EU Business Ethics Helpline Data Privacy Notice and Consent
The purpose of this Notice is to provide you with clear information concerning the processing of any information that you submit through the Syneos Health, Inc. Business Ethics Helpline (the “Business Ethics Helpline”) and to obtain your consent to the processing of your personal data, as set out below. If you do not accept the terms below, please do not submit any information through the Business Ethics Helpline. Instead, please report this matter to your local Management, Human Resources, or the Legal Department, as appropriate.
This Notice applies to you if you are employed in, or make a report from, any of the European Union Member States, Switzerland or Turkey (together, the “Applicable Jurisdictions”). The data controllers in respect of the Business Ethics Helpline site are the Syneos Health, Inc. operating companies, INC Research LLC, inVentiv Health, Inc. and the INC Research or inVentiv Health entity that employs you or has engaged your services. In the context of the Applicable Jurisdictions, this Notice prevails over all other notices and information provided in relation to the Business Ethics Helpline.
The Business Ethics Helpline is a confidential telephone and online reporting system operated by Convercent, Inc. and provided by Syneos Health, Inc. to allow you to ask questions and to report incidents. Use of the Business Ethics Helpline is entirely voluntary. In some of the Applicable Jurisdictions, only matters relating to accounting, auditing, banking, bribery, or financial issues can be reported through the Business Ethics Helpline. If your concern pertains to issues not listed for your particular country, you are encouraged to report them to local management or through our other established reporting channels. The information you submit will be treated confidentially and communicated on a need-to-know basis only, except as set out below. Because anonymous reporting is discouraged in the Applicable Jurisdictions, we encourage you to submit your name and contact details in order to enable us to follow up with questions.
Please be aware that the information you supply about yourself, your colleagues, or any aspect of the Company’s operations may result in decisions that affect others. Therefore, we ask that you only provide information that, to the best of your knowledge, is correct. While you will not be sanctioned for submitting information in good faith, even if it later turns out to be incorrect, knowingly providing false or misleading information will not be tolerated. In any report you submit, you should only provide information about other individuals where it is strictly necessary to do so and where that information is directly relevant to the matter being reported.
Information collected: The Business Ethics Helpline captures the information you directly provide on a voluntary basis, which may include: your name and contact details, any questions you submit, the name and title of any individuals you may be reporting, and a description of the conduct in question, including all relevant details. We collect information about you that you provide through the Business Ethics Helpline only if you provide consent. We process information relating to individuals other than the submitter because it is necessary to satisfy legal obligations to which we are subject and because we have a legitimate interest in detecting and preventing violations of applicable laws and policies that is not overridden by your interests, rights and freedoms to protect personal data about you. Any information that you provide will be processed in accordance with this Notice.
How the reported information will be used: The reported information will be stored in the Business Ethics Helpline database hosted by Convercent, Inc. (“Convercent”) in the United States and used for the purpose of answering your question(s) or investigating the report. Syneos Health, Inc. through its INC Research/inVentiv Health operating companies will evaluate any information you provide, and may conduct appropriate investigations and take corrective action where necessary.
Data protection laws in the United States may not be as extensive as those in the Applicable Jurisdictions. INC Research, LLC and Convercent adhere to the privacy principles of the EU-U.S. and Swiss-U.S. Privacy Shield Program. To learn more about the Privacy Shield Frameworks, and to view the certifications of INC Research, LLC and Convercent, visit the U.S. Department of Commerce’s Privacy Shield List. For other transfers of personal data to recipients located outside the EU, we have put in place an appropriate data transfer mechanism, such as EU Standard Contractual Clauses, to ensure that your personal data is adequately protected. You may obtain a copy of the relevant data transfer mechanisms that we have put in place by contacting us as detailed below. Unless otherwise required by law, the information in the Business Ethics Helpline database may only be accessed and used by those individuals who are duly authorized by Syneos Health, Inc. and have a legitimate business need to access the information. These individuals may include appropriate Syneos Health, Inc. Human Resources, Legal, Audit, or Management functions and employees, and technical staff at Convercent. These individuals may be located in the United States or in any other country. We also may disclose personal data about you: (i) if we are required to do so by law or legal process; (ii) for the purposes of, or in connection with, any legal proceedings, or otherwise for the purposes of establishing, exercising or defending any legal rights; (iii) to law enforcement authorities or other government entities based on a lawful disclosure request; or (iv) when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.
Your rights: Subject to applicable law, you may have the right to access, correct, obtain restriction of, object to and delete your personal data that are processed in the context of the Business Ethics Helpline. You also have the right to withdraw any consent to the processing of your personal data that you have given at any time. If you wish to exercise any of your data protection rights or if you consider that we have processed your personal data in violation of applicable law, please contact us as detailed below. If you consider that we have processed your personal data in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.
Please note that, under applicable law, individuals you identify through the Business Ethics Helpline may have the right to be informed about the fact that a report has been made. However, we will not reveal your name or identity unless required by applicable law or necessary to conduct a thorough investigation. In addition, all such individuals you identify will have the right to respond to or correct any information you submit.
Information you submit may be retained for as long as is necessary to investigate the reported matters. Such information will be deleted promptly after: (i) it is determined that no investigation is necessary; (ii) the conclusion of any investigation and any legal proceedings; or (iii) such further periods as may be mandated by applicable law, as appropriate. Syneos Health, Inc. may retain aggregated, de-identified records in accordance with applicable law. For additional information, see Convercent Privacy Policy or contact [email protected]
