Ensemble Strategies Inc. Privacy Policy
Ensemble Strategies and what we do
Ensemble Strategies is a strategy company. We partner with organizations in the health sector to help build strategies/plans for health programs, health policies, communication campaigns, education courses and marketing plans.
Our role when partnering with these organizations is to conduct research with groups that are relevant to their business objectives and then to summarize the results into a plan that clients can use to finalize their strategy.
As well as doing research, from time to time, we facilitate advisory board meetings or internal workshops for our clients. For these types of projects our role is to plan the meeting activities and act as moderators to ensure everyone is engaged and provides feedback. We also summarize the results of these meetings in a report/plan that clients use to finalize their strategy. We are not involved in managing the logistics of these meetings.
For all our projects, we furnish summary reports. Reports do not include people’s names or contact information. There is no way to tie individual comments in a report to any single individual.
People/groups we engage in research, Advisory Board meetings and workshops
The people we engage in research or in workshops depend on our clients’ business objectives. Some examples of the groups we more commonly speak with include: members of the general public, people with specific health conditions, people caring for individuals with specific condition, health professionals (for example doctors, nurses, pharmacists) and employees within our clients’ organizations.
When you participate in our market research surveys and events, your personal privacy will be protected. You can be assured of the following:
We will not make your Personal Information available to anyone without your knowledge unless it is for research purposes only or if required by law (as described in this policy). This protected personal information includes your name, address, phone number and e-mail address.
We will never try to sell you anything and we will never sell your name to anyone. That is not our business. We are not telemarketers or direct marketers. We are market researchers interested only in your opinions.
Your decisions about participating in a study, responding to specific questions, or discontinuing participation will be respected without question.
The rules we follow
Respecting the privacy of all those individuals we interact with, and maintaining their trust is of paramount importance to us. Ensemble Strategies demonstrates our commitment to your privacy by complying with the laws and regulations under applicable privacy laws including the Personal Information Protection and Electronic Documents Act (PIPEDA), Canada’s federal private-sector privacy law.
The purpose of this Privacy Policy is to inform you about the Personal Information (“Personal Information”) we collect about you. It outlines how we collect, use and disclose that information when you participate in one of our projects. This policy will also explain you how you can verify the accuracy of your information submitted to and how you may correct that information.
In addition to this Policy, Ensemble Strategies adheres to the requirements of the Interactional Chamber of Commerce (ICC/European Society for Opinion and Market Research (ESOMAR)’s International Code on Market, Opinion and Social Research and Data Analytics which can be found at https://www.esomar.org/what-we-do/code-guidelines
If you have any questions regarding our Privacy Policy and how we handle private information please contact our Privacy Officer:
Yola Zdanowicz
CEO
Ensemble Strategies Inc.
88 Mavety Street
Toronto, ON. M6P 2L6
416 882 4943
yola@ensemblestrategies.com
Scope of this Privacy Policy
This Policy does not cover the collection of information that is:
Non-personally identifiable or non-personal information;
Your name, business title, business address and telephone number and fax in your capacity as an employee of an organization;
Publicly available information.
The type of Personal Information we collect
When we engage people in research, we ask them about their opinions and their experiences. Everyone provides consent to participate in our projects, whether it's a research project or a strategic workshop or Advisory Group meeting.
The information that we collect during our projects could include Personal Data, including but not limited to:
Demographic information (age, gender, income range, household composition, language preference, etc.)
Info on education, employment status and/or occupational background
Health related information (disease, conditions, and treatments)
Info on hobbies, interests
Info on philosophical beliefs
We store as little contact or “identifier” information as possible (first and last name, address, email address, fax and phone number). As much as possible, we work with anonymized data.
We store no contact or identifier information for individuals who participate in our quantitative research projects (online check box type) surveys; participants are completely anonymous to Ensemble Strategies.
The situations for which we may have contact or identifier information include, but are not limited to:
In-depth interview or online forum projects where moderators need to call someone to conduct the interview or send them a link via email to an online platform.
