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Academy Policies

Privacy Policy

Privacy Policy

Last Updated: December 4, 2019

The New York Academy of Sciences (the “Academy,” “we,” “us,” and “our”) is committed to treating your personal information with respect and sensitivity. This privacy policy (this “Privacy Policy”) explains how we may collect, store, use, and disclose personal information when you access or use (1) our website located at www.nyas.org and all of our other websites to which this Privacy Policy is posted (collectively, the “Website”); (2) our New York Academy of Sciences programs, including our Global STEM Alliance programs (“Programs”); and (3) any services, content, and features made available by us through the Website or the Programs (together with the Website and the Programs, the “Services”).

YOUR ACCEPTANCE OF THIS PRIVACY POLICY

By accessing or using the Services, you consent to our collection, storage, use, and disclosure of your information as described in this Privacy Policy. The provisions contained in this Privacy Policy supersede all previous notices and statements regarding our privacy practices with respect to the Services. If you do not agree to every provision of this Privacy Policy, you may not access or use the Services.

We may revise this Privacy Policy from time to time in our sole discretion, subject to applicable law. When we revise this Privacy Policy, we will post a revised version on the Website. The revised Privacy Policy will be effective upon posting on the Website, unless otherwise set forth therein or as otherwise required by applicable law. You are free to decide whether or not to accept a revised version of this Privacy Policy, but accepting this Privacy Policy, as revised, is required for your continued access and use of the Services. If you do not agree to this Privacy Policy or any revised version of this Privacy Policy, your sole recourse is to terminate your access and use of the Services. Except as otherwise expressly stated by us, your access and use of the Services are subject to the version of this Privacy Policy in effect at the time of your access or use of the Services.

TYPES OF INFORMATION WE COLLECT

When you use the Services, we may collect information that allows you to be identified (“Personal Data”), and we may also collect information that does not identify you (“Anonymous Information”). When Anonymous Information is, directly or indirectly, associated or combined with Personal Data, such Anonymous Information will be considered Personal Data for purposes of this Privacy Policy. In addition, to the extent Internet Protocol (“IP”) addresses or similar identifiers or information are considered personally identifiable information by applicable law, we will treat such identifiers and information as Personal Data under this Privacy Policy.

Information You Provide to Us

In general, you may visit the Website without telling us who you are or sharing any Personal Data with us.

When you register for an account for the Services (an “Account”), use other aspects of the Services, or communicate with us for customer service or technical support for the Services, we may ask you to provide certain Personal Data, such as your name, email address, postal address or telephone number, date of birth, gender, and ethnicity.

You may decline to provide Personal Data to us, but, if you do so, certain Services, or features of certain Services, may not be available to you. For example, we sometimes request certain Personal Data to determine whether you are eligible for Services targeted toward particular populations, such as a program to promote mentoring of girls in “STEM”-related careers. Sometimes, funders or sponsors of our Services require us to provide them with information regarding participants in these Services. Such information could include the contact information and program status of participants, which we would disclose to the funder or sponsor in the form of Personal Data, or the ethnicity, gender or other characteristics of participants, which we would disclose to the funder or sponsor in aggregate form. In such cases, participation in the Services may be contingent on individuals providing the relevant Personal Data.

You may also have the opportunity to voluntarily provide additional Personal Data to us, such as information pertaining to your educational background or personal and professional goals, or other biographical information, which may or may not be associated with your Account.

We may ask you whether you want to receive autodialed and prerecorded message calls and/or text messages relating to the Services. If you consent to such use of your phone number for these purposes, you may, if permissible under applicable laws and regulations, receive autodialed and prerecorded message calls and/or text messages from us, as applicable, relating to the Services, at that number.

Information Collected From Devices

When you access the Services using a computer or mobile device, including a desktop computer, laptop, mobile phone, tablet, smartwatch or other consumer electronic device (each, a “Device”), we may collect information from your Device, such as your Device type and manufacturer, your mobile carrier, your device software version, your Device identifiers, your mobile phone number, your IP address, your browser type, your network connection type, information about the webpage that referred you to the Website or that you visited prior to the Website, and your behavior and activity on the Website. Your behavior and activity on the Website may include the amount of time you spend using the Services and your login and log out times.

