Who are we?
Miles Advisory LLP
20 North Audley Street, London, W1K 6WE
Tel: 0203 978 9898
We provide executive search services to clients looking to recruit personnel for their businesses. We also provide interim management and coaching services for candidates.
What does this Policy cover?
We at Miles Advisory take your personal data seriously. This policy:
• sets out the types of personal data that we collect about you
• explains how and why we collect and use your personal data
• explains how long we keep your personal data for
• explains when, why and with who we will share your personal data;
• sets out the legal basis we have for using your personal data;
• explains the effect of refusing to provide the personal data requested;
• explains the different rights and choices you have when it comes to your personal data; and
• explains how we may contact you and how you can contact us.
What personal data do we collect about you?
We collect the information necessary to be able to find available opportunities and further information needed to assess your eligibility through the different stages of recruitment. This information includes CV’s, identification documents, educational records, work history, employment and references.
We may also collect sensitive personal data about you, we only collect sensitive personal data from you, and further process this data, where you have given your explicit consent.
If you are receiving coaching from us, we will also process any additional information that you choose to provide to us during the course of the coaching.
How and why we use your personal data?
We use your personal data to match your skills, experience and education with a potential employer. We will initially collect basic information on you such as contact details, job role and experience and then pass this on to the client in search of personnel. If you are chosen by the client and go through to the next stage we will then be collecting more information from you at the interview (or equivalent) stage and onwards in that manner.
If you are receiving coaching from us, we use your personal data in order to understand more about you and to assist you with understanding your skills and areas for improvement or future opportunities and options.
How long do we keep your personal data for?
We only retain your information for as long as is necessary for us to use your information as described above or to comply with our legal obligations. However, please be advised that we may retain some of your information after you cease to use our services, for instance if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.
When determining the relevant retention periods, we will take into account factors including:
(a) our contractual obligations and rights in relation to the information involved;
(b) legal obligation(s) under applicable law to retain data for a certain period of time;
(c) our legitimate interest where we have carried out a balancing test (see legal basis below);
(d) statute of limitations under applicable law(s);
(e) (potential) disputes;
(f) if you have made a request to have your information deleted; and
(g) guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information where we no longer require your information for the purposes collected.
Who do we share your personal data with?
Your personal data is shared with the client who has a position to fill. We share your data in order to determine with the client whether you are a good fit for the available position.
What legal basis do we have for using your information?
For prospective candidates, interim managers, referees and clients, our processing is necessary for our legitimate interests in that we need the information in order to be able to assess suitability for potential roles, to find potential candidates and to contact clients and referees. We carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. We keep a record of these balancing tests. You have a right to and can find out more about the information in these balancing tests by contacting us using the details below.
If you are shortlisted as a candidate or if you are coached by us, then this may involve the processing of more detailed personal data including sensitive data such as health information that you or others provide about you. In that case we always ask for your consent before undertaking such processing.
For clients, we may also rely on our processing being necessary to perform a contract for you, for example in contacting you.
What happens if you do not provide us with the information we request or ask that we stop processing your information?
If you do not provide the personal data necessary or withdraw your consent for the processing of your personal data, we may not be able to match you with available job opportunities.
Do we make automated decisions concerning you?
No, we do not carry out automated profiling.
No, we do not.
Do we transfer your data outside the EEA?
To better match your employee profile with current opportunities we may transfer your personal data to clients and partners in countries outside the EEA. These countries privacy laws may be different from those in your home country. Where we transfer data to a country which has not been deemed to provide adequate data protection standards we always have security measures and approved model clauses in place to protect your personal data.
To find out more about how we safeguard your information as related to transfers and to obtain a copy of such safeguard, contact us at firstname.lastname@example.org
What rights do you have in relation to the data we hold on you?
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.
1. The right to be informed
You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.
2. The right of access
This is so you’re aware and can check that we’re using your information in accordance with data protection law.
3. The right to rectification
You are entitled to have your information corrected if it’s inaccurate or incomplete.
4. The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
5. The right to restrict processing
You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be
‘blocked’ to make sure the restriction is respected in future.
6. The right to data portability
You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
7. The right to object to processing
You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).
8. The right to lodge a complaint
You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
9. The right to withdraw consent
If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
• baseless or excessive/repeated requests, or
• further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
How will we contact you?
We may contact you by phone, email or social media. If you prefer a particular means of contact over another please just let us know.
How can you contact us?
If you are unhappy with how we’ve handled your information or have further questions on the processing of your personal data, contact Chris Stainton on 0203 978 9898/ email@example.com.
STATEMENT FOR FINANCIAL YEAR 2019/20
This Modern Slavery Act Transparency Statement is published by Miles Advisory LLP in accordance with section 54 of the Modern Slavery Act 2015 for the financial year ending 31st March 2020.
Miles Advisory LLP is a human capital consultancy established in 2019 offering executive search, interim management and board advisory solutions. We are headquartered in the United Kingdom and carry out services on behalf of our clients around the world.
We are committed to ensuring compliance with all laws and regulations relevant to our business in all countries where we operate. Following the implementation of the Modern Slavery Act 2015, the Board and management are committed to maintaining and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere within our own business or in any of our supply chains.
Modern Slavery encompasses all acts of slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Miles Advisory LLP respects human rights and does not tolerate any form of modern slavery.
We employ mainly highly skilled professional and administrative staff and as such is at low risk of modern slavery and human trafficking. All employees are provided with a clear contract of employment, which complies with UK legislation. Employees are treated in a fair and equal manner and with dignity and respect. We do not tolerate any form of discrimination, victimisation or harassment on any grounds. New employees are made aware of our ethical and compliance standards. As part of this process they are made aware how to report and deal with such an instance. Our whistleblowing policy supports and encourages our staff to report wrongdoing and this extends to Modern Slavery.
We are also committed to act ethically, with integrity and transparency in all our business dealings and relationships. We communicate our zero-tolerance view of modern slavery to all suppliers and outsourcing partners at the start of our business relationship. We will terminate our relationship with third parties if they do not comply with this policy. We have not identified any specific risk areas within our supply chain but as a matter of good practice we will continue to monitor and mitigate any actual or potential risks and where necessary, take steps to strengthen these contractual relationships.
This statement was approved by Miles Advisory LLP and will be reviewed and updated annually.
29 April 2019