Scope

This Privacy Policy applies to information, including personal information collected by OmniComm Systems, Inc. and its affiliated offices. The document outlines our strong commitment to our customers’ privacy and the protection of personal information. As a company serving global clinical trials your personal information may be used and stored outside of the country you live. We will take any necessary step to ensure that your information is in compliance with this Privacy Policy.

Purpose

The purpose of this policy is to describe OmniComm’s privacy principles set forth by federal and international regulations that govern clinical research, and the Safe Harbor privacy framework regarding transfer and hosting of personal information in electronic, paper, or verbal formats.

General

This Privacy Policy demonstrates our commitment to respect the privacy and the protection of any personal information submitted to and hosted at OmniComm Systems, Inc.. OmniComm Systems, Inc. respects individual privacy and values the confidence of its customers, employees, clinical trial participants, healthcare professionals, investors, business partners, and others. OmniComm Systems, Inc. collects, maintains and uses personal information in a manner that is consistent with the laws of countries in which the organization does business. Data Privacy is taken serious and is implemented in companywide Policies and SOPs.

OmniComm Systems Privacy Commitments

OmniComm Systems complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland.  OmniComm Systems has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  To learn more about the Safe Harbor program, and to view OmniComm Systems’ certification, please visit http://www.export.gov/safeharbor/

OmniComm Systems respects and follows the privacy principles set forth by the Safe Harbor privacy framework including the transfer of personal information in electronic, paper or verbal formats from the member states of the European Union and Switzerland to the United States:

Notice

OmniComm Systems, Inc. informs individuals about the purposes for which it collects and uses personal information. The notice will be provided in clear language in a conspicuous manner. The use of the data is limited to the purpose first identified and no more information is collected than is required to satisfy the purpose. Data used for pharmaceutical research and other purposes when using OmniComm software products should be anonymized when appropriate. Any personal information that is related to the use of the OmniComm clinical trial software products or personal data developed in specific medical or pharmaceutical research studies is the responsibility of the client.
OmniComm Systems, Inc. informs individuals about the type of third party to which OmniComm Systems, Inc. discloses information if any, and offers individuals the choices and means for limiting the use and disclosure of their personal information.

Choice

OmniComm Systems, Inc. offers individuals the option of choice whether their personal information is disclosed to a third party. Individuals can also choose to not have their data shared if the purpose is incompatible with the original purpose of data collection. OmniComm Systems, Inc. provides individuals with reasonable mechanism to exercise their choices.
If sensitive personal information is to be disclosed to a third party or is to be used other than the purpose originally authorized, OmniComm Systems, Inc. will give individuals explicit (opt in) choice, and will disclose the information only after explicit consent of the individual.

Onward Transfer

OmniComm Systems, Inc. ensures by written agreement that our agents and third party providers follow the same privacy principles and data protections principles as OmniComm Systems, Inc.

Security

OmniComm Systems, Inc. provides services internationally and receives information from all over the world. Whenever OmniComm Systems, Inc. is required to transfer personal information, regardless of where this occurs, OmniComm Systems, Inc. protects confidentiality, integrity and availability of personal information by physical and logical security measures. OmniComm Systems, Inc. has written procedures in place regulating the protection of confidential data from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Data Integrity

OmniComm Systems, Inc. takes reasonable steps to ensure that personal information is reliable to its use, that the data is accurate, complete and current. OmniComm Systems, Inc. does not process information that is incompatible with the original purposes for which it has been collected or subsequently authorized by the individual.

Access

Upon request, individuals will be granted reasonable access to personal information that OmniComm Systems, Inc. hold about them. In addition, upon request, OmniComm Systems, Inc. will take reasonable steps to allow individuals to correct, amend, or delete information that is found to be inaccurate or incomplete.

Enforcement

OmniComm Systems, Inc. has written procedures in place that regulate regular internal compliance audits of the privacy principles. Internal audits are conducted by the OmniComm Compliance Committee or by a third party as delegated by the Compliance Committee. The Compliance Committee is comprised of a cross-section of department and affiliate representatives across the companies, who have authority to enforce the policies that are created. The CEO has the ultimate responsibility and authority of managing Quality Systems. Non-compliance issues are investigated and corrective actions are put in place and followed up until resolution for any problems arising out of failure to comply with the principles. Remedy actions could include disciplinary actions, up to and including termination of employees.

Dispute Resolution

Individual complaints are being investigated and remedy actions performed in the same rigorous way as described for non-compliance detected during internal audits (see above, Enforcement).
All individuals are encouraged to please forward any individual complaints, issues, concerns, or questions regarding the collection, the use or disclosure of personal information to:

OmniComm Systems, Inc.

Attention: Compliance Department
2101 West Commercial Boulevard, Suite 3500
Fort Lauderdale, FL 33309, USA

Notification of Policy Changes

If major content changes are made to OmniComm Systems, Inc. Privacy Policy we will outline and post the changes along with the new version on this Web site. The effective date of the revised Privacy Policy will be set forth in this paragraph. This Privacy Policy was last updated on 22-OCT-2010 and is effective as of that date.