Information Collected From Participant Interactions

We may monitor, observe, or record program-related interactions of GSA program participants while they interact online or in person, and you hereby consent to such actions on our part.  We will treat observations and recordings of GSA program participant interactions as Personal Data, and we will protect them and may share them as described elsewhere in this Privacy Policy and our online Terms of Use for the Services.

Information Collected From Cookies and Similar Technologies

When you access or use the Services, we may place small data files on your Device that assign random, unique numbers to your Device to enable us to recognize your Device when you use the Services. These data files may be cookies, pixel tags, other local shared objects, or similar technologies provided by your browser or associated applications (collectively, “Cookies”). We may use Cookies to recognize your Device, manage and store your settings and preferences for the Services, improve the Services, offer targeted products and services to you, and collect and analyze information about your use of the Services.

The Cookies we use in connection with the Services may include the following:

  • Session Cookies: Session Cookies are temporary Cookies that expire and are automatically erased when you close your browser window. We may use session Cookies to grant you access to content and to enable actions that require you to be logged into your Account to perform.
  • Persistent Cookies: Persistent Cookies are Cookies that usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We may use persistent Cookies to better understand usage patterns so we can improve the Services. For example, we may use a persistent Cookie to associate you with your Account or to remember your choices for the Services.
  • Third-Party Cookies: We may permit certain third parties to place Cookies through the Services to provide us with better insights into the use of the Services and user demographics and to provide relevant advertising to you. These third parties may use Cookies to collect information about your online activities over time and across different websites when you use the Services. For example, we may utilize Google Analytics to analyze usage patterns for the Services. Google Analytics generates a Cookie to capture information about your use of the Services that Google uses to compile reports on website activity for us and to provide other related services. Google may use a portion of your IP address to identify its Cookie. We may also allow third parties to display advertisements through the Services. These third-party advertisers may use Cookies to collect Anonymous Information. In some cases, we may have access to information from Cookies used by third-party advertisers through the Services, and this information may permit us to identify other websites or services that you have visited that are also associated with such third-party advertisers. The use of Cookies by third-party advertisers is subject to the respective third-party advertisers’ privacy policies.

By accessing or using the Services, you consent to the placement of Cookies on your Devices as described in this Privacy Policy. If you prefer not to receive Cookies through the Services, you may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser. Unless you set your browser settings to refuse all Cookies, our system may issue Cookies when you access or use the Services. If you set your browser settings to refuse all Cookies, the performance of certain features of the Services may be limited or not work at all.

In some of our email messages to you, we may use “click-through URLs” linked to content on the Website. We track click-through data to help us understand and analyze interest in topics and use of the Services.

Do Not Track

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.

Information Collected From Third Parties

We also collect Personal Data about you from other companies. For instance, we may receive Personal Data about you from educational institutions, nominating partners, and third-party service providers.

SPECIAL CATEGORIES OF PERSONAL DATA

We do not, unless you explicitly consent, process any Personal Data relating to you in the following special categories: (i) data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; (ii) genetic data; (iii) biometric data for the purpose of uniquely identifying you; or (iv) data concerning your health, sex life or sexual orientation.

HOW WE USE INFORMATION

We may use Anonymous Information as described elsewhere in this Privacy Policy and for research and commercial purposes, such as to improve the Services.

We may use Personal Data for the purposes described elsewhere in this Privacy Policy and internally for our general commercial purposes, including, among other things, to:

  • provide the Services and notices related thereto
  • analyze, improve, and customize the Services
  • provide customer and technical support for the Services
  • send you announcements, newsletters, promotional materials, and other information about the Services and third-party products and services that we think may be of interest to you
  • detect, prevent, and investigate actual or suspected fraud, hacking, infringement, or other misconduct involving the Services
  • collect fees and other amounts owed in connection with the Services

We may use Personal Data in other ways that we expressly disclose at the time you provide it.

We do not use your Personal Data to make automated decisions about you without any human input. In we ever begin to do so, if and as applicable, and to the extent required by applicable law, we will endeavor to implement suitable safeguards, including, for example, an opportunity for you to request human intervention, express your point of view, contest any decisions made, and request that we restrict the use of your personal data for the purposes of these automated decisions.

