Our privacy practices reflect applicable legal requirements, including the General Data Protection Regulation, or the GDPR (“Applicable Data Protection Law”).
It is important that the personal data which we maintain about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us using the details set out in the “How to Contact Us” section below.
Who we are
What is personal data?
Personal data is information which relates to an identified or identifiable natural person, (this means a human being). Anonymous information, for which it is not possible to determine to whom the data relates, is not considered personal data.
What personal data do we collect about you?
As a clinical research organization which also provides resourcing services, while doing business with you, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, title, education, work history, therapeutic experience, company name and Employee Identification Number, and any other identity data potentially found on your curriculum vitae/resume which you may provide to us.
Contact Data includes address, email addresses, skype address and telephone numbers which you may provide to us.
Financial Data includes Employee Identification Numbers, Tax ID Numbers, social security numbers, bank accounts and wiring information used in order to pay you.
Transactional Data includes details about payments to and from you and other details of services you have provided for us, including wiring information.
Usage Data includes information about how you use our website and our services, if applicable.
Marketing and Communications Data includes your preferences in receiving marketing or job opportunity or company update information from us and our third parties, and your communication preferences (i.e. opting out). This information may be collected either online or offline.
Information you provide to us: The information you provide to us may include part or all of the data categorized above under Identity Data, Contact Data and Financial Data, including personal data provided when you:
- Request information about Catalyst or inquire about a job opportunity or posting;
- Inquire about a job opportunity from our site’s postings or via email;
- Subscribe or respond to our marketing campaigns;
- Speak with a Catalyst-representative to discuss relevant work experience and area of residence to ensure alignment with job opportunities and client programs;
- Provide feedback or contact us to discuss a project or assignment in which you are engaged with Catalyst;
- Engage with us and execute onboarding documents, including your curriculum vitae, executed contract agreements, emergency contact forms, banking data and wiring instructions.
Information we collect about you: With regard to each of your visits to our website or “Our Sites” (Our Sites can include our presence on social media platforms, including Facebook and LinkedIn, among others, which are governed by the Privacy Policies of their respective platforms), we may automatically collect the following information:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- Information about your visit, including the full uniform resource locators (URL) clickstream to, through and from Our Sites, (including date and time); pages you viewed or information for which you searched; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
- Information we receive from other sources, such as LinkedIn, or other publicly available websites or social media sites, prior to your engagement with us.
We collect the following information when you are engaged by Catalyst:
- Reference checks from individuals you refer;
- Debarment Status – we perform debarment checks to ensure you have not been debarred from regulatory authorities;
- Per our Client’s hiring requirements and based on a signed acknowledgement form you provided for release: background check data which could include criminal, employment, education and drug testing;
- Your Good Clinical Practice (GCP) scores, if applicable to the position, from the GCP test you were asked to complete and successfully pass;
- Contract services agreement and addendum outlining the terms of assignment or scope of work;
- Emergency contact information;
- Direct deposit and bank information, International Payment Wiring form;
- Your address;
- Employee Identification Number/Social Security Number;
- Company/Corporation Name and registration information.
How will we use the information about you? We use the personal data you provide, and that we collect about you in order to:
- Manage our relationship and engagements with you before, during, and after being engaged by Catalyst;
- Communicate with you in response to queries, or to check in with you if you are actively on assignment;
- Provide you with information about us and our services, including job opportunities (“Services”),
- Provide the Services to you on request, and to fulfil our obligations in respect of the same;
- Ensure appropriate, timely and accurate compensation and payment logistics should you be engaged by us;
- Maintain and administer our website and any other online or social media channels, platforms or Our Sites that we operate, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- Improve Our Sites, to ensure content is presented in the most effective manner for you and for your computer or device;
- As part of our efforts to keep Our Sites safe and secure, and to prevent fraud;
- Measure or understand the effectiveness of marketing activities we serve to you and others, and to deliver relevant marketing to you;
- Provide suggestions and recommendations to you and other users of Our Sites about services and opportunities which may interest you or them.
Our legal basis for processing your data. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where the processing is necessary for the performance of a request or contract you have entered into with us, including a request for one of our Services;
- Where we need to comply with a legal or regulatory obligation: (i) to assist the EMEA, FDA or other public authority upon inquiry (ii) to identify you when you contact us; or
- Where the processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Such legitimate interests may include:
- Correspondence or communication with you, i.e. keeping you up-to-date on the latest announcements, updates, job opportunities, events;
- Improving our candidate or user relations;
- Compliance with a request from you in connection with the exercise of your rights;
- For the management of queries, complaints or claims; and
- For the establishment and defense of our legal rights.
