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Privacy Policy for Symphony Research

Introduction

Symphony Research, a clinical research site located in Jacksonville, FL, is committed to protecting the privacy and confidentiality of personal information entrusted to us by our research participants, clients, and other individuals. This Privacy Policy outlines how we collect, use, store, and protect personal information in accordance with applicable laws and regulations, including the Health Insurance Portability and Accountability Act (HIPAA) and the General Data Protection Regulation (GDPR) where applicable. Our policy ensures that personal information is not shared with third parties unless explicitly requested by the individual to whom the data pertains or as required by law.

1. Scope of This Policy

This Privacy Policy applies to all personal information collected by Symphony Research in the course of conducting clinical research studies, managing participant data, and engaging with clients or other stakeholders. Personal information includes any data that can be used to identify an individual, such as name, contact details, medical history, or other sensitive information provided during participation in clinical trials or related activities. This policy also includes our SMS Terms and Conditions, detailed in Section 15, which govern the use of text messaging for communication with participants.

2. Information We Collect

Symphony Research may collect the following types of personal information:

  • Personal Identifiers: Name, address, phone number, email address, and other contact details.
  • Health Information: Medical history, current health status, medications, and other health-related data relevant to clinical research studies.
  • Demographic Information: Age, gender, ethnicity, and other demographic details required for research purposes.
  • Study-Specific Data: Information collected during clinical trials, such as test results, survey responses, or other study-related metrics.
  • Other Information: Any additional data voluntarily provided by individuals or required to facilitate participation in research studies.

We collect this information directly from individuals through informed consent forms, interviews, questionnaires, medical assessments, or other research-related processes.

3. How We Use Personal Information

Symphony Research uses personal information solely for the purposes of conducting clinical research and managing related activities. These purposes include:

  • Research Study Execution: To enroll participants, conduct clinical trials, and analyze study results.
  • Participant Communication: To contact participants regarding study updates, appointments, or follow-ups, including via SMS as outlined in Section 15.
  • Regulatory Compliance: To meet legal and regulatory requirements, such as reporting to institutional review boards (IRBs) or regulatory authorities.
  • Safety Monitoring: To ensure participant safety by monitoring adverse events or other health-related outcomes.
  • Administrative Purposes: To manage study logistics, such as scheduling or coordinating with research staff.

Personal information is processed in a manner that ensures its confidentiality and is only used for the specific purposes for which it was collected.

4. Sharing of Personal Information

Symphony Research does not share personal information with any third parties unless:

  • Explicit Consent is Provided: Personal information will only be shared with external entities if the individual to whom the data pertains explicitly requests or consents to such sharing in writing.
  • Required by Law: We may disclose personal information if required to do so by law, court order, or other legal processes, such as to comply with regulatory audits or investigations.
  • De-Identified Data: We may share de-identified or aggregated data (data that cannot be linked to an individual) with study sponsors, researchers, or other entities for research analysis, provided it complies with applicable regulations and does not compromise individual privacy.

We ensure that any data shared under these circumstances is handled in compliance with HIPAA, GDPR, and other applicable privacy laws.

5. Data Security

Symphony Research employs robust physical, technical, and administrative safeguards to protect personal information from unauthorized access, use, or disclosure. These measures include:

  • Encryption: Sensitive data, including SMS communications, is encrypted during storage and transmission.
  • Access Controls: Access to personal information is restricted to authorized personnel who require it for legitimate research purposes.
  • Secure Storage: Physical and electronic records are stored in secure environments with restricted access.
  • Staff Training: All employees and research staff are trained on privacy and data protection protocols to ensure compliance with applicable regulations.

6. Data Retention

Personal information is retained only for as long as necessary to fulfill the purposes for which it was collected, including meeting regulatory or legal requirements. Once the retention period expires, data is securely destroyed or de-identified in accordance with applicable laws and best practices.

7. Individual Rights

Individuals whose personal information is collected by Symphony Research have the following rights, subject to applicable laws:

  • Access: You may request access to the personal information we hold about you.
  • Correction: You may request corrections to inaccurate or incomplete personal information.
  • Deletion: You may request the deletion of your personal information, subject to legal or regulatory retention requirements.
  • Restriction of Processing: You may request restrictions on how your personal information is processed.
  • Data Portability: You may request a copy of your personal information in a structured, commonly used, and machine-readable format.
  • Withdraw Consent: If you have provided consent for data processing, including SMS communications, you may withdraw it at any time, though this may affect your participation in a research study.

To exercise these rights, please contact our Privacy Officer using the contact details provided in Section 11.