HOW WE SHARE INFORMATION

We may share Anonymous Information with third parties as described elsewhere in this Privacy Policy and for our commercial purposes.

We may share Personal Data for the purposes described elsewhere in this Privacy Policy and as follows:

  • if you request or authorize it
  • to complete a transaction or provide a service requested by you
  • to our third-party service providers that provide services on our behalf, such as payment processing, data analysis, e-mail delivery, hosting, order fulfillment, infrastructure, network storage, customer service, technical support, and promotional services
  • to comply with applicable laws, rules, and regulations and governmental and quasi-governmental requests, court orders, and subpoenas
  • to protect our rights, property, and safety or the rights, property, and safety of our users and others
  • if the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Personal Data may be one of the transferred assets) or in the event of bankruptcy

YOUR RIGHTS AND CHOICES ABOUT YOUR PERSONAL DATA

You may opt not to receive promotional emails from us by contacting us as indicated below or by following the “unsubscribe” instructions in any promotional email you receive from us. Please note, however, that we may still send you non-promotional emails about your relationship with us.

You have the right to: (i) request confirmation of whether we store, use or share any of your personal data; (ii) obtain access to or a copy of your personal data; (iii) receive an electronic copy of personal data that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your personal data or object to those uses; (v) seek correction of inaccurate, untrue or incomplete personal data; or (vi) request erasure of personal data held about you by us, subject to certain exceptions prescribed by law.

Where we are relying on consent to process your personal data, you have the right to withdraw that consent at any time. However, withdrawing consent will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you would like to exercise any of these rights, please contact us at the email or physical address set out below. You will not have to pay a fee to exercise any of these rights.

In addition, if you are a resident of the European Union, you have the right to complain to a Data Protection Authority if you believe that your personal data has been collected or used in violation of relevant privacy requirements.

We will retain Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by applicable law.

INFORMATION YOU SHARE SOCIALLY

The Services may allow you to connect and share your actions, comments, content, and information publicly or with mentors, mentees, and other Program participants. We are not responsible for maintaining the confidentiality of any information you share publicly or with mentors, mentees, and other Program participants. In addition, the Services may allow you to connect with us and share on third-party websites, applications, and services. Please be mindful of your personal privacy needs and the privacy needs of others, as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others. We also do not control the privacy practices of third parties. Please contact those websites and services directly if you want to learn about their privacy practices.

HOW WE PROTECT YOUR PERSONAL DATA

We have, and require our third-party service providers to have, administrative, technical, and physical safeguards in place in our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, and alteration. The measures we utilize may include storing Personal Data on secured servers, transmitting Personal Data using encryption technologies, and auditing and reviewing our data collection practices.

No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Data. You also play a role in protecting your Personal Data. Please safeguard your username and password for your Account and do not share them with others. If we receive instructions using your Account login information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your Account or any other breach of security related to the Services. We reserve the right, in our sole discretion, to refuse to provide the Services, terminate your Account, and to remove or edit content.

DONOR PRIVACY

The Academy values the impact made by its donors and is committed to respecting donor privacy.

All information concerning donors or prospective donors, including their names, addresses and telephone numbers, personal financial information, the amount of their gift, etc., shall be kept strictly confidential by the New York Academy of Science Organization, its staff and volunteers, unless permission is obtained from the donor to release such information. All requests for donors to remain anonymous will be honored.

We will not sell or rent our donor information with any other entity for commercial purposes, nor will we send mailings to our donors on behalf of other organizations.

This policy applies to personably identifiable information collected both online and offline, on any platform, and through electronic, written, or oral communications.

If you have questions about this policy or wish to review or change the information we have about you, please contact us at gifts@nyas.org.

PROTECTING CHILDREN’S PRIVACY

The Services are not directed, or intended to be attractive, to children younger than 13 years old. We do not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, do not use the Services or submit any information to us.

THIRD-PARTY LINKS

When you use the Services, you may be directed to other websites and applications that are beyond our control. We may also allow third-party websites or applications to link to the Services. We are not responsible for the privacy practices of any third parties or the content of linked websites and applications, but we do encourage you to read the applicable privacy policies and terms and conditions of such parties, websites, and applications. This Privacy Policy only applies to the Services.

