Privacy Policy
Our Commitment
Twinstrand Therapeutics Inc. is committed to protecting the privacy and security of personal information in our custody or control. This policy explains the types of personal information we collect, how it is used, and the steps we take to ensure that the privacy of personal information is appropriately protected. Our policies and practices have been designed to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and corresponding current provincial personal information laws. This policy applies to individuals who we deal with in Canada including employees, shareholders, researchers, patients, customers, health care professionals and others.
Who is Twinstrand?
For the purposes of this Privacy Policy “Twinstrand” means Twinstrand Therapeutics Inc. and all affiliated companies. Twinstrand is a biopharmaceutical company focused on the discovery, development and commercialization of therapeutics for cancer, viral and parasitic diseases. The scientific platform is based upon the creation of prodrugs using patient plant toxins. While Twinstrand performs its own research and development, clinical trials are performed by other organizations pursuant to contractual arrangements.
Personal Information
Personal information is information that refers to an identifiable individual and includes information recorded in any form. Personal information includes such things as age, income, date of birth, ethnic origin, unique identification numbers, medical and financial data. Standard “business card” contact information is not considered personal information.
Purposes for Collection
Twinstrand collects personal information from its employees in order to establish, manage and conclude the employment relationship. Typically the information collected at the recruitment stage is used to evaluate candidates. On hiring, certain information is collected to establish the employment relationship and enrol the individual in applicable programs. During employment, information is collected to review and evaluate the employee’s performance.
Twinstrand collects certain information from directors and investors in order to manage those relationships and to comply with applicable law.
Twinstrand may collect personal information from organizations who are conducting product trials or research evaluations, for the purpose of advancing development of organization’s research and products.
On occasion Twinstrand may collect personal information from others for purposes related to its business.
We will identify the purposes at the time the information is collected.
Twinstrand will also collect information as required or permitted by applicable law.
Types of Personal Information Collected
Clinical trial information, if obtained, would usually be in anonymized statistical form. On occasion research results may include identifier data and personal health information reasonably related to the research and trial in question.
For employees, we collect information such as employment and education history, medical/spousal information for benefit plans, social insurance numbers (used only for government filings), photo ID for legal and filing purposes, banking information for payroll or any financial transactions, activity logs, performance evaluations and sick reports.
For shareholders, directors and officers (and other individuals as required) certain information is collected and disclosed in compliance with the information requirements of various laws.
For researchers and peer reviewers, information may include professional qualifications, employment, education and information required by regulators or by contract between Twinstrand and government and / or private funders.
Obtaining Consent
Generally, Twinstrand obtains consent to collect, use or disclose personal information except where consent is not required by law. The method of obtaining consent is appropriate to the type and sensitivity of personal information being collected, used or disclosed. In appropriate circumstances we collect information indirectly from third party sources such as medical institutions, physicians and investment counsellors.
For employees in British Columbia, the applicable law implies consent for the collection, use and disclosure of personal information in circumstances reasonably related to the establishment, management and conclusion of the employment relationship. In some cases, we will ask for express consent to collect, use or disclose personal information where such information would be considered sensitive or outside our normal procedures. For example, we would obtain express consent in the event we require a “background check” before hiring an individual.
An individual can always choose not to provide us with certain information, change their consent preferences or withdraw consent. However, in such circumstances we may not be able to provide the applicable product or service or continue to maintain a contractual or employment relationship.
Information Updates
Twinstrand may periodically distribute newsletters, press releases, announcements or other material providing updates about Twinstrand. An individual can choose to receive this material by adding their name to our subscriber list at info@twinstrand.com. A subscriber can unsubscribe at any time by notifying info@twinstrand.com.
Limits on Collection
Twinstrand typically collects only personal information reasonably required to provide products and services or to maintain the relationship. If the personal information we require is collected for a different reason, we will give notice of the reason and obtain consent before or at the time the information is collected, used or disclosed. Twinstrand will only collect personal information by fair and lawful means.
