Introduction
Welcome to L.E.K. Consulting’s global database of primary research and other professional, experts and information providers contact’s privacy notice (the “Privacy Notice”).
L.E.K. Consulting respects your privacy and is committed to protecting your personal data. This Privacy Notice will inform you as to how we look after the personal data which we may have collected directly from you, from public sources (including the internet) or from third parties who have supplied such data to us. It also tells you about your privacy rights and how applicable laws may protect you.
In reading this Privacy Notice you should refer to the glossary of terms at the end of the policy to understand the meaning of some of the terminology used. For ease, we have divided this Privacy Notice into the following sections. Please note that unless otherwise stated in this notice, this Privacy Notice only applies to the personal data of data subjects or consumers who are protected by applicable privacy laws regarding personal information, including the EU General Data Protection Regulation ((EU) 2016/679) (“GDPR”), the Brazilian General Data Protection Law, Federal Law no. 13,709/2018 (“LGPD”), the Singapore Data Protection Act of 2012 (“PDPA”), or the California Consumer Privacy Act of 2018 (“CCPA”).
1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected
4. How we use your personal data
5. Disclosures of your personal data
10. Your California Privacy Rights
1. Important information and who we are
Purpose of this privacy notice
This Privacy Notice aims to give you information on how L.E.K. Consulting collects and processes your personal data.
We do not knowingly collect data relating to children under the age of 16 so if you become aware that we hold personal data on any person under 16 years of age please inform us immediately; our contact details are set out below.
It is important that you read this Privacy Notice together with any other Privacy Notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements the other notices and is not intended to override them.
Controller
L.E.K. Consulting is made up of different legal entities which operate in various regions around the world. Details of the regions and where our offices are based can be found in our webpage. L.E.K. Consulting’s legal entities include all those legal entities which are authorised to operate under the “L.E.K. Consulting” brand through our global network in the Americas, Europe and the Asia Pacific regions (the “L.E.K. Consulting Group”). This Privacy Notice is issued on behalf of the L.E.K. Consulting Group, and, therefore, when we mention "L.E.K. Consulting" or “L.E.K.”, "we", "us" or "our" in this Privacy Notice, we are referring to the relevant company in the L.E.K. Consulting Group responsible for processing your data. We operate and share between the L.E.K. Consulting Group entities a global database of primary research sources as well as of other professionals, experts and information providers but will let you know which entity or entities are processing your data in our communications with you. Please note that you may be contacted by more than one L.E.K. Consulting Group entity.
All questions in relation to this Privacy Notice, including any requests to exercise your rights, should be directed to the data privacy manager using the details set out below.
Contact details
If you are a consumer or data subject protected by the GDPR, LGPD, PDPA, or CCPA or other applicable privacy law regarding your personal information, the data privacy manager can be contacted by email at DataPrivacyManager@lek.com or at our postal address which is:
L.E.K. Consulting
Attn: Legal
75 State Street, 19th Floor
Boston, MA 02109.
If you are a data subject protected by the GDPR, in the EU you have the right to make a complaint at any time to relevant supervisory authority which for L.E.K. Consulting’s Group EU entities is the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). In Brazil, the relevant authority is the National Data Protection Authority (ANPD). In Singapore, the relevant authority is the Personal Data Protection Commission. In California, the relevant office is the Office of the Attorney General. We would, however, appreciate the chance to deal with your concerns before you approach any authority so please contact us in the first instance.
Changes to the Privacy Notice and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Our communications with you and our website may include links to third-party websites, plug-ins and applications. This may include surveys sent by L.E.K. Consulting’s Group entities or on behalf their behalf by survey provider firms or other respondent information gathering software or tools. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identifiers have been removed (anonymous data).
We may collect, use, store and transfer within L.E.K. Consulting different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes title, first name, maiden name, last name, gender, job title, qualifications and experience.
- Contact Data includes postal addresses, email address and telephone numbers (fixed line and mobile numbers) both of a corporate or personal nature.