INTERNATIONAL TRANSFERS

Your Personal Data may be stored on computers and systems in the United States and other countries. By using the Services, you consent to the collection, transfer, processing, and storage of your Personal Data in such countries in the manner described in this Privacy Policy. You also acknowledge that the privacy laws of such countries may differ from the laws in the country where you are located and may not provide you the same rights or protections for your Personal Data.

CONTACT US

We have appointed a data protection officer who is responsible for overseeing questions related to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below. Our data protection officer may be reached at dpo@nyas.org or New York Academy of Sciences, Attention: Privacy, 115 Broadway, 8th Floor, New York 10006.

Financial Conflict of Interest Policy

Financial Conflict of Interest Policy

Last Updated: May 1, 2025

1. BACKGROUND

The New York Academy of Sciences (“NYAS”) recognizes that many personnel (both internal and external) of NYAS may engage in relationships with outside entities, some of which may create the appearance of a conflict of interest. NYAS therefore, has promulgated the below policy (“Policy”) to ensure that all scholarly activities which rely on external funding are carried out under the highest standards of ethical conduct. This Policy shall protect the interests of the scholarly community of NYAS by ensuring the integrity and objectivity of the programmatic activities created and hosted by NYAS.

2. POLICY OVERVIEW

NYAS strives to ensure funded programmatic activities are free from bias resulting from financial conflicts of interest. Therefore, this Policy is applicable to everyone (internal and external) who participates in planning programmatic activities funded by NIH or PHS funds (or any other external agency) through NYAS (each an “Investigator” as further defined below). Each Investigator must:

  1. Disclose their significant financial interests (“SFI” as further defined below) in non-NYAS entities that would appear related to the Investigator’s professional responsibilities through NYAS;
  2. Comply with this Policy; and
  3. Undergo FCOI training, at least once every four (4) years.

Disclosure of SFI is essential for NYAS to determine if there are financial conflicts of interest and how such conflicts should be managed and reported in full compliance with all laws and regulations. Non-disclosure of SFI or non-compliance with this Policy will at a minimum require FCOI training and may lead to suspension or termination of employment or involvement with the applicable programmatic activities.