Limits on Use, Disclosure and Retention
Except as required or permitted by law, Twinstrand uses and discloses personal information only for the purposes it was collected. Twinstrand does not sell or rent personal information to any organization or person for any reason. If Twinstrand or a substantial part of our business is sold or otherwise transferred to a third party, personal information may be transferred as well, subject to appropriate safeguard and restrictions. We will provide notice of any transfer of personal information in connection with such a major transaction. In addition to the above, we may also share information with third parties acting on our behalf. We will use reasonable efforts to ensure that personal information, if outsourced in this fashion is used in a manner that is consistent with this Policy.
Twinstrand may disclose or collect information as permitted or required by law, for example:
- to a government institution or other person or entity that has asserted its lawful authority to obtain the information;
- where we have reasonable grounds to believe the information could be useful in the investigation of unlawful activity;
- to comply with a subpoena or warrant or an order made by a court, person or entity with jurisdiction to compel the production of information;
- to comply with court rules regarding the production of records and information;
- to our legal counsel;
- in the establishment, administration or termination of an employment relationship;
- to meet ethical requirements or obligations imposed by self-regulatory bodies, physicians, hospitals or other health care institutions;
- if the information is publicly available;
- in connection with the financing, insuring, sale, assignment or licensing of Twinstrand’s business or a division thereof, in accordance with requirements imposed by law;
- to assist in or coordinate product recalls;
- to conduct surveys and questionnaires; and
- to monitor compliance with research protocols and conditions imposed on clinical trials.
Twinstrand retains personal information only as long as it is required for our business relationship or as required by federal or provincial laws, subject to reasonable industry practices for records retention.
Accuracy
Twinstrand makes reasonable efforts to keep personal information in its custody or control up to date, accurate and relevant for its intended use. However, we rely on individuals to update us with appropriate information changes.
An individual may request access to the personal information we have on record in order to verify its accuracy. Please refer to the “Contact” section below.
Security
The security of personal information is a high priority for Twinstrand. We maintain appropriate safeguards and security measures to protect personal information, whether recorded on paper or captured electronically, against unauthorized access, disclosure or misuse, including:
- physical security measures such as restricted access facilities and locking filing cabinets;
- electronic security measures for computerized personal information such as a password protection and encryption where appropriate;
- organizational processes such as limiting access to personal information to a selected group of individuals; and
- reviewing contractual obligations with third parties who need access to personal information to verify they are required to protect and secure personal information as appropriate.
Although we cannot take responsibility for any theft, misuse, unauthorized disclosure, loss, alteration or destruction of data by a third party, we take reasonable precautions to prevent such occurrences.
Privacy Practices
Twinstrand is committed to providing understandable and easily available information about our privacy policy and practices related to the management of personal information. This policy and any related information is available at all times on our website, www.twinstrand.com under “Privacy Policy,” or upon request. To contact us, please refer to the “Contact” section below.
Access to Personal Information
An individual can request access to their own personal information to verify, update, or correct it, and to have any obsolete personal information removed, to understand how it has been used and disclosed.
Subject to certain exceptions prescribed by law, and provided we can authenticate identity, an individual will be given reasonable access to their personal information, and will be entitled to challenge the accuracy and completeness of the information and to have it amended as appropriate.
An individual can also ask us to change their preferences for our publications, to advise that they do not wish to receive any further communication from us.
We will respond to requests for access to, changes to, or removal of personal information in a timely manner.
Questions and Concerns
Twinstrand will respond in a timely manner to questions, concerns and complaints about the privacy of personal information and our privacy policy and practices.
Contact
E-mail us at: privacy@twinstrand.com
Call us at: 604.415.7180
Write us at: 8081 Lougheed Highway, Burnaby, BC, V5A 1W9, Attention: Privacy Officer
Changes to this Privacy Policy
To accommodate changes in our service, the technology, and legal developments, this Policy may change over time. We may add, change, or remove portions of this Policy when we feel it is appropriate and such changes become effective upon posting.