Worker Privacy Information Statement
Welcome to Modis part of the Adecco Group. We look forward to working with you to help you to further
develop your career. As you’d expect, to properly perform our services, we collect and use
information about you.
Modis is committed to protecting and respecting your privacy. This Privacy Information Statement
describes your privacy rights in relation to the information about you that we process, as well as
the steps we take to protect your privacy. We know it’s long, but please read this Statement
carefully. There is an index below so you can go straight to the bits you want if you prefer.
Some terms to be clear about
First we need to be clear about how we use some words in this statement.
It may seem obvious, but in this Statement you will be referred to as ‘the
Candidate’ or ‘You’.
When we talk about ‘us’ or the ‘Company’ we mean Modis International Limited. The registered office
for Modis International Limited is 10 Bishops Square, London E1 6EG. The Company is part of the
Adecco Group, the largest HR services provider in the world. Through its various companies and
business lines the Adecco Group provides several HR (Human Resources) activities like staffing,
secondment, payroll services, recruitment & selection, testing solutions, career transition, talent
development, training & education, outplacement and international mobility (‘our
To carry out our Activities the Company uses several IT systems. In some cases the Company provides a
Self Service Portal (‘Portal’) for its candidates/personnel. The Portal
allows you to search and apply for jobs the Company and its sister companies advertise which match
your interests, skills and/or experience, in the locations where you have expressed an interest in
Finally, this is a statement about information about people – like you and your family. It
includes facts about you, but also opinions about you and that you hold (“I’m a football
fan” for example). It’s not about information about the Company (although sometimes the
two overlap). This type of information is sometimes called ‘Personal information’,
‘Personally Identifiable Information’ or ‘PII’. We use the term
‘Personal Information’ in this Statement.
What personal information does the company collect and use?
Personal information that the company usually collects includes, but is not limited to:
- Your name, date and place of birth, contact details and qualifications (education, training
courses and internships), and any other information you mentioned on your resume or CV;
- If you log on to the Portal using your LinkedIn or any other social media account: your profile
- If you contact us, in some cases we will keep a record of that correspondence;
- Feedback about you from our staff and third parties who you work with or for, and other
appraisal information; where you give feedback on others, we usually keep that too and that is
also personal information about you (it’s your opinion after all);
- We may also collect information on your use of our systems including (but not limited to) your
IP address, browser, timestamp, location, country traffic data, location data, weblogs and other
communication data and the resources that you access. This information will make our systems
easier to use in the future;
- Details of any disabilities and any accommodations we may need to make for you in the workplace;
- When you start working for the company we shall also collect:
- Your gender, nationality, copy ID documents, proof of address and copies of documents
evidencing your right to work in the locations you will work in (visas, work permits,
- Payroll information such as your bank account information, national insurance or social
security number, tax codes and reference numbers, your fees, salary and benefits information and
any voluntary deductions you ask us to make from your salary and fees (like trade union
membership or church dues);
- Records of your attendance, time spent on projects, training, promotions, investigations and
- Information about your use of our IT systems and premises (including CCTV and door entry
- Details about your dependents and next of kin;
- Travel information (travel data, credit card information, passport number, expenses incurred)
for the purposes of the negotiation, arrangement and purchasing of all travel related activities
(e.g. Airfare, Train, Hotel & Car Rental reservations) and the reimbursement of travel
- Photos and videos of your attendance at training or similar sessions (you will be given a
chance at the session to ask not to be videoed or photographed); and
- In some cases we will also collect sensitive personal information (e.g. data relating to your
Why do we use personal information about you?
The company collects and processes personal information:
- To provide you with the assistance you expect, like finding you suitable assignments to work on,
helping you with training, or facilitating the process of applying for new assignments. This
includes keeping you informed of future work opportunities by email, telephone, mail and/or
other communication methods;
- To further develop and improve our systems/processes; this mainly takes place in the context of
new IT systems and processes, so that information about you may be used in the testing of those
new IT systems and processes where dummy data cannot fully replicate the operation of that new
- To perform studies and statistical and analytical research, for example to compare the
effectiveness of our placement of associates with clients between different business sectors and
geographies and seek to identify factors that might influence any differences we identify;
- To transfer data to third parties (see below);
- Where necessary, to comply with any legal obligation;
- When you start working for the Company, to perform our duties to you as your employer or
customer (in the case of individual contractors); and
- We may also process your information to:
a. To comply with your contract of employment or contract for services, and all other contracts
and rules that govern our employment or other contractual relationship with you;
b. Maintain and improve administration of talent generally (including for the purposes of
c. Carry out other human resources activities (including work management, absence management,
training/people management, expense management, and disciplinary procedures);
d. Manage shares and other assets to which you may be entitled;
e. Promote the security and protection of people, premises, systems and assets;
f. Monitor compliance with internal policies and procedures;
g. Administer communications and other systems used by the Adecco Group (including internal
h. Investigate or respond to incidents and complaints;
i. Comply with obligations and rights and cooperate with investigations carried out by the
police, government or regulators;
j. In the case of photos or videos of training sessions, to report internally that the training
sessions have taken place and their content (for example in internal updates) and also to market
similar sessions internally and to third parties; or
k. Participate in any potential or actual purchase or sale, or joint venture, of all or part of
a business or company, that any member of the Adecco Group wishes to participate in.
- Photos and/or videos collected from you for the purposes of identification and right to work verification.
What does the law say about this?
We are required by law to have a ground set out in the law to process the information we hold about
When you are working with or through Modis our processing of personal information for all these
purposes is based on processing grounds like the performance of a contract to which the data
subject is a party (purposes 1 and 6-7), processing necessary to comply with legal or regulatory
obligations (purpose 6-7) and/or processing necessary in the legitimate interests of Modis in
exercising its and its staff fundamental rights to run a business in a way which does not unduly
affect your interests or fundamental rights and freedoms (purposes 1-5 and 7). When
processing is necessary for the legitimate interests of Modis, we ensure that processing is
conducted in such a manner that our legitimate interests outweigh any individual’s interest.
We shall only process your personal information other than on these grounds with your consent (a
further processing ground).
Do you have to give us the personal information we ask
The provision of your personal information is a requirement necessary to enter and/or maintain our
contract with you. This means that you are obliged to provide your personal information to Us.
If you do not provide your personal information to us, we