3. DEFINITIONS

  1. “Family Member” means, with respect to an Investigator, their immediate family members consisting of their spouse or domestic partner, ancestors, siblings and their spouses, and lineal descendants and their spouses.
  2. “Financial Conflict of Interest or FCOI” means a significant financial interest that could directly and significantly affect the design, conduct, or reporting of funded programmatic activities.
  3. “Investigator” is any individual (whether or not an employee of NYAS) involved in an externally funded programmatic activity or proposal at NYAS who is responsible for the design, conduct, or reporting of such programmatic activity.
  4. “Key Person” means any person, whether or not an employee of the NYAS, who (i) has responsibilities, or exercises powers or influence over NYAS as a whole similar to the responsibilities, powers, or influence of Related Parties and officers; (ii) manages NYAS, or a segment of NYAS that represents a substantial portion of the activities, assets, income or expenses of NYAS; or (iii) alone or with others controls or determines a substantial portion of NYAS’s capital expenditures or operating budget.
  5. “Mitigation Report” means a report that follows a retrospective review if bias is found to have occurred. The Representative will draft a mitigation report to include, at a minimum, the key elements documented in the Retrospective Review and a description of the impact of the bias on the programmatic activity, and NYAS’s plan of action taken to eliminate or mitigate the effect of the bias (e.g., impact on the programmatic activity; extent of harm done, including any qualitative and quantitative data to support any actual or future harm; and an analysis of whether the programmatic activity is salvageable). The Representative will promptly notify and submit a Mitigation Report to the external funding entity.
  6. “Related Entity” means, with respect to an Investigator, any entity in which they and/or their Family Members, have a thirty-five (35) percent or greater ownership interest or, in the case of a partnership or professional corporation, a direct or indirect ownership interest of more than five (5) percent.
  7. “Related Party” means a Key Person of NYAS or any affiliate of NYAS and their Family Members and Related Entities who the Investigator reports to or works with, and the Family Members and Related Entities of the Investigator.
  8. “Representative” is the individual or group tasked with reviewing potential FCOI cases, developing FCOI management plans, conducting retrospective reviews and writing mitigations reports when needed, overseeing FCOI training, and updating publicly available FCOI policies.
  9. “Responsibilities” means the professional responsibilities on behalf of NYAS related to funded programmatic activities, related publications, professional practice, committee memberships, and services on panels.
  10. “Retrospective Review” is an investigation undertaken by the Representative when an Investigator is found to have not disclosed in a timely manner an SFI that is determined to constitute an FCOI, or an SFI that is determined to constitute an FCOI and was not reviewed or managed in a timely manner, or the failure of the Investigator to comply with a management plan. The purpose of the retrospective review is to determine whether any funded programmatic activities, or a portion thereof, conducted during the time period of the noncompliance, was biased in its design, conduct, or reporting. Retrospective reviews document, at a minimum: the project number and title; principal Investigator’s names(s); name of Investigator with an FCOI; name of the entity with which the Investigator has an FCOI; the reason for the retrospective review; the detailed methodology used for the review; and findings and conclusions of the review. The Representatives completes and documents a retrospective review within 120 calendar days of the determination of noncompliance.
  11. “Significant Financial Interest or SFI” as defined in 42 CFR 50.603 means:
    1. A financial interest consisting of one or more of the following interests of the Investigator (and those of the Investigator’s Related Parties) that reasonably appears to be related to the Investigator’s Responsibilities (as defined below):
      1. With regard to any publicly traded entity, an SFI exists if the value of any remuneration received from the entity in the twelve (12) months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000. Remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair-market value;
      2. With regard to any non-publicly traded entity, an SFI exists if the value of any remuneration received from the entity in the twelve (12) months preceding the disclosure, when aggregated, exceeds $5,000, or when the Investigator (or the Investigator’s Related Parties) holds any equity interest (e.g., stock, stock option, or other ownership interest); or
      3. Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests.
    2. The occurrence of any reimbursed or sponsored travel related to their Responsibilities unless the sponsor is (a) a government agency (federal, state, or local), or (b) an institution of higher learning or its affiliated entities such as an academic teaching hospital, medical center, or research institute. This includes both travel that is reimbursed through payment directly to the traveler and travel that is paid in-kind (e.g., when a sponsor books and pays for a plane ticket or hotel room on the traveler’s behalf).
    3. An SFI does not include the following:
      1. Salary, royalties, or other remuneration paid by NYAS, including intellectual property rights and agreements to share in royalties related to such rights;
      2. Income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the individual assets that comprise the investment vehicles;
      3. Income from seminars, lectures, or teaching engagements sponsored by a government agency or institution of higher education, to the extent such income is paid directly to NYAS; or
      4. Income from service on advisory committees or review panels for a government agency or institution of higher education, to the extent such income is paid directly to NYAS.

4. PROCEDURE

  1. Investigators who are planning to or participating in a programmatic activity that is externally funded must disclose to NYAS their SFIs in a timely fashion (when a project is submitted for funding, when they receive an award, annually during the term of the award, and within thirty (30) calendar days of discovering a new SFI), on the form provided by NYAS, to the Representative.
  2. The Representative will determine if whether the SFI constitutes an FCOI, based on guidance from NYAS in accordance with all laws and regulations. An SFI constitutes an FCOI, at a minimum, if the SFI could be affected by the funded programmatic activities, or is an entity whose financial interest could be affected by the programmatic activities. If the SFI is determined to be an FCOI, the Representative will take actions to discuss and approve the implementation of an FCOI management plan consistent with all laws and regulations and, furthermore, to promptly notify all external funding sources via a FCOI report. Investigators are responsible for complying with the terms of any FCOI management plan.
  3. The Representative will decide on one of the following actions in the instance of an FCOI, depending on the details of the FCOI:
    1. Requiring disclosure of the FCOI in all public presentations;
    2. Reassignment of the Investigator to another project;
    3. Reduction or elimination of the FCOI; or
    4. Severance of relationships that cause FCOI.
  4. Investigators who are planning to or participating in programmatic activities that are externally funded must complete the required FCOI training provided by the Representative prior to engaging in programmatic activities that are externally funded and at least every four (4) years thereafter. Investigators must also complete a new FCOI training whenever this Policy is revised in any manner that affects the requirements of the Investigators. Investigators new to NYAS (either as employees or external contractors) must complete an FCOI training within thirty (30) calendar days of their start date. Investigators found not complying with this Policy, or who must comply with a FCOI management plan, must also complete additional training.

