Last Updated: April 23, 2019
LMK Clinical Research Consulting, LLC, and its affiliates and business partners (“LMK,” “We,” “us,” or “our”) is pleased to provide information to all of our clients, customers, clinical trial participants and website visitors about our company’s efforts to maintain the privacy and confidentiality of all data and information collected or handled by LMK. Please rest assured that we use our best efforts to protect the privacy of not only visitors to this website, but also of all clients, customers and clinical trial participants from whom we have collected, compiled, handled or processed data.This Policy includes protection of all personal information associated with our trial master file services, information submitted on our website for the purpose of obtaining information about the services that LMK provides, or inquiries related to employment with LMK. This information is collected either in electronic or paper format, and received by LMK in the United States from website visitors, customers, clients, and prospective clients and customers.
The privacy principles stated herein below and used by LMK are based on industry-wide best practices, and where applicable, federal, state and local law.
THE INFORMATION WE HANDLE AND THE WAY IN WHICH WE USE SUCH INFORMATION
Clinical and/or Medical Information and Data
As a member of the clinical research industry, specifically our trial master file management services, we handle a large volume of health data and other medical information relating to clinical study participants on behalf of our clients. LMK utilizes several techniques, and uses its best efforts, to enhance the privacy and confidentiality of such data, consistent with industry regulations and standards.
All clinical and medical information processed or handled by LMK is done so under contract with our clients. In terms established by the contract with our client or customer, LMK considers that the sponsor/client/customer is ultimately in control of how and why clinical and medical data are disclosed or processed within our services, and as such is the “controller” of such clinical, health and medical data and information, whereas LMK, and its employees, agents and affiliates, are merely “processors” or “handlers” of the information under contract with the customer or client who is the controller thereof.
Employee and Human Resource Data
LMK collects personal information from applicants to open positions within the company, including private contact details, professional qualifications and previous employment history to inform employment decisions. LMK conducts various background checks on applicants, including, where law allows, criminal history checks and professional licensing checks. Once employed, LMK collects information on staff for human resource, performance, payroll and tax purposes. Various company internal systems will collect and record employee level information consistent with standard business operations, and LMK has implemented safeguards to prevent the accidental disclosure of such information.
Web VisitorsLMK collects named information about visitors to its website where this is voluntarily provided to meet a request from those individuals, for example where a client contact requests information on a company service, or where someone wants to apply for a vacant position with the company. Through the use of cookie-based technologies, LMK may collect various data linked to virtual identities allocated to visitors when they access our websites. We use such data to enable us to track and target your interests to enhance the experience on our site — including for Google Analytics. We receive IP addresses in the normal course of the operation of our website. An IP address is a number assigned to you by your Internet service provider so you can access the Internet. Although we do receive IP addresses, we do not use them to personally identify you or disclose them to others.
Except as described above, we will not otherwise use or disclose any of your personally identifiable information, except to the extent reasonably required: (i) to correct technical problems and malfunctions and when we process your information; (ii) to protect the security and integrity of our website; (iii) to protect our rights and property and the rights and property of others; (iv) to take precautions against liability; (v) to comply with laws or to respond to judicial process or mandate; or (vii) to provide information as otherwise required or permitted by law.
Any person who provides personal information to LMK is given the ability to choose whether such information will be disclosed or used for a purpose incompatible with the purpose for which it was originally collected or subsequently authorized by the individual, unless requested by law. In replying to individual inquiries about LMK services, we will use the personal information provided to process the requested information.
LMK has limited to no control over the confidential medical, health, personal or other clinical information provided to it from its customers and/or clients, but LMK will only handle such information in a manner consistent and in compliance with its contractual obligations with its customers and clients, as well as laws on confidentiality and data privacy regulations.
SHARING OF INFORMATION
Personal information will be shared within LMK and its affiliates and agents, as well as third-parties only on a “need to know” basis to meet specified legitimate business purposes. LMK does not trade or sell personal information. Under rare circumstances, LMK may be required by law to disclose certain personal information as part of legal investigations or for litigation purposes. LMK also reserves the right to disclose personal information to a buyer or other successor in the event of a merger, reformation, or other sale or transfer of some, or all, of LMK’s business. However at all times, LMK will continue to take the utmost care to ensure the privacy and confidentiality of such data and/or information.
Companies working as agents or affiliates of LMK are required to sign confidentiality and non-disclosure agreements whereby they commit to only handle and process personal information consistent with the contracted purposes, apply appropriate organizational and technical security safeguards, and where relevant, utilize the same or similar privacy principles as stated herein.
Where mandated by law, LMK, and/or its affiliates or agents, will take reasonable steps to permit individuals to correct or delete information that is inaccurate or incomplete, except when the burden or expense of doing so would be greater than the risk to the individual’s privacy, or where the rights of third-parties would be violated.
When LMK is handing or processing medical, health, or other clinical information on behalf of its clients and customers, it has no direct relationship with, or control over, the personal information that it is handling, and as such, all inquiries or requests regarding said data or information will be directed to the study sponsor, or appropriate client or customer representative, who has contracted with LMK to process and handle the personal information.
We will apply reasonable safeguards to protect personal information in our possession from loss, misuse, disclosure, and/or any other unauthorized use. To minimize the risk of unauthorized disclosure of clinical study related information, these data are maintained and controlled as required by the contractual obligations between LMK and the customer or client with whom LMK contracted. In the event that an employee, affiliate or agent of LMK becomes aware of a data security breach, they are required to notify their respective supervisor who will then take corrective action and preventive action.
LMK will use personal information that it collects, handles or processes solely for the purposes stated herein. The personal information collected, handled or processed by LMK, and its agents and affiliates, will be adequate, relevant and not excessive in relation to the purpose or stated purposes for which the information is collected, handled or processed. LMK collects and processes personal information for only specified and lawful purposes and does not process the information in any manner incompatible with that purpose or purposes.
The potential use and handling of individuals’ personal information is stated hereinabove. LMK regularly reviews its data and information handling processes and procedures to ensure compliance with the policies and principles stated herein. Any employee who knowingly violates this policies and provisions stated herein will be subject to disciplinary actions up to and including termination of employment.