- Financial Data includes bank account details and other payment method details.
- Transaction Data includes details about payments to and from you (as the case may be) and other details of honorarium payments we have agreed.
- Technical Data includes internet protocol (IP) address, browser type and version when responding to surveys, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our communications or surveys or in fact, our website.
- Profile Data includes your name and those interviews or surveys you may have participated in with us, your responses, preferences and feedback.
- Usage Data includes information about how you use our surveys or responds to interviews.
- Marketing and Communications Data includes, where you are also a client of L.E.K. Consulting, your preferences in receiving marketing from us and our third parties and your communication preferences. Details of how we process this data are set out on our Marketing Communications Privacy Notice. Please note that your data therefore may be processed in accordance with each privacy notice in accordance with their terms and each for their relevant purposes.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of data subjects responding to surveys. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
We do not generally collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). In the rare occasion where, in the context of our legitimate business activities (including servicing a client) we are required to collect this type of personal sensitive data, we will seek your consent to process such data and put in place safeguards to protect that information. Where a third party is collecting this information from you we will ask that they have the required consent or other legitimate basis to process the information but we are not responsible for their obligations to you. We do not knowingly collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we may have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with payment for honoraria).
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- respond or have in the past responded to our interviews or surveys;
- subscribe to our service or publications;
- request marketing materials to be sent to you; or
- give us some feedback.
- Third parties or publicly available sources. We may receive or collect personal data about you from various third parties and public sources (including the internet) including but not limited to those set out below. Information received or collected may be Contact, Identity, Financial , Transaction or Technical Data:
- analytics providers such as Google;
- search information providers such as LinkedIn and Monster;
- providers of technical, payment and delivery services such as PayPal, Swift Prepaid;
- from data brokers or such as:
- Expert Network firms such as Atheneum Partners, AlphaSights, Xperts Council, Coleman Research, Dialectica, Guidepoint Global and Third Bridge;
- List Publishers such as Exactdata, InfoGroup, InfoUSA, Information Refinery, IQVIA SK&A and NextMark;
- Business Directories such as Data.com Connect, S&P CapitalIQ, Orbis, Infogrette, Definitive Healthcare, Thomson One/Eikon, LexisNexis, Bureau Van Dijk, Clarksons, D&B Hoovers and Manta
- from publicly availably sources such as Companies House in the UK and the Electoral Register based inside the EU or equivalent in other jurisdictions
- from searches we carry out on the internet
4. How we use your personal data
We use your personal data in accordance with applicable law. Most commonly, we will use your personal data in the following circumstances:
- Where you have provided us with your consent.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
You can find out more about the types of lawful basis that we can rely on to process your personal data by contacting us.
Generally we do not rely on consent as a legal basis for processing your personal data in the context of our interview, survey and other communications with you but where we have asked you for consent and we rely on consent as the legal basis for processing your personal data, you have the right to withdraw consent by contacting us.
Purposes for which we will use your personal data
We collect your personal data to enable us to build a source of individuals or respondents to whom we approach in the context of our regular business activity. We process your Identity and Contact Data in the carrying out of our business activity so that we can identify and contact industry professionals to help us understand the market landscape and activities we are looking into and to unable us to share findings with our clients in the ordinary course of our providing consulting services. We retain your personal data to contact you on an ongoing basis.
We use your Financial Data to provide payment of honoraria where applicable. We also process your personal data to manage our relationship with you such as notifying you of changes to this Privacy Notice or review Transaction Data or Usage Data.
To process your personal data in the ways described we have considered our legitimate interests and those of third parties on behalf of whom we may process the data (mainly our clients) and have considered your fundamental rights and freedoms do not override this legitimate interest. We use legitimate interest as the basis for such processing or, in a jurisdiction where this is required, your consent. We also rely on the need to process some of your personal data to enable us to perform the contact that exists between us once we carry out the processing at your request, such as providing us with Financial Data for example.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
Opting out
You can ask us (or third parties) to stop these interview and survey participation communications with you at any time by following the opt-out unsubscribe link in such communications or by contacting us at any time. If you opt-out or unsubscribe we will process your personal data to enable us to perform this agreement with you. Where we rely on your consent for the processing you may also request to withdraw this consent at any time by contacting us.