A list of health care professionals or of people with specific traits that has been purchased from a list supplier. These lists are sometimes used as a starting point for recruiting people for research. Everyone on these lists has given permission to the list supplier to be contacted for research.
List privacy and security rules are outlined in contracts between our clients and Ensemble Strategies and adhere to PIPEDA standards.
These lists are destroyed after the completion of a research project.
While lists might help with recruitment efforts, Ensemble does not know the identity of the physicians who ultimately agree participate in quantitative (online check box) surveys.
For strategic workshop or advisory boards where we might be sending pre-meeting exercises to these individuals or calling them by name when we facilitate the meeting or workshop.
Adverse events AEs (i.e. side effects, improper use or complaints) related to a prescription medication that is made by a client sponsoring a research product. Prior to health studies, individuals are given the choice to share or not share their contact information in the event of a reported AE so the pharmaceutical company can follow up on the event, ask additional questions and submit the information to Health Canada. If a participant gives permission to share their contact details, then information about only the AE is submitted to our client along with the person’s contact information. If permission is not given, the report is submitted without any contact information.
For projects where contact and identifier information are needed during the recruitment process, we store this information separately from individuals detailed answers to interviews, on-line forums, workshop or final survey research questions.
How we collect information
Ensemble Strategies does not directly recruit participants for research. We subcontract this work to specialty recruitment or online research panel firms who recruit people on our behalf. These firms also handle all details regarding the payment of research participants.
These firms collect your Personal Information by fair and lawful means. These firms may use (1) their own pre-recruited panels of people who have agreed to participate in ongoing research or (2) they might reach out to the wider community using publicly available lists or lists that have been purchased from other organizations. All individuals on purchased lists have given permission to be on these lists (“opt-in lists”).
Ensemble Strategies does not recruit participants for Strategic Workshops or Advisory Boards. Our clients make these arrangements and prepare contracts with these individuals through their legal departments and pay participants directly (if appropriate).
In all cases, the firms above follow Personal Information Protection and Electronic Documents Act (PIPEDA), Canada’s federal private-sector privacy laws when recruiting, collecting, and storing your Personal Information.
Ensemble Strategies’ role in different types of projects is documented below:
For online quantitative (check box) surveys: Design the questionnaires. While we don’t host these projects on our internal system, we analyze and summarize the results on the back end using anonymized data files.
For qualitative (interview, focus groups, online storytelling projects): Design the recruitment screening questionnaires, any pre interview exercises as well as the interview guides for all. We act as moderators to engage people in these types of projects. We collect and store all the output from these initiatives, analyze and summarize the results on the back end using anonymized data.
For Strategic workshops/Advisory Boards: Design the pre-meeting exercises, workshop/Advisory Board agenda and discussion guides, facilitate the meeting and summarize the results on the back end using anonymized data.
To whom Personal Information is disclosed
We will not make your Personal Information available to any third party without your knowledge, unless it is for research purposes or required by law, as further specified below.
The only exceptions when we may disclose your Personal Information and/or survey responses to third parties are as follows:
To a client of Ensemble Strategies who commissioned the research study you participated in, who is contractually bound to keep the information confidential and use it only for research or statistical purposes (this will not include your name or contact information unless you have shared it for adverse event reporting purposes);
To a third party engaged by Ensemble Strategies to perform functions on its behalf, such parties are restricted from using your Personal Information in any way other than to provide services to Ensemble Strategies;
You consent to sharing your identifying information and individual responses with a third party for a specified purpose (e.g. in the case of Advisory Boards and Strategic Workshops);
In the rare but possible circumstance that the information is subject to disclosure pursuant to judicial or other government subpoenas, warrants, orders or for similar legal or regulatory requirements. In that specific case, we will consult with our attorney before responding to any request for the information.