5. ADMINISTRATION

  1. The Representative is responsible for administration of this Policy, including, but not limited to:
    1. Notifying the Governors of NYAS of any SFIs disclosed by Investigators when proposals are submitted for funding, and for providing backup materials to assist in evaluating the SFI for a FCOI;
    2. Identifying to the Governors any Investigators who should be required to file annual financial disclosure statements;
    3. Assisting NYAS in reviewing its 1085 form of annual disclosures to identify any potential conflicts of interest with ongoing grant/contract activities;
    4. Certifying in each application for funding to external sources that NYAS has this Policy in effect, and make any other required certifications;
    5. Track and notify appropriate parties of any incoming external funding source awards, and actual or potential FCOIs related to the awards, prior to the establishment of spending authority, within sixty (60) days for new or newly identified FCOIs, within sixty (60) days of identification of a new Investigator; at least annually, and after any retrospective reviews;
    6. Establish in any subaward from external funding sources whether the subrecipient will follow the FCOI policy of NYAS or of the subrecipient. This includes obtaining a certification from the subrecipient that its FCOI policy complies with all laws and regulations. If applicable, the subaward agreement will require the subrecipient to report identified FCOIs for its Investigators prior to the expenditure of funds, and within thirty (30) calendar days of identification, to allow NYAS to report identified FCOIs to the appropriate funding agency as required by law. If the subrecipient has no compliant FCOI policy, the subaward agreement will require the subrecipient to provide Investigator disclosures to NYAS in compliance with this Policy prior to the expenditure of funds.
    7. Lead FCOI reviews and develop, implement and monitor management plans that shall specify the actions that have been taken to manage the FCOI, should a conflict of interest be identified for an Investigator;
    8. Lead FCOI Retrospective Reviews and drafting of Mitigation Reports;
    9. Provide to the appropriate funding agency all FCOI reports required by law, including, but not limited to:
      1. the initial FCOI report;
      2. the ongoing annual FCOI report;
      3. a revised FCOI report if any SFIs are identified subsequent to the initial report within sixty (60) calendar days of the disclosure;
      4. a report of any Retrospective Reviews that reveal any programmatic activities bias, along with the Mitigation Report; and
      5. a report of any instances of Investigator noncompliance with this Policy or with a management plan.
    10. Maintaining all FCOI case records, for at least three (3) years from the date the final expenditure report was submitted to the funding agency or, when applicable, from other dates specified in 45 CFR 75.361.
  2. The Representative shall also be responsible for overseeing:
    1. Training for the members of the NYAS community including all required documentation and records of such training;
    2. Maintaining the publicly accessible website that shares this Policy and to report on the existence and management of any FCOI which shall be updated at least annually, or within sixty (60) calendar days of identification of information that was not previously disclosed. Information about FCOIs will remain available on the website for three (3) years from the date it was most recently updated.

6. ENFORCEMENT MECHANISMS

  1. NYAS does not at this time intend to participate in clinical, drug, or device evaluation research. However, in any case in which the Department of Health and Human Services (DHHS) determines that a PHS-funded project of clinical research whose purpose is to evaluate the safety or effectiveness of a drug, medical device, or treatment has been designed, conducted, or reported by an investigator with a financial conflict of interest that was not managed or reported by the Institution as required by 42 CFR Part 50, NYAS shall require the Investigator involved to disclose the FCOI in each public presentation of the results of the research and to request an addendum to previously published presentations.
  2. NYAS Investigators will be subject to the disciplinary process, up to and including removal, if they fail to disclose FCOI situations fully and truthfully, or fail to comply with any stipulated plan for managing disclosed conduct.