Please note, we may process your personal data using more than one legal basis depending on the specific purpose for which we are using your data. Please contact us using the details provided in the “How to Contact Us” section below if you need details about the specific legal ground upon which we are relying to process your personal data on any given occasion.
We will only use any of your special categories of personal data when the law allows us to. Most commonly, we will use your special categories of personal data in the following circumstances:
- Where we have your explicit consent;
- Where the processing is carried out in the course of our legitimate activities with appropriate safeguards;
- Where the processing relates to special categories of personal data that you have made public;
- Where the processing is necessary for establishing, exercising, or defending legal claims; and
- Where the processing is necessary for reasons of substantial public interest as provided in domestic or EU law.
Given the specific purposes for which we envisage using your personal data, under the provisions of Applicable Data Protection Law we do not anticipate being required to obtain your consent to do so, save for where we wish to use your personal data to provide you with marketing or information about services which may be of interest to you, and we are required by Applicable Data Protection Law to seek your consent before we do so. For more information on this please see the “Marketing” section below. Should we wish to use your personal data for other specific purposes requiring your consent, we will contact you to request this.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note, we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by Applicable Data Protection Law.
If you provide your prior consent, or where we are otherwise permitted to do so under Applicable Data Protection Law, we may also use your personal data to contact you by email and mail with details of services, including job opportunities, publications and related materials we think may be of interest to you.
Catalyst will only share your information with third parties for marketing purposes with your prior consent or where we are otherwise permitted to do so under Applicable Data Protection Law. In which case, we shall pass your personal data on to other companies, trade bodies or associations so that they may offer you their products and services.
You have a right at any time to stop us from contacting you or sharing your personal data for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us using the details set out in the “How to Contact Us” section below.
Please note, where you opt out of receiving these marketing messages, this will not delete any personal data provided to us as a result of another transaction or interaction.
Disclosures of your personal data
We may disclose your personal data:
- To third parties as required for our everyday business purposes, including to our clients, related companies, our business partners, and technical services providers if applicable, including in order to provide you with the Services you request;
- Analytics and search engine providers that assist us in the improvement and optimization of the Sites;
- To third parties in the event we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- If Catalyst or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
- To competent authorities (including regulatory and tax authorities), courts and bodies as required by law; or
- To protect the rights, property, or safety of Catalyst and our members and non-members, or for internal investigations and reporting. This may include exchanging information with other companies and organisations for the purposes of fraud protection.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Where we are required to transfer your personal data out of the European Economic Area (“EEA”), we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries deemed to provide an adequate level of protection for personal data by the European Commission; or
- We will undertake the transfer on the basis of a specific contract approved by the European Commission which give personal data the same protection it has in Europe (“Model Form Clauses”). For further details, and a copy of the text of these Model Form Clauses see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en; or
- Where we use service providers based in the US, we may transfer personal data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us using the details set out in the “How to Contact Us” section below if you want further information about the specific mechanisms we use when transferring your personal data outside of the EEA in a given circumstance.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, clients, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
How long will you use my personal data?
We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
For further information as to any specific retention periods that might apply to personal data we hold about you, please contact us using the details set out in the “How to Contact Us” section.
In some circumstances you can ask us to delete your personal data: see the “Your Legal Rights” section below for further information.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research, marketing or statistical purposes. If we do that, we may use this information indefinitely without further notice to you.
Third party websites
Your Legal Rights
In certain circumstances, you have rights under Applicable Data Protection Law in relation to your personal data. In relation to certain rights we may ask you to confirm your identity and where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either (i) the date we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request. You may have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the personal data’s accuracy; (b) where our use of the personal data is unlawful but you do not want us to erase it; (c) where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Services to you and we may need to suspend or terminate your access to Our Sites. We will advise you if this is the case at the time you withdraw your consent.
- Complaining to the UK data protection regulator if you are concerned about the way we have processed your personal data. The Information Commissioner’s Office (“ICO”) website sets out further details.
If you wish to exercise any of the rights set out above, please contact us using the details set out in the “How to Contact Us” section below.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
How to Contact Us
By email: firstname.lastname@example.org
Or write to us at:
Catalyst Clinical Research
5826 Fayetteville Road, Suite 202
Durham, NC 27713 USA
Attn: Data Privacy Manager
Telephone: +1 (919) 648-0668
Fax: +1 (919) 908-6979