Safe Harbor Privacy Policy
Safe Harbor Privacy Policy

Safe Harbor Standards
This Safe Harbor Privacy Statement (the "Statement") sets forth the privacy principles followed by the Novartis Institute for Functional Genomics, d.b.a. the Genomics Institute of the Novartis Research Foundation ("GNF"), in connection with the transfer and protection of "personal information" received from the European Union (EU) and Switzerland.

About The Safe Harbor
The "Safe Harbor" program was jointly established by the United States Department of Commerce and the European Commission, as a method for transferring personal information from the European Union (EU), to companies in the United States. A similar arrangement was later reached between the US Department of Commerce and the Information Commissioner of Switzerland, so that the Safe Harbor program now includes the U.S. - EU Safe Harbor Framework and the U.S. - Swiss Safe Harbor Framework. The Program is a voluntary self-certification process for companies operating in the United States. Companies that certify represent that they are upholding privacy standards for personal information received from the EU and Switzerland that have been accepted by the EU Commission, the Swiss Federal Data Protection and Information Commission and the US Department of Commerce. These standards exceed current US privacy standards. GNF has certified to the Safe Harbor program and makes that same representation.

This Statement governs personal information transferred from countries in the EU or Switzerland (which has adopted substantially similar privacy laws to those of the EU), to the United States on behalf of GNF. It applies to personal information in electronic and off-line formats.

Safe Harbor Privacy Principles
The following privacy principles apply to the transfer, collection, use or disclosure of personal information from the EU or Switzerland by GNF.

Notice: GNF informs individuals in the EU and Switzerland about the purposes for which it collects and uses their personal information, how to contact GNF, the types of third parties with which GNF shares their personal information, and the choice and means GNF offers for limiting the use and disclosure of their personal information.

Consistent with the Safe Harbor requirements, GNF may not be in a position to furnish notice in certain limited situations. Specifically, notice is not required where the processing of EU or Swiss personal information is necessary to respond to a government inquiry; is required by applicable laws, court orders or government regulations; or is necessary to protect GNF 's legal interests and providing notice would interfere with those interests.

Choice: GNF will not process personal information about EU or Swiss individuals for purposes other than those for which the information was originally obtained or subsequently authorized by the individual unless the individual affirmatively and explicitly consents ("opt-in") to the processing, or unless an exception applies. GNF also provides EU and Swiss individuals with the opportunity to withdraw consent at any time ("opt-out"), in which case their personal information will not be further processed. There are certain limitations on the right to opt-out, such as those that apply in the clinical research situation. In that situation, GNF can continue to rely upon personal information already provided by clinical research participants who choose to discontinue participation in a clinical trial, to the extent needed to protect the integrity of the study, but cannot collect any additional personal information about that individual once the written request to withdraw participation is received.

Data Integrity: GNF seeks to ensure that any personal information held about EU and Swiss individuals is accurate, complete, current and otherwise reliable in relation to the purposes for which the information was obtained. GNF collects personal information that is adequate, relevant and not excessive for the purposes for which it is to be processed. EU and Swiss individuals have a responsibility to assist GNF in maintaining accurate, complete and current personal information about them.

Transfers to Third Parties: GNF will only transfer personal information about EU and Swiss individuals to third-parties where the third-party (a) has provided satisfactory assurances to GNF that it will protect the information consistently with this Statement; or (b) is located in the EU, Switzerland or a country considered "adequate" for privacy by the EU or Swiss Commission, and therefore is required to comply with the EU or Swiss data protection laws or substantially equivalent privacy laws depending upon where the personal information originated ; or (c) the third-party has also certified to the Safe Harbor, and is accordingly independently responsible for complying with the Safe Harbor requirements.

Where GNF has knowledge that a third-party to whom it has provided EU or Swiss personal information is processing that information in a manner contrary to this Statement or the Safe Harbor requirements, GNF will take reasonable steps to prevent or stop the processing.

Access and Correction: Upon written request to GNF, GNF will provide EU and Swiss individuals with reasonable access to their personal information. GNF will also take reasonable steps to allow EU and Swiss individuals to review their information for the purposes of correcting their information. There are certain limitations to the Access and Correction rights, as set forth in the US Department of Commerce's Safe Harbor website.

Security: GNF takes reasonable precautions to protect EU and Swiss personal information in its possession from loss, misuse, unauthorized access, disclosure, alteration and destruction.

Enforcement: GNF has established internal mechanisms to verify its ongoing adherence to this Statement. GNF also encourages individuals covered by this Statement to raise any concerns about our processing of their personal information by contacting GNF's Privacy Officer. GNF will seek to resolve any concerns. GNF has also agreed to participate in the dispute resolution programs provided by the European Data Protection Authorities.

Limitation on Scope of Principles: Adherence to these Privacy Principles may be limited to the extent required to meet a legal, governmental, national security or public interest obligation.

How to Contact Us
If you have any questions about our Privacy Statement, please email or write to us at:

Privacy Officer
Novartis Institute for Functional Genomics
10675 John Jay Hopkins Drive
San Diego, CA, USA 92121