients.

However, in certain circumstances some of your Personal Information may be disclosed, transferred, stored, processed or used overseas by us, or by third party service providers. Overseas disclosure of your Personal Information may happen from time to time if:

  1. our offices or related entities are overseas
  2. we outsource certain activities overseas
  3. transactions, information, services or products have an overseas connection, or
  4. our computer systems including IT servers are located overseas.

You consent to the collection, use, storage, and processing of your Personal Information both within and outside of Australia as set out in this Privacy Policy.

In particular, your Personal Information may be disclosed to third parties in countries in which those parties or their, or our, computer systems may be located from time to time, where it may be used for the purposes described in this Privacy Policy. In these circumstances, you consent to the collection, use, storage and processing of your Personal Information in those countries. Where such parties are located overseas, you may have rights to enforce such parties’ compliance with applicable data protection laws, but you might not have recourse against those parties under the Australian Privacy Act in relation to how those parties treat your Personal Information.

Marketing

We may collect, use and disclose your Personal Information for other purposes not listed in this Privacy Policy. If we do so, we will endeavour to make it known to you at the time we collect or use your Personal Information.

Storage and security measures

We aim to keep your Personal Information secure. Any Personal Information that is collected via our Website or which is held on our computer systems is protected by safeguards including physical, technical (firewalls, SSL encryption etc) and procedural methods. However, there are risks in transmitting information over the internet. We cannot guarantee the security of any information transmitted online, and that information is transmitted at your own risk.

Accessing and updating your Personal Information

You are generally entitled to access Personal Information that we hold about you. If you request access to your Personal Information, in ordinary circumstances we will give you full access to your Personal Information. Depending on the nature of the request, we may charge for providing access to this information, however such charge will not be excessive. However, there may be some legal or administrative reasons to deny access. If we refuse your request to access your Personal Information, we will provide you with reasons for the refusal where we are required by law to give those reasons.

You can access and correct some of your Personal Information through the Website by logging into your account and updating or editing your profile at any time. Alternatively, a request for access can be made by contacting our Director in any of the ways specified at the end of this Privacy Policy.

We take all reasonable steps to ensure that any Personal Information we collect and use is accurate, complete and up-to-date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested, and properly update the information provided to us to keep it true, accurate, current and complete.

Please contact us in any of the ways specified at the end of this Privacy Policy if you believe that the Personal Information is inaccurate, incomplete or out of date, and we will use all reasonable efforts to correct the information.

It would assist us to ensure we properly understand your request, and allow us to respond more promptly, if requests are made in writing and include as much detail as possible.

Complaints about your Privacy

If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Policy, please contact our Director in any of the ways specified at the end of this Privacy Policy and advise us as soon as possible. We will investigate your queries and privacy complaints within a reasonable period of time depending on the complexity of the complaint.

It would assist us to respond to your complaint promptly if it is made in writing. Please detail information relevant to your complaint.

We will notify you of the outcome of our investigation.

Updates to this Privacy Policy

We may, from time to time, review and update this Privacy Policy, including to take into account new laws, regulations, practices and technology. All Personal Information held by us will be governed by our most recent Privacy Policy, posted on our website at: www.innovateclinical.com.au, where the Privacy Policy will be located. Any changes to this Privacy Policy may be advised to you by updating this page on our Website. We will aim to provide reasonable advance notice of such changes though this may not always be possible depending on the circumstances. We encourage you to check this page from time to time for any changes.

What to do if you have a question, problem or complaint or want to contact us about our use of your Personal Information or this Privacy Policy?

If you:

  1. have a query or concern about this Privacy Policy or our Personal Information handling processes
  2. wish to make a complaint in relation to a breach of your privacy
  3. would like to access your Personal Information held by us
  4. would like to update or correct your Personal Information held by us, or
  5. would like to opt out of direct marketing,

please contact us in any of the following ways:

Email Address: info@innovateclinical.com.au, or

Mailing Address: Suite 103, Level 1, 41-45 Pacific Highway, Waitara, or

Phone number: +612 9159 3838