Cookies
If you access our website please note that we use cookies in accordance with the cookies policy set out in our website. You can set your browser to refuse browser cookies.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- We will share the personal data where it is necessary for the establishment, exercise or defence of legal claims or threatened legal claims or wherever courts of competent jurisdiction are acting in their judicial capacity.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with this policy and applicable law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We share your personal data within the L.E.K. Consulting Group on a global basis and your personal data may also be shared globally with third parties who may be providing services to any L.E.K. Consulting company. For transfers involving the processing of personal data to which GDPR, LGPD, or PDPA applies, we have put in place legal mechanisms designed to provide adequate data protection as required under such law. Such mechanisms include, but may not be limited to, the EU Model Clauses and the EU-US Privacy Shield Framework. For transfers within L.E.K. Consulting Group of companies, we also ensure each office complies with our internal policies on personal data.
With respect to data subjects protected by GDPR, and the following applies:
- We have data processing agreements based on the Model Clauses between our EU and US offices.
- Whenever we transfer your personal data to third parties out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is.
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, on the adequacy of the protection of personal data in non-EU countries see the European Commission website.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details of the EU Model contracts for the transfer of personal data to third countries see the European Commission’s website.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield Framework which requires them to provide similar protection to personal data shared between the Europe and the US. For further details on the EU-US Privacy Shield see the European Commission’s website.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data.
7. Data security
Taking into account the state of the art, the cost of implementation and the nature, scope, contexts and purpose of the processing as described, as well as the risks of varying likelihood and severity for your rights, we have put in place reasonable and appropriate security measures aimed at preventing your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed commensurate to that risk. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. However, as with any information transmitted via the internet or even in protected environments this is always susceptible of unauthorised access. Most of our communications with you are through email which involves well published risks including, data corruption, hacking, interception, unauthorised amendment and other tampering and, in some cases, use of email may compromise confidentiality we cannot therefore be responsible for the confidentiality of your data in these instances.
We have put in place procedures to deal with personal data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we may have to keep certain information about you (including Contact, Identity, Financial and Transaction Data) for up to 6 years (or in jurisdictions such as Germany or in particular instances up to 10 years) after we no longer communicate with you or you ceasing to be an active contact of our global database. Where any statute of limitation requires longer periods we shall retain the personal data for such longer periods.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under local data protection laws, you may have rights in relation to your personal data. In the processing of your personal data, certain of your rights are protected by applicable local laws, such as the GDPR, LGPD, PDPA, CCPA and, where applicable, these rights will include the right to:
Request access to your personal data (commonly known as a "data subject access request" or “data portability request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure or deletion of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are also processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this 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 are protected by an applicable law such as GDPR, LGPD, PDPA, or CCPA and wish to exercise any of the rights set out above, please contact us However, there are circumstances in which those rights may not be available to you and we may not satisfy your request.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We will respond to a legitimate request in the timeframe allotted under applicable law.
10. Your California Privacy Rights
CONSUMER PRIVACY NOTICE UNDER CALIFORNIA CONSUMER PRIVACY ACT OF 2018
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements this Privacy Notice – Global Contacts and Primary Research and applies solely to those contacts who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). The personal information we collect is described in Section 2 of the Privacy Notice.
HOW WE USE YOUR PERSONAL INFORMATION
We may use or disclose the personal information we collect from you for one or more of the business purposes described in Section 4 of the Privacy Notice.
ACCESS & DATA PORTABILITY RIGHTS
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- the categories of personal information we collected about you;
- the categories of sources for the personal information we collected about you;
- our business or commercial purpose for collecting or selling that personal information;
- the categories of third parties with whom we share that personal information;
- the specific pieces of personal information we collected about you (also called a data portability request).
