Privacy Policy | Leichter Advisors

Executive search runs on personal information, most of it about people who did not ask to be contacted. This policy describes how the firm actually works, and it is written to be read.

Who we are

Leichter Ellison Advisors, LLC, a limited liability company organized in Connecticut, United States, trading as Leichter Advisors. Address: 295 Madison Avenue, 12th Floor 1011, New York, NY 10017, United States.

We are the controller of the personal information described here. For questions, requests or complaints, write to info@leichteradvisors.com.

We have not appointed a data protection officer; we are not required to. A partner handles privacy requests personally.

Whose information we hold

Candidates and prospective candidates. Senior professionals in investment management and related industries, whether or not they have ever spoken to us.

Clients and business contacts. People at organizations that engage us, or might.

Referees. People a candidate nominates, or who are approached with a candidate’s agreement.

Visitors to this website.

What we collect

For candidates and prospective candidates: name; current and previous employers, job titles and dates; professional qualifications and education; business location; a LinkedIn profile URL; a work email address, and a personal email address or mobile number where you have given us one or where it is available from a professional source; compensation information where you or the market tells us; our own notes of conversations with you; assessments written by the partner who interviewed you; references; and, where you send one, a CV.

For clients and business contacts: name, role, employer, work contact details, and our notes of our dealings with you.

For referees: name, role, employer, the relationship to the candidate, and what you tell us.

For website visitors: nothing, unless you accept analytics cookies. See Cookies.

We do not seek special category data (health, race, religion, politics, trade union membership, sexual orientation, biometric or genetic data) and do not want it. If it reaches us incidentally, for example in a CV, we do not use it in any assessment.

Where it comes from

From you, when you write to us, speak to us, or send a CV.
From public and professional sources: a company website, a regulatory filing or register, a press report, a conference program, a professional networking site such as LinkedIn.
From referrals: someone in the market suggesting we should speak to you.
From our client, where they name people they would like considered.

If we hold information about you and you did not give it to us, you are entitled to ask what we hold and where it came from. See Your rights below.

Why we use it, and on what legal basis

Each entry below is something we do, the reason for it, and the lawful basis under UK and EU GDPR.

Identify and research people who might fit a role or a study: so that we can do the work we are engaged to do. Legitimate interests, ours and our clients’, in matching senior roles to the people able to do them.
Contact you about a role, or about the market: the same. Legitimate interests, and consent where the law where you are requires it.
Assess you against a specification and write it up: so that we can advise our client honestly. Legitimate interests.
Present you to a client: to progress your candidacy. Consent: we ask you first, every time.
Take references and verify qualifications: to advise our client, and because a firm that does not check is not doing the job. Legitimate interests, with your knowledge.
Keep a record of the market and of our conversations: because research is the firm’s asset, and because a search that repeats work already done wastes everyone’s time. Legitimate interests.
Send the newsletter: because you asked for it. Consent.
Run and improve the website: to make it work. Consent, for analytics cookies only.
Meet legal, tax and regulatory obligations: because we must. Legal obligation.

Where we rely on legitimate interests, we have weighed them against your interests and rights. The balance rests on this: the information is professional, the purpose is one a senior professional would reasonably expect of an executive search firm, we approach discreetly, and we stop when asked. You can object at any time. See Your rights.

We never contact a candidate about a confidential move through an employer’s email address.

Our clients, and only with your agreement, given in advance. We tell you which client before we tell the client about you.

Referees, to the extent needed to take a reference, and only with your agreement.

Service providers who process information on our behalf under contract: Microsoft (email, files and calendars), Bullhorn (our applicant tracking system, Invenias), Kit (our newsletter provider, who hold newsletter subscribers’ email addresses and nothing else), and our website host. They act on our instructions and may not use the information for their own purposes.

Professional advisers, and authorities, where we are legally required.

We do not sell personal information, and we do not share it for cross-context behavioral advertising. We have never done either.

International transfers

The firm operates across the Americas, Europe and Asia Pacific, and information about you may be accessed by our partners in the United States and in Asia, and stored on systems in the United States and the European Union.

Where information moves out of the United Kingdom or the European Economic Area, we rely on the UK International Data Transfer Addendum or the European Commission’s Standard Contractual Clauses, together with the safeguards our providers apply. Where it moves out of Hong Kong or Japan, we take the steps those regimes require of a transferring party.

How long we keep it

Candidate and market records: for as long as the information remains useful to the work. A senior career is long, and someone who is not right for a role this year may be exactly right in five. We review records and remove those that are out of date or that were never substantive.

Engagement records: for the duration of the engagement and for seven years afterwards, which is what our legal, tax and professional obligations require.

Website analytics: see Cookies.

If you ask us to erase your information, we do so unless we are required to keep it. In that case we tell you what we are keeping and why.

Your rights

Wherever you are, you may ask us what we hold about you, ask us to correct it, ask us to stop contacting you, or ask us to delete it. Write to info@leichteradvisors.com. We do not charge, and we answer within one month; if a request is complex we tell you and explain the delay.

We may need to confirm who you are before we act. That protects you.

United Kingdom and European Economic Area (UK GDPR, EU GDPR). You have the rights of access, rectification, erasure, restriction, portability, and objection, including an absolute right to object to direct marketing. Where we rely on consent you may withdraw it at any time, without affecting anything done beforehand. You may complain to a supervisory authority: in the UK, the Information Commissioner’s Office (ico.org.uk); in the EEA, the authority where you live or work.

Hong Kong (Personal Data (Privacy) Ordinance). You may make a data access request or a data correction request. We respond within 40 days. You may complain to the Office of the Privacy Commissioner for Personal Data (pcpd.org.hk).

Japan (Act on the Protection of Personal Information). You may request disclosure, correction, addition, deletion, or the cessation of use or provision of your retained personal data, and we respond without undue delay.

United States. Residents of California, Colorado, Connecticut, Virginia and other states with comprehensive privacy laws may request to know, access, correct, delete, or obtain a portable copy of their personal information, and may opt out of sale, sharing and targeted advertising. We do none of those three, so there is nothing to opt out of. We will not discriminate against you for exercising a right. California residents may designate an authorised agent to act for them.

Security

Information is held in the firm’s own systems, under access controls, with encryption in transit and at rest, and on accounts protected by multi-factor authentication. Only the people who need a record can reach it. No system is perfect, and we say so.

Automated decisions

We do not make decisions about you by automated means, and no algorithm decides whether you reach a shortlist. Every assessment is written by the partner who spoke to you.

Children

This website and the firm’s services are for professional adults. We do not knowingly collect information about anyone under 18.

Changes

We will update this policy when the way we work changes. The version and effective date at the top of the page tell you which one you are reading. Material changes will be flagged here.

Contact

info@leichteradvisors.com, or by post to Leichter Ellison Advisors, LLC, 295 Madison Avenue, 12th Floor 1011, New York, NY 10017, United States.