Introduction
Medpace, Inc. (Medpace) is committed to respecting the privacy of clinical research subjects. Not only
does Medpace strive to collect, use and disclose personal information in a manner consistent with the laws
of the countries in which it does business, but it also has a tradition of upholding the highest ethical
standards in its business practices. The Safe Harbor Privacy Policy (the "Policy") sets forth the privacy
principles that Medpace follows with respect to personal information transferred from the European
Economic Area (EEA) which includes the member states of the European Union (EU) plus
Iceland, Liechtenstein and Norway, to the United States.
Scope
This Policy applies to all personal information received by Medpace from the
EEA in any format, including electronic, paper, or verbal.
Privacy Policy
Medpace is committed to respecting the privacy of individuals. Medpace has enacted internal procedures to
repeatedly review and monitor the use of personal information and to ensure it is used responsibly and that
we comply with internationally recognized standards of privacy protection. Internationally recognized
standards require that the processing of personal data, both automated and manual, meet the following data
protection principles:
1) NOTICE: When personal information is collected from individuals in the EEA, they will be
informed of the purpose for which the information is collected and how the information will be used. The
third parties to whom any information may be disclosed will be disclosed to the individual. Notice will be
provided in clear and conspicuous language when individuals are first asked to provide personal
information.
2) CHOICE: Organizations must give individuals the opportunity to choose (opt out) if their
personal information will be disclosed to a third party or used for a purpose incompatible with the purpose
for which it was originally collected or subsequently authorized by the individual. Affirmative or explicit
(opt in) choice must be given if the information is to be disclosed to a third party or used for a purpose other
than its original purpose or the purpose authorized by the individual.
3) DATA INTEGRITY: Medpace will use personal information in ways that are compatible with
the purpose for which the data was collected. Medpace will take reasonable steps to ensure that personal
information is relevant to its intended use, accurate, complete and current.
4) TRANSFER TO AGENTS: Medpace will obtain assurances from its agents that the agents will
safeguard personal information consistently with this Policy. Where Medpace has knowledge that an agent
is using or disclosing personal information in a manner contrary to this Policy, Medpace will take
reasonable steps to prevent or stop the use or disclosure.
5) ACCESS AND CORRECTION: Medpace will take reasonable steps to permit individuals to
correct, amend, or delete information that is demonstrated to be inaccurate or incomplete except where the
burden or expense of providing access would be disproportionate to the risks to the individual's privacy or
where the rights of persons other than the individual would be violated.
6) SECURITY: Medpace maintains a high level of security, particularly in relation to data.
Computer equipment, networks, programs, data and documentation are maintained to a high standard, and
precautions to protect personal information in its possession from loss, misuse, unauthorized access,
disclosure, alteration, and/or destruction.
7) ENFORCEMENT: Medpace will ensure adherence to this Policy by ensuring (a) readily
available and affordable independent recourse mechanisms so that each individual's complaints and
disputes can be investigated and resolved and damages awarded where the applicable law or private sector
initiatives so provide; (b) procedures for verifying that the commitments companies make to adhere to the
Safe Harbor Principles have been implemented; and (c) obligations to remedy problems arising out of a
failure to comply with the principles exist. Sanctions must be sufficiently rigorous to ensure compliance by
the organization. Medpace will provide an annual self certification letter to ensure appearance on the list of
Safe Harbor participants.
DISPUTE RESOLUTION
Any questions or concerns regarding the use or disclosure of personal information should be directed to the
Medpace Privacy Officer. Medpace will investigate and attempt to resolve complaints and disputes
regarding the use and disclosure of personal information in accordance with the principles contained in this
Policy. For complaints that cannot be resolved between Medpace and the complainant, Medpace has
agreed to participate in the dispute resolution procedures of the panel established by the European data
protection authorities to resolve disputes pursuant to the Safe Harbor Principles.
TRAINING
Medpace has provided its employees with appropriate training to ensure that all individuals who process
personal information are fully aware of their responsibility with respect to data protection.
LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by Medpace to these Safe Harbor Principles may be limited (a) to the extent require to respond
to a legal or ethical obligation; and (b) to the extent expressly permitted by an applicable law, rule or
regulation.
INTERNET PRIVACY/LINKS TO THIRD PARTY WEB SITES
Medpace sees the Internet and other advanced electronic technology as valuable tools for communicating
and interacting with others. Medpace recognizes the importance of maintaining the privacy of information collected online. Some of our Web pages may contain links to Web sites outside the Medpace organization.
Linked Web sites are not under the control of or endorsed by Medpace. This Policy does not apply to
linked Web sites outside the Medpace organization.
PRIVACY POLICY CHANGES
Medpace reserves the right to change, modify or amend this Policy at anytime. If you have questions
regarding this privacy policy, please send your inquiries to privacy@medpace.com.