The United States Department of Commerce, the EU and Switzerland have agreed on a set of data protection principles and frequently asked questions (the “Safe Harbor Principles”) to enable U.S. companies to satisfy the requirement under European Union and Swiss laws that adequate protection be given to personal information transferred from the EU or Switzerland to the United States. Axio Research adheres to the Safe Harbor Principles and complies with the US-EU Safe Harbor Framework and the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Axio Research 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 Axio Research’s certification, please visit http://www.export.gov/safeharbor/
For purposes of this Policy, the following definitions shall apply:
“Client” means any third party that Axio Research will either provide to or receive from personal information to perform tasks on behalf of and under the instructions of said client.
“Personal information” means any information or set of information that identifies or could be used by or on behalf of Axio Research to identify an individual. Personal information does not include information that is encoded or stripped of all personal identifiable information, or that is publicly available.
“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns the health or sex life of an individual. Axio Research will also treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
The privacy principles in this Policy are based on the Safe Harbor Principles.
NOTICE: Axio Research may collect individual’s personal information directly from individuals or principal investigators in the EU or Switzerland or may receive personal information of individuals through our clients in the US. Consent forms made available to participating individuals for signatures will include information about the purposes for which their personal information will be used, any third parties that their information may be disclosed to, and the choices and means provided to them for limiting the use and disclosure of their personal information. The language used in the consent forms will be clear and conspicuous and will be explained verbally by a member of the PI’s team allowing for any questions or concerns by the individual to be addressed.
CHOICE: Axio Research will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
For sensitive personal information, Axio Research will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
If Axio Research is also the Client, we will provide individuals with reasonable mechanisms to exercise their choices. If the Client is separate from Axio Research, we will abide by this policy to the extent that it does not infringe contractual obligations.
DATA INTEGRITY: Axio Research will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Axio Research will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
TRANSFERS TO AGENTS: Axio Research will obtain assurances from its clients that they will safeguard personal information consistently with this Policy. Where Axio Research has knowledge that a client is using or disclosing personal information in a manner contrary to this Policy, we will take reasonable steps to prevent or stop the use or disclosure.
ACCESS AND CORRECTION: Axio Research collects personal information solely for the purpose of research and/or statistical purposes through our clients. Any access or correction requests would need to be made through the client as Axio is contracted directly with the client.
SECURITY: Axio Research will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration, and destruction.
ENFORCEMENT: Axio Research will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Axio Research determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the Axio Research Privacy Office at the address given below. Axio Research will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between Axio Research and the complainant, Axio Research 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.
Questions or comments regarding this Policy should be submitted to the Axio Research Privacy Office by mail or e-mail at:
Axio Research Privacy Office
2601 Fourth AVE Suite 200
Seattle, WA 98121
If this Policy is revised, a new version and effective date will be posted on the Axio Research website. All revisions will be consistent with the Safe Harbor Principles.