Modex: Recruitment Privacy Policy

This Recruiting Privacy Policy (Privacy Policy) describes the privacy and security practices that M3 Holdings Group (C/O Corsham Tenant Limited, 41, Corsham Street, London, United Kingdom, N1 6DR) and its subsidiaries and affiliates (“the Group”, “we” or “us”) employ when collecting, using and handling (processing) personal information about you in connection with our online and offline recruitment activities.The present Privacy Policy is to make you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. Also, it provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR) and applicable law of EEA and the UK, where relevant.


This Privacy Policy applies to our processing of personal information of candidates in connection with our career portal and our other recruitment channels (collectively, “Recruitment Channels”).


“Candidate” is used in this Privacy Policy to refer to anyone who applies for a job role, or who otherwise seeks to work with or for us (whether on a permanent or non-permanent basis;“Personal Data” means all information that relates to an identified individual or to an identifiable individual. For example, your name, address, email address, educational and employment background, CV and job qualifications.

Which categories of personal data do we process?

We will collect and process personal data from you through the application and recruitment process. Such information may include:
  • Name and other personal data such as gender, date and place of birth;
  • Contact information, such as address, telephone number, and e-mail address;
  • Past employment history (including previous employers, job titles, or positions) and references in order to evaluate potential employees for employment;
  • Other academic, professional, and training information, such as academic degrees and professional qualifications;
  • Your CV/resume which may include details of any memberships or interests;
  • Information from interviews and video-call records you may have, if any;
  • Details of the type of employment you are or may be looking for, current and/or desired salary and other terms relating to compensation and benefits packages, willingness to relocate, or other job preferences;
  • Details of how you heard about the position you are applying for;
  • Any sensitive and/or demographic information provided by you during the application or recruitment process information about your citizenship and/or nationality and immigration status;
  • Reference information and/or information received from background checks (where applicable), including information provided by third parties;
  • Information relating to any previous applications you may have submitted to the Group and/or any previous employment history with the Group;
  • Information that we believe is relevant to your application or a potential future application (e.g. your LinkedIn profile);
  • Background check (where permitted or required by law); and/or
  • Information related to any assessment you may take as part of the interview screening process.

Where do we source your personal information?

We process personal data that you provide directly to us in connection with the below purposes, such as when you register in the careers , submit a job application, or interview with us.

We may also receive personal information from other sources, such as during references, background, or employment checks, and from third party recruitment sources or from a publicly accessible source: for example, LinkedIn, or other business or employment-oriented services that operate via websites where you have added information about yourself; publications which you have written/contributed to, and which are publicly available.

Why and how do we use your personal data?

We collect and process your personal data where it is necessary in order to take steps, at your request, prior to our potentially entering into a contract of employment with you.
Your personal data will be used by the Group for the purposes of carrying out its application and recruitment process which includes:

  • Carrying out and supporting human resources functions and activities, including processing and evaluating your application, assessing your eligibility to work, making hiring decisions, and managing and improving our recruiting and hiring processes;
  • Assess your skills, qualifications, and suitability for the work or position, including through assessment centres, and generally to process your application, including validation of your information via your references (only to the extent we are permitted to contact your referees and to collect such information from your referees);
  • Communications with you about the recruitment process and/or your application(s), including, in appropriate cases, informing you of other potential career opportunities at us;
  • Making improvements to our application and/or recruitment process;
  • Complying with legal obligations and internal policies;
  • Complying with applicable laws, regulations, legal processes or enforceable governmental requests;
  • Proactively conducting research about your educational and professional background and skills and contacting you if we think you would be suitable for a role with us.

Who may have access to your candidate data?

We do not sell your personal data to third parties.

We may disclose personal data to the following categories of recipients:
  • We will share your personal data with our HR team.
  • We may share some of your personal data with third parties empowered by us to use your personal data for permitted purposes, under our instruction.
  • Where required by law, we will also disclose your personal data to a governmental authority;
We ensure that the third party processor takes adequate measures to protect your personal, by signing a data processing agreement with it.

International transfers

Your personal data are, as a general rule, processed and stored in the European Economic Area (the “EEA”). In cases where they are processed and/or stored outside the EEA, appropriate safeguards compliant with the M3 Holdings’s legal obligations will be implemented as required by law.

Indeed, as we operate globally, we have a legitimate interest in transmitting your personal data within our Group and affiliates/subsidiaries located all around the world. We may also need to outsource some services to external service providers located outside the EEA. These countries potentially do not have an adequate level of data protection compared to the level of data protection within the EEA.

As a rule, your data shall not be disclosed to third countries which do not have adequate data protection unless appropriate safeguards are duly implemented between us and the third party (e.g., such as European Standard Contractual Clauses).

Only the personal data that are strictly necessary to the affiliate/subsidiary or service provider will be transferred, and, if required, via encrypted means.

For how long do we retain personal information?

Unless otherwise required by applicable national laws and/or with your consent, your personal data shall not be retained for longer than one (1) year after the last contact with you.

We retain this information for various reasons, including in case we face a legal challenge in respect of a recruitment decision, to consider you for other current or future jobs at us and to help us better understand, analyze and improve our recruitment processes.

If you are offered and accept employment with us, the information collected during the application and recruitment process will become part of your employment record.

If you do not want us to retain your personal data for consideration for other roles, or want us to update it, please contact [email protected].

Please note, however, that we may retain some information if required by law or as necessary to protect ourselves from legal claims.

What your rights are in respect of your personal data?

In certain countries, you may have certain rights under data protection law. This may include the right to request access or to update your information, request that it be deleted, or object to us using it for certain purposes.

If you wish to exercise a right of access please contact [email protected]. We will respond to any requests in accordance with applicable law, and so there may be circumstances where we are not able to comply with your request.

Pursuant to the EU GDPR and applicable national data protection laws, you have the right to be informed of your rights as a Candidate.

Subject to the above paragraph, you will find below the summary of your rights:

  • Right of Access – You have the right to ask for information about the processing of your personal data and/or for copies of your personal data. Your request may be denied to protect another individual’s rights.
  • Right to Rectification – You have the right to ask for rectification of personal data you think is inaccurate and to ask us to complete information you think is incomplete.
  • Right to Erasure (“Right to be forgotten”) – Under certain circumstances, such as when our processing of your personal data is based on your consent, you have the right to ask us to erase your personal data. However, notwithstanding such a request, we may still process your personal data if it is necessary to comply with our legal obligations, or for the establishment, exercise or defense of legal claims.
  • Right to Restriction of processing – Your right to restrict us from processing your personal data (except for storing it): (a) if you contest the accuracy of the personal data (in which case the restriction applies only for a period enabling us to determine the accuracy of the personal data); (b) if the processing is unlawful and you prefer to restrict the processing of the personal data rather than requiring the deletion of such data by us; (c) if we no longer need the personal data for the purposes outlined in this Private Policy, but you require the personal data to establish, exercise or defend legal claims; or (d) if you object to our processing based on our legitimate interest (in which case the restriction applies only for the period enabling us to determine whether our legitimate grounds for processing override yours).
  • Right to Object - Your right to object is not absolute, i.e., you can only object to processing when we are processing your personal data for our legitimate interests. However, we may override the objection if we demonstrate compelling legitimate grounds, or if we need to Process such Candidate Personal Information for the establishment, exercise or defense of legal claims.
  • Right to Data Portability – Your right to data portability is not absolute, i.e., you have the right to ask to receive your personal data and/or have we transfer your personal data to another company, where technically feasible, provided that (i) you have given us your consent for the processing or (ii) the processing is necessary of the performance of a contract between you and M3 Holdings, such as your employment contract or in order to take steps at your request prior to entering into your employment contract, and (iii) the processing is carried out by automated means. Your request may be denied to protect another individual’s rights.

Additional information for general data protection regulation ((EU) 2016/679) (GDPR)

Legal Basis for Processing

The legal basis under General Data Protection Regulation ((EU) 2016/679) (GDPR) for processing your personal data to evaluate your candidacy is both is our legitimate interests in properly reviewing your candidacy and assessing your application to work at us and for steps we need to take prior to entering into an employment contract with you;

The legal basis under EU law for retaining your personal data for further processing for future job openings is our legitimate interests in considering you for other job openings we may have;

The legal basis under EU law for retaining your personal data for recordkeeping purposes is our legitimate interest in asserting or defending legal claims that impact the course of our business or reputation;

Where we collect sensitive personal information from you, we will do so normally only with your explicit consent or where we have an obligation under employment law to process such information.

When you contact us, we reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason.

Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. According to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in the Member State of your residence, place of work or of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.


We are committed to making sure that your personal data are kept secure and have implemented accepted standards of technical measures and security policies that protect the information it has under its control from:
i. Unauthorized access.
ii. Improper use or disclosure.
iii. Unauthorized modification.
iv. Unlawful destruction or accidental loss.

All our personnel and any third parties which engage to process your personal information are obliged to respect the confidentiality of your information.

This Privacy Policy was last changed on July 17, 2020. This Privacy Policy may change over time to comply with legal requirements or to meet our changing business needs. The most up-to-date version of the Privacy Policy can be found on this website. In case there is an important change that we want to highlight to you, we will also inform you in another appropriate way (for example, via our website).

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