Last revision on 20 September 2023
PSI CRO AG, the parent company and PSI Pharma Support America, Inc., (PSI, we) will need to collect and use information about your professional qualifications and other personal data to manage the employment relationship between the employee and PSI, the employer.
This Data Privacy Notice is an overview of how we process your personal data, namely how we collect, use, storage, and disclose them.
WHICH PERSONAL INFORMATION DO WE PROCESS
Personal Information that we may need to collect about you may relate to the following categories:
Contact: name, e-mail address, phone number, position, department, business location, (previous) residential and registered addresses.
Job, position: job title, job function, department, region, supervisor, etc.
Passport and business travel: date of birth, gender, birth country, birth city, national ID type, national ID, citizenship status, citizenship country, nationality, travel details, national and international passport, visa applications, visa details, etc.
Appraisal: performance rating history, appraisal records, line manager and peer assessment.
Payroll: bank account number, monthly salary amount, tax deductions.
Expense and compensation: company credit card expenditures, company paid expenses, benefits, housing allowances, travel allowances, staff travel details, car or commuting allowances, expenses refund and advances.
Training: processional improvement courses, exam certifications, training records.
User data: data required to provide you with access to company computer systems and networks, e.g., IP address, user password, user login name IDs assigned in the system.
WHAT ARE THE PURPOSES AND LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
PSI will use your personal information for the management, development, maintenance, and control of the employment relationship between you as the employee and PSI. Examples of such processing purposes are managing payroll, ensuring health and safety in the workplace, performing tax accountability, supporting professional career of the employee via conducting appraisals, trainings, promotions, incentives.
PSI may be required to collect information about your working hours, providing you with applicable types of mandatory insurances, etc. When using your personal information for these purposes, PSI will do so to comply with the legal obligation.
PSI needs to perform the activities listed below, and has the legitimate interest to use your relevant personal information to carry out these activities:
- Assigning you a role and tasks in a project/study conducted by PSI for a clinical trial sponsor and managing your engagement into this and other projects/studies in accordance with the study contract.
- Arranging your business-related travelling, enrolling you into corporate and project-related trainings.
- Identifying you in the corporate computer network and systems, creating user accounts to enable your access the corporate resources that you need for work.
- Monitoring access to the office premises via electronic access system and installing video cameras to safeguard you and the company’s assets.
- Monitoring activity of the users accessing the corporate resources, including e-mail and internet, to ensure appropriate computer security.
- Carrying out internal evaluations to build systems to improve our internal business processes.
PSI may be offering you to join a program of social benefits or may need to share photographs picturing you and taken at a team building or other work-related event via PSI public media accounts. For such specific information uses, we will reach out for your consent.
WHO WILL HAVE ACCESS TO YOUR PERSONAL INFORMATION
PSI personnel: As PSI is a global company with worldwide presence, we need to share information, including personal information of our employees, within PSI, to manage our business operations and comply with the applicable laws. This means that all PSI staff will have access to your PRIMA profile, as well as other personal information as needed to enable them to carry out their job responsibilities.
Third party service providers: When we need to process your information to fulfill our employer responsibilities, for instance managing payroll, ensuring health and safety in the workplace, and managing your request for the use of social benefits or advantages; we may need to share some of your personal information with the companies that PSI engages to assist with the provision of such services.
Sponsors, study vendors: When your job responsibilities require you to work as a member of a project team for different clinical studies, PSI will share your contact information, information about your professional qualifications and other relevant personal information with the study sponsors and vendors involved in the study.
Authorities: When we collect information for some of the purposes, we may do so in response to a statutory requirement. In such cases, to comply with the law, we will have to share your information with the authorities. In addition, regulatory authorities will have access to your personal information when this information make part of the study file. There may be other cases when disclosure of your information will be required. We will follow the applicable laws in this regard.
FOR HOW LONG DO WE RETAIN YOUR INFORMATION
PSI will retain your personal information for as long as you are PSI’s employee. After the termination of employment relationship, we may keep your information during the legally established deadlines and to comply with the legal obligations to which PSI is subject.
When you are engaged in a study as a project team member, some of your personal information contained in your CV(s), study-related communication, etc., shall be retained as part of the study file in accordance with the laws applicable to clinical trials.
HOW TO EXERCISE YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
You have the right to request access to, rectification or erasure of your personal information, restriction of processing, as well as object to processing in some cases. You can request a digital copy of the personal information in a technically usable form. You can also withdraw your consent to processing for some purposes, if you initially consented to have your information processed, however please note that in such case the use of your information before you changed your mind, remains lawful.
You may obtain more information about how we use your personal information, including the complete list of purposes for which your information is processed, categories of personal data processed by PSI entity that employed you, etc., as well as file any other enquiry.
For this, please contact PSI Data Protection group and Data Protection Officer at
If you are based in the EU, you have the right to lodge a complaint to the supervisory authority. You will find your national data protection authorities and their contact details following this link: https://edpb.europa.eu/about-edpb/about-edpb/members_en
If you are a resident of California, please read PSI’s California-Specific Description of Privacy Rights
HOW WILL YOU KNOW THAT PSI REVISED THIS NOTICE
PSI reserves the right to modify this Notice as needed to reflect changes in laws, PSI practices and procedures, or requirements imposed by applicable regulation. If changes occur, PSI will notify you of the changes to this Notice that can have an impact on your obligations and rights.