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This notice is effective as of 14 March 2001
and last updated 27 March 2012

PPD is committed to respecting the privacy of individuals. We recognize that when you choose to provide us with information about yourself, you trust PPD to act in a responsible manner. PPD has enacted internal procedures to repeatedly review and monitor the use of this information to ensure it is used responsibly and complies with internationally recognized standards of privacy protection. Such international standards include, but are not limited to, the European Union Data Protection Directive [EC/95/46]. Internationally recognized standards require that the processing of personal data, both automated and manual, meet the following data protection principles:

• Data has fair and lawful processing
• Data is obtained only for specified and lawful purposes and is not processed in any incompatible manner
• Data use is adequate and relevant but not excessive
• Data is kept current (where necessary) and accurate
• Data is not kept longer than necessary
• Data processing is in accordance with the rights of data subjects
• Data is protected by appropriate security measures
• Data is not transferred to third parties unless adequate level of data protection exists

PPD 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. PPD 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 PPD’s certification, please visit http://www.export.gov/safeharbor/.

Purposes of Data Processing

PPD processes personal data for specific and limited purposes, which we inform you about when we request information from you. Examples of different purposes include, but are not limited to:

• Investigator data processed to allow PPD to identify and contact individual investigators to ascertain their interest in participating in clinical trials in accordance with their experience and specialty. Investigators selected to conduct clinical trials may also be required to provide additional information to allow for appropriate reimbursement for their participation.
• Individual subject data processed for participation in certain clinical trials (studies conducted in PPD Phase I clinics), and in some instances, in order to assist in patient recruitment.
• Applicant and employee data processed to enable accurate records to be maintained on all applicants and employees documenting information for government reporting requirements, performance, payroll and other items.

Prior to processing personal data, PPD will provide notice to data subjects in a clear and conspicuous language. Dependent on the type of data processing, notice may be given in person, by e-mail, post, telephone or by posting on our website.
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Data Collection

PPD may collect information on its Web pages for reasons such as processing newsletter requests and job applications, and providing investor information. Categories of collected information (if provided by you) include contact information, company information and job search/application information. For example, name, address, phone number, e-mail address, company name, position, resume, desired compensation and/or "cookie" information may be collected to process your request.

Every effort is made to ensure that the information is accurate and up-to-date and all communications with individuals provide easy means of validating, correcting errors and updating information.
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Data Processing

All processing of personal data is, by consent, for the purposes listed above and under the control of the data controller. Individuals have the right to:

• Obtain copies of their data
• Correct their data
• Prevent processing for direct marketing
• Withdraw consent to processing with its consequential effects
• Prevent non-core purpose disclosures
• Prevent trans-border disclosures to third parties where there are inadequate data protection arrangements.

To access personal information held and request corrections, amendments and/or delete information where it is inaccurate, please refer to the "Inquiries, Complaints and Subject Access Requests" section of this policy.
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Data Security

PPD maintains a high level of security, particularly in relation to data. Computer equipment, networks, programs, data and documentation is maintained to a high standard, and access to data and equipment is at all times restricted to appropriate staff.

The handling of medical information obtained in clinical research is governed by national and international data protection regulations and medical confidentiality. Any medical information collected will be maintained under these regulations.
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Release, Sharing or Transference of Data

The information you provide to us will be available to PPD, its subsidiaries and companies working as agents of PPD. Access to data and equipment is at all times restricted to appropriate staff. PPD will not trade, sell, release, share or transfer your personal information for use by any business outside the PPD organization without your consent, or in a form other than what was disclosed to you at the time the information was collected, unless permitted or required by law.

Under some circumstances PPD may be required by law enforcement or judicial authorities to provide personal information as required by law to the appropriate government authorities.

Companies working as agents of PPD or clinical trial sponsors (such as pharmaceutical companies) are required to sign confidentiality agreements or provide assurance agreeing to handle all confidential information containing personal data in accordance with applicable law, including but not limited to, the European Data Protection Directive [EC/95/46].

PPD is a global company and has information databases in different offices throughout the world. PPD may transfer your data to one of its databases outside your country of domicile. If the level of privacy protection in a country does not comply with recognized international standards, PPD will ensure that data transfers to PPD databases in that country are adequately protected.
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Links to Third-Party Websites

Some of our Web pages may contain links to websites outside of the PPD organization. Linked websites are not under the control of or endorsed by PPD. This policy does not apply to linked websites outside the PPD organization. It is recommended that you review the privacy policy of each individually linked website that you choose to visit.
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Cookies

A cookie is a piece of data stored on the hard drive of your computer. PPD enables temporary cookies (a.k.a. session-only cookies) to allow site visitors to easily move from one interactive feature to another, offering visitors a better experience while navigating the PPD corporate Internet site. However, use of a cookie does not link to or reveal personally identifiable information while on our site, unless you explicitly provide that information to us. Furthermore, the cookie will automatically expire after a short period of time and will automatically be removed completely when the Web browser is closed.

Cookies can also enable us to track and target your interests to enhance the experience on our site. They are used to create a profile and can be used for such purposes as notifying you of relevant trade shows or symposia, but only if you opt-in to this feature. Visitors will always be given the choice and the information will not be sold to other organizations.

We receive IP addresses in the normal course of the operation of our website. An IP address is a number assigned to you by your Internet service provider so you can access the Internet. We do not use them to personally identify you or disclose them to others.
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Children's Online Privacy Protection

PPD does not collect or maintain information from our website from individuals we actually know are under the age of 13, and no part of our website is structured to attract anyone under 13 years.
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Training

PPD has provided its employees with appropriate training to ensure that all those who process personal data are fully aware of their individual responsibilities and of management's objectives with respect to data protection.
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Inquiries, Complaints and Subject Access Requests

All communications, queries and subject access requests related to data protection issues should be addressed to:

Executive Director, Global Privacy
PPD
Granta Park
Great Abington,
Cambridge
CB21 6GQ
UK

You may also submit an electronic request for action or response on behalf of PPD. Using reasonable efforts, PPD will promptly respond to any communications regarding our use of personal information. For unresolved disputes between PPD and complainants, PPD has agreed to co-operate with the European Data Protection Authorities (DPAs) dispute resolution procedures. In addition, specific PPD Internet (external) and intranet (internal) Web pages enable you to access and update your profile or other personal information online or provide further instruction on how individuals may obtain copies and update their data via various department resources. Examples would be:

• Investigators entering and maintaining profiles via the PPD website, and
• Employees wishing to obtain and update their personal training records through the PPD Global Learning and Performance Department's Intranet page.
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Privacy Policy Changes

PPD reserves the right to modify or amend this privacy policy. For instance, this privacy policy may need to change as new legislation is introduced or as it is amended. Changes to PPD's privacy policy will be posted on this website. We recommend that you review this policy from time to time.
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