You can make this request by calling us, toll-free, at 1-833-535-0732, or emailing us at dataprivacymanager@lek.com or writing us at
L.E.K. Consulting
Attn: Legal
75 State Street, 19th Floor
Boston, MA 02109
In order to verify your request, you will be required to provide the following information: legal name; contact information (including, as applicable, mailing address, telephone number and email address); proof of identity (including, as applicable, photo identification).
DELETION RIGHTS
You have the right to request that we delete any of your own personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
- An exception to your request may apply if retaining the information is necessary for us or our service provider(s) to: Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug products to identify and repair errors that impair existing intended uses;
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et al);
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with L.E.K. Consulting;
- Comply with a legal requirement; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided such information.
You can make this request by calling us, toll-free, at 1-833-535-0732, emailing us at dataprivacymanager@lek.com or writing us at
L.E.K. Consulting
Attn: Legal
75 State Street, 19th Floor
Boston, MA 02109
In order to verify your request, you will be required to provide the following information: legal name; contact information (including, as applicable, mailing address, telephone number and email address); proof of identity (including, as applicable, photo identification).
NON-DISCRIMINATION
You have a right not to receive discriminatory treatment by L.E.K. Consulting for exercising privacy rights under the CCPA.
AUTHORIZED AGENT
You have a right to designate an authorized agent to make a request under the CCPA on your behalf. In order to do so, your authorized agent can make a request on your behalf by calling us, toll-free, at 1-833-535-0732, emailing us at dataprivacymanager@lek.com or writing us at
L.E.K. Consulting
Attn: Legal
75 State Street, 19th Floor
Boston, MA 02109
In order to verify your request, your authorized agent will be required to provide the following information about you: legal name; contact information (including, as applicable, mailing address, telephone number and email address); proof of identity (including, as applicable photo identification). In addition, your authorized agent will be required to provide the following information: legal name of authorized agent; contact information of authorized agent (including, as applicable, mailing address, telephone number and email address); proof of identity of authorized agent (including, as applicable, photo identification), and proof of authorization to act as authorized agent (including, as applicable, written consent signed by you, or a certified copy of a Power of Attorney).
CONTACT L.E.K. CONSULTING
You can contact us for questions or concerns about our privacy policies and practices by e-mail to dataprivacymanager@lek.com or write us at
L.E.K. Consulting
Attn: Legal
75 State Street, 19th Floor
Boston, MA 02109
11. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to contact you for your views and perspectives to help us understand the market landscape within the area of your expertise, qualification or experience to allow to share those perspectives with our clients and others in the course of carrying out or business activity of providing consulting services. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
Internal Third Parties
Other companies in the L.E.K. Consulting Group acting as joint controllers or processors and who are based in those offices specified in our website and provide IT and system administration services and undertake leadership reporting.
External Third Parties
- Market research companies, whether as suppliers or programmers used for the hosting and administration of the database including the collection of data on our behalf and including the administering of surveys or other research and interview tools or information collection methods.
- Banking and payment and clearing service providers may be required by us to process honoraria payments to you where these apply.
- Service providers acting as processors based in any jurisdiction who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide services to us and, in certain instances, our clients.
- Tax authorities, regulators and other authorities who require reporting of processing activities in certain circumstances.
ANNEX A
L.E.K. Consulting Group entities who may process your personal data include:
- L.E.K. Consulting LLC
- L.E.K. Consulting LLP
- L.E.K. Consulting GmbH
- L.E.K. Consulting S.A.R.L.
- L.E.K. Consulting Australia Pty Ltd
- L.E.K. Consulting India Private Limited
- L.E.K. Consulting Limited
- L.E.K. (Brasil) Participações S.A
Please note that this list is subject to change from time to time and that there may be instances in which we share personal data as described in this Privacy Notice with associated entities of the entities listed.