8. Informed Consent

Before collecting personal information, Symphony Research obtains informed consent from participants, clearly explaining the purpose of data collection, how it will be used, and any potential sharing (with consent). Participants are informed of their rights, including those related to SMS communications, and provided with a copy of this Privacy Policy.

9. Third-Party Service Providers

Symphony Research may engage third-party service providers (e.g., data storage, analysis, or SMS communication platforms) to support research activities. These providers are bound by contractual agreements to maintain the same level of data protection and confidentiality as outlined in this policy. Personal information is only shared with such providers if explicitly consented to by the individual or required for study purposes, and only in a manner compliant with applicable laws.

10. International Data Transfers

If personal information is transferred outside the United States (e.g., for multi-site international studies), Symphony Research ensures that such transfers comply with applicable data protection laws, including GDPR for European residents. Appropriate safeguards, such as standard contractual clauses, are implemented to protect personal information during international transfers.

11. Contact Information

For questions, concerns, or to exercise your rights regarding your personal information or SMS communications, please contact our Privacy Officer at:

‍Symphony Research
3604 University Blvd S, Ste 100, Jacksonville, FL 32256Email: privacy@symphonyresearch.comPhone: (800) 711-2006

12. Changes to This Privacy Policy

Symphony Research may update this Privacy Policy periodically to reflect changes in legal requirements, research practices, or operational needs, including updates to our SMS Terms and Conditions. Any updates will be communicated to participants and stakeholders, and the revised policy will be made available on our website and at our research facility.

13. Compliance with Laws

Symphony Research is committed to complying with all applicable federal, state, and international privacy laws, including but not limited to HIPAA, GDPR, the Federal Policy for the Protection of Human Subjects (45 CFR Part 46), and the Telephone Consumer Protection Act (TCPA) for SMS communications. We work closely with IRBs and regulatory authorities to ensure our practices align with ethical and legal standards.

14. Complaints

If you believe your privacy rights have been violated, including issues related to SMS communications, you may file a complaint with our Privacy Officer using the contact details in Section 11. You also have the right to file a complaint with a supervisory authority, such as the U.S. Department of Health and Human Services (for HIPAA-related concerns), a relevant data protection authority (for GDPR-related concerns), or the Federal Communications Commission (for TCPA-related concerns).

15. SMS Terms and Conditions

Symphony Research offers an SMS communication service to provide participants with timely appointment reminders for clinical research studies. By opting in to receive SMS messages, you agree to the following terms and conditions:

15.1 Types of Messages

Symphony Research will only send SMS messages for the purpose of appointment reminders related to your participation in clinical research studies. These messages may include:

  • Confirmation of upcoming study-related appointments.
  • Reminders of appointment dates, times, and locations.
  • Instructions or preparations required for the appointment (e.g., fasting or bringing specific documents).

No other types of messages, such as promotional or marketing content, will be sent via SMS.

15.2 Frequency of Messages

Symphony Research will send one SMS message per day for each scheduled appointment, starting no earlier than 24 hours prior to the appointment time, unless otherwise requested by the participant or required for study purposes. If no appointment is scheduled, no SMS messages will be sent.

15.3 Opt-In and Consent

Participation in the SMS communication service is voluntary. You must provide explicit consent to receive SMS appointment reminders, typically through the informed consent process or a separate opt-in form. Consent can be withdrawn at any time by following the opt-out instructions below.

15.4 Opt-Out

You may opt out of receiving SMS messages at any time by:

  • Replying "STOP" to any SMS message from Symphony Research.
  • Contacting our Privacy Officer at the contact details provided in Section 11. Upon opting out, you will no longer receive SMS appointment reminders, though this may affect your ability to receive timely updates about study appointments.

15.5 Costs

Symphony Research does not charge participants for receiving SMS messages. However, standard messaging and data rates may apply as per your mobile carrier’s plan. Please check with your carrier for details.

15.6 Privacy and Security

SMS messages containing personal information, such as appointment details, are sent through secure platforms compliant with HIPAA and other applicable privacy laws. However, SMS is not an inherently encrypted communication method, and participants should be aware of potential risks. Symphony Research limits the content of SMS messages to minimize the inclusion of sensitive personal information.

15.7 Contact for SMS-Related Inquiries

For questions or concerns about our SMS communication service, please contact our Privacy Officer using the contact details in Section 11.

Effective Date: October 27, 2025.

This Privacy Policy, including the SMS Terms and Conditions, reflects Symphony Research’s commitment to safeguarding your personal information and ensuring transparency in our data and communication practices. We value your trust and strive to maintain the highest standards of privacy and confidentiality in all our clinical research activities.