How we keep Personal Information safe
Ensemble Strategies has implemented commercially reasonable safeguards and precautions to protect your personal information, including technical and organizational measures against unauthorized access, improper use, alteration, unlawful or accidental destruction, and accidental loss. These measures include encryption protocols, two factor authentication, firewalls, continuous malware monitoring, antivirus solutions, etc. Access to personal information is restricted to subcontractors who have a need to know and who are required to maintain the confidentiality and security of information.
Client needs and/or contracts dictate how long information is kept. Ensemble Strategies builds long term corporate and brand strategies with its client and therefore accesses prior project information on an ongoing basis. In addition, specific Health Canada and Pharmaceutical company regulations require adverse event reports to be kept for a minimum of 10 years.
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Consent
Ensemble Strategies and/its subcontractors obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information. You may provide your consent to either orally or in writing. When you participate in quantitative (check box) survey research you will complete the questionnaire yourself.
When you participate in qualitative studies (interview, focus groups, online storytelling projects) or in Advisory Board meetings or Strategic workshops, sessions will be moderated by a senior researcher/facilitator. These projects may be recorded or videotaped and there may be others listening or viewing for note-taking, training, or research evaluation purposes. To protect your privacy, only your first name or title (e.g. Dr) will be used during discussions. You will be asked to give your consent to any recording and/or to having individuals listen or view the interviews.
You are always free to choose whether to participate in research, Advisory Boards or Strategic Workshops, and are free to stop participating at any time.
Transparency
Participants have the right to request an update, modification or deletion of the Personal information they have shared. Upon your written request (and to the extent required and permitted by law) we will give you access to any of the Personal Information we have collected on you.
To request this Personal Information, we ask that you submit your request in writing our Privacy Officer at the e-mail address or postal address listed at the beginning of this Privacy Policy. We will attempt to fulfill the request within 30 days and will include an explanation of what the information is being used for and to whom it has been disclosed, if applicable.
If you are a member of a research panel that this owned and run by a subcontractor that Ensemble Strategies has hired to recruit research participants your written request will also be shared with the relevant firm given that they may have originally collected and stored your Personal Information.
In certain situations, we may not be able to give you access to all of your Personal Information. This may occur when:
Providing access to Personal Information would be likely to reveal Personal Information about a third party;
Disclosing the information would reveal confidential commercial information.
If we deny your request for access to your Personal Information, we will advise you of the reason for the refusal.
Subcontractor Relationships
Ensemble Strategies expects third party service providers to adhere to applicable company policies and standards in the course of providing products or services to Ensemble Strategies, for example:
Fundamental principles of the Personal Information Protection and Electronic Documents Act (PIPEDA), Canada’s federal private-sector privacy law.
Confidentiality or non-disclosure agreements that govern the sharing of sensitive data, documents or project discussions.
Pharmaceutical Adverse Event (AE) Training & AE Reporting Policies.
Holding specific amounts and types of professional insurance.
International Anti-Bribery & Anti-Corruption Principles (delineated by pharmaceutical companies and government).
Clients' Privacy Policies.
Clients’ Publication & Presentations Policy.
How Ensemble Strategies Manages a Privacy Breach
Ensemble Strategies has been successful in ensuring full security and has never experienced a privacy breach to date.
Ensemble Strategies protocol of detailing with a potential privacy breach involves a shutdown of the system ensuring the situation is quarantined and allowing the IT team to identify the issue at hand and take corrective action.
In the event of a breach, Ensemble Strategies’ Privacy Officer will be notified. She, Ensemble Strategies’ IT consultants and CyberScout (Cyber Risk Specialists) would develop a detailed response plan.
Any impacted clients and Ensemble Strategies research/project participants would be identified.
Following the containment of the breach and resolution, the Ensemble Strategies team will proceed with a full system check and security enhancements as needed.
Changes to this Privacy Policy
We may update and make changes to this policy from time to time, consistent with applicable data protection and privacy laws and principles. Any changes in the policy will be posted on our website. We encourage you to periodically review our Privacy Policy for the latest information on our privacy practices.