WHRDG respects the privacy of its employees, its customers and visitors
to its website and is committed to protect the Personal Information
(defined below) that you share with us. WHRDG makes reasonable efforts
to protect your Personal Information. WHRDG’s privacy program and data
security activities are governed by this policy and other policies and
procedures. With respect to Personal Information about individuals
(“data subjects”) located in European Union (EU) countries, Iceland,
Lichtenstein and Norway (the European Economic Area) WHRDG also adheres
to a self-regulatory program that complies with the safe harbor privacy
principles set forth in the July 2000 agreement between the EU and the
United States Department of Commerce (Safe Harbor Program). For more
information about the Safe Harbor Program, please go to
http://www.export.gov/safeharbor. As used in this
policy, "Personal Information" is information relating to an identified
or identifiable natural person that identifies that person.
WHRDG collects, processes, and stores Personal Information for the
evaluating, and implementing employment-related actions and
evaluating, and administering compensation, benefits, and other
human resources programs.
evaluating, and implementing employment-related education and
evaluating employee conduct and performance.
and employee security, and health and safety.
storing customer information.
business records relating to past, present, and potential customers,
suppliers, contractors, joint venture partners, other business
associates, and employees.
auditing, accounting, financial, and economic analyses.
business communications, negotiations, transactions, conferences,
and compliance with contractual and legal obligations.
Providing good and
services, including clinical studies, to our customers.
website, which includes processing orders and engaging in
transactions and communications
policy applies to The Willis Human Resource Development Group and all of
its subsidiaries and affiliates around the world, and applies to all
goods and services provided by WHRDG. References to “WHRDG” in this
policy refer to Willis Human Resource Development Group its subsidiaries
and affiliates around the world.
EU SAFE HARBOR PROGRAM
abides by the Safe Harbor Program’s data privacy principles with respect
to transfers of Personal Information between the United States and
member states of the European Economic Area. The privacy principles in
this policy are based on the Safe Harbor Program’s Principles.
WHRDG may obtain Personal Information from data subjects through the
purposes identified above. At the time WHRDG collects Personal
Information from you, it will inform you of the purposes for which it
collects and uses such information and how to contact WHRDG with any
inquiries or complaints. WHRDG will not disclose Personal Information to
WHRDG will offer you the opportunity to choose whether your Personal
Information is to be (a) disclosed to a third party or (b) used for a
purpose that is incompatible with the purpose(s) for which it was
originally collected or subsequently authorized by you.
WHRDG will take reasonable precautions to protect your Personal
Information from loss, misuse and unauthorized access, disclosure,
alteration and destruction.
WHRDG will not process your Personal Information in a way that is
incompatible with the purposes for which it has been collected or
subsequently authorized by you. To the extent necessary for those
purposes, WHRDG will take reasonable steps to ensure that Personal
Information is relevant for its intended use, accurate, complete and
WHRDG will provide you with reasonable access to your Personal
Information that it holds and will undertake reasonable steps to permit
you to correct, amend or delete that information demonstrated to be
inaccurate or incomplete.
Transfer to Third Parties
When WHRDG transfers information to a third party that is acting as an
agent, before doing so it will ascertain that the third party either
safeguards Personal Information consistent with this policy, is subject
to the EU Directive 95/46/EC (the EU Data Protection Directive, Safe
Harbor certification in the U.S by the third party, or by being subject
to another European Commission adequacy finding). Alternatively, WHRDG
may enter into a written agreement with such third party requiring that
the third party provide at least the same level of privacy protection as
required by the relevant principles of this policy. Where WHRDG has
knowledge that an agent is using or disclosing Personal Information
contrary to this policy, WHRDG will take reasonable steps to prevent or
stop the use or disclosure.
WHRDG will conduct compliance audits of its relevant privacy practices
to verify adherence to this policy. Any employee that WHRDG determines
is in violation of this policy will be subject to disciplinary action.
AND SUBMITTED ON THE WEBSITE
When you browse our Web site, you do so anonymously, unless you have
previously indicated that you wish WHRDG to remember your login and
password. We do not automatically collect Personal Information,
including your email address. We do log your IP address to give us an
idea of which part of our Web site you visit and how long you spend
there. But we do not link your IP address to any Personal Information
unless you have logged in to our Web site. We do use a standard
technology called “cookie” to collect information about how you use the
site. Please go to “Web Browser Cookies” below for more information.
WHRDG collects Personal Information when you register with WHRDG for an
account, when you ask to be included in an email or other mailing list,
when you submit your personal information to WHRDG for any other reason.
When Personal Information is collected, we will inform you at the point
Server log files
Our server log files are stored in a secure location, and can only be
accessed by specified employees of WHRDG. This information is kept
indefinitely for historical purposes. This information is used to
analyze trends, administer the site, track user movement in the
aggregate, and gather broad demographic information for aggregate use.
We make use of multiple databases to record and retrieve information
sent to us through web forms (such as contact information, products and
services requested, and any billing/payment information, etc.). This
information is kept indefinitely for historical purposes. This
information is used for billing purposes and to fill customer's orders.
If we have trouble processing an order, the information is used to
contact the user.
Web browser cookies
We make use of a web browser cookie for the sole purpose of giving the
visitors of our Web site the option to login quickly, without the hassle
of putting in the username and password of their account. These cookies
are created by the visitors browser, and are generally saved somewhere
on the visitor's hard drive. Visitors have the ability to disable this
feature at any time, either by unselecting "Automatically login from
this computer" in their account information, or by disabling the use of
cookies on their web browser. The cookie that we create will last for
exactly one year from the time of creation, at which time a new cookie
will be created upon the next login.
Through the Website
some areas of our Web site you are offered the opportunity to submit
Medical investigators who have an interest in working with WHRDG in
clinical studies may submit information to our Investigator Database.
Information gathered via the Investigator Database is shared with our
clients who are interested in conducting clinical studies in the
therapeutic areas described by the registering investigator.
Patients participating in any clinical study managed by WHRDG, or those
acting on their behalf, who submit unsolicited information to a Web
site, including Personal Information, may expect that we will share that
information with our client who is responsible for the study, the
medical investigator supervising the patient’s participation in the
study, the institutional review board supervising the study and others
who may have an interest in that particular patient’s experience in the
clinical study. If a patient sends an unsolicited email to our Web site
regarding a clinical study, we reserve the right to use or disclose the
information contained in the email to third parties without seeking any
additional consent from the patient.
Our Web site also contains forms for completion and submission, such as
on our Contact Us page and Career Opportunities page. Information
submitted via these forms will be used for the purposes described
on the page containing the form. You may expect that information
submitted will be shared with the appropriate WHRDG employees and agents
necessary to take action on the information or request submitted. For
example, resumes and information related to those seeking employment
will be shared with the staff of the WHRDG Human Resources Department
and other WHRDG employees involved in the hiring process.
WHRDG takes every precaution to protect data subjects’ information,
whether collected on-line or otherwise. When data subjects submit
sensitive information via the Web site, their information is
protected both online and off-line.
When our order form asks data subjects to enter sensitive information
(such as credit card number), that information is encrypted and is
protected with the best encryption software in the industry: SSL. While
on a secure page, such as our order form, the lock icon on the bottom of
Web browsers such as Netscape Navigator and Microsoft Internet Explorer
becomes locked, as opposed to un-locked, or open, when data subjects are
While we use SSL encryption to protect sensitive information online, we
also do everything in our power to protect data subject-information
off-line. All of our data subjects' information, not just the sensitive
information mentioned above, is restricted in our offices. Only
employees who need the information to perform a specific job (for
example, our billing clerk or a customer service representative) are
granted access to Personal Information. Finally, the servers that store
Personal Information are in a secure environment, in a locked facility.
The Web site is not intended or designed to attract children. We do not
collect information or data on our Web site from children under the age
of 13 nor do we desire to receive any information or data from children
who visit our Web site.
Updating Personal Information on the Website
If a data
subject's Personal Information changes (such as zip code, phone, email
or postal address), we provide a way to correct and update data
subjects' Personal Information. This can usually be done by selecting
"Modify my account information" after logging in.
SHARING OF PERSONAL
WHRDG will not transfer your Personal Information to third parties
without your consent, except under limited conditions. Though we make
every effort to preserve data subject privacy, we may need to disclose
Personal Information when required by law wherein we have a good-faith
belief that such action is necessary to comply with a current judicial
proceeding, a court order or legal process served on our Web site. WHRDG
is a global company, your Personal Information may be shared with other
WHRDG offices or subsidiaries around the world. All such entities are
confidentiality and data transfer agreements. If you choose to provide
us with your Personal Information, we will only transfer that
information with your permission.
Third party intermediaries
We use an outside shipping company to ship orders, and a credit card
processing company to bill data subjects for goods and services. These
companies do not retain, share, store or use Personal Information for
any secondary purposes.
In the event WHRDG goes through a business transition, such as a merger,
being acquired by another company, or selling a portion of its assets,
data subjects' Personal Information will, in most instances, be part of
the assets transferred. Data subjects will be notified via a notice on
our Web site prior to a change of ownership or control of their Personal
Information. If as a result of the business transition, the data
subjects' Personal Information will be used in a manner different from
that stated at the time of collection they will be given choice
consistent with our notification of changes section.
Our server will automatically send you an email at certain events during
a web form submission. These events include but are not limited to first
time account creation, forgotten password retrieval, order confirmation,
etc. These emails are strictly used to keep the data subject well
We communicate with data subjects on a regular basis to provide
requested services and in regards to issues relating to their account we
reply via email or phone.
LINKS TO OTHER SITES
This Web site contains links to other sites. Please be aware that we,
WHRDG, are not responsible for the privacy practices of such other
sites. We encourage our data subjects to be aware when they leave our
site and to read the privacy statements of each and every Web site that
collects Personal Information. This policy applies solely to information
collected by this Web site.
NOTIFICATION OF POLICY
Please note that this policy may be amended, from time to time. If we
policy, and other places we deem appropriate so our data subjects are
always aware of what information we collect, how we use it, and under
what circumstances, if any, we disclose it. We will use information in
collected. Any such changes will comply with the EU Safe Harbor
WEB SITE TERMS AND
By using the Web site, you agree to the terms and conditions set forth
herein. Furthermore, you acknowledge and agree that the documents and
articles contained on the Web site are the property of WHRDG and may
contain copyrighted materials, proprietary trademarks and trade names of
WHRDG. No material from any Web site owned, operated, licensed or
controlled by WHRDG may be copied, reproduced, republished, uploaded,
posted, transmitted or distributed in any way.
Commercial enterprises seeking to do business with WHRDG should not
submit unsolicited confidential or proprietary information to WHRDG’s
Web site. WHRDG reserves the right to use or disclose unsolicited
information for any purpose.
WHRDG makes no representations about the content and suitability of the
information in the Web site for any purpose. The articles, information
and works provided in the Web site are provided "AS IS", WITHOUT ANY
WARRANTY OF ANY KIND, EITHER EXPRESSED OR IMPLIED, WHETHER CONTRACTUAL
OR STATUTORY, INCLUDING, BUT NOT LIMITED TO, ANY IMPLIED WARRANTIES OF
MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT OR
OTHERWISE. WHRDG assumes no liability for the use or interpretation of
information contained herein. Decisions based on such information are
the responsibility of the data subject. WHRDG is not liable for any
direct, indirect, special, incidental or consequential damages arising
out of the use, or the inability to use, the material on the Web site.
If you do not agree to these terms and conditions, do not use the Web
If data subjects have any questions or suggestions regarding this
policy, please contact us at: CustomerRelations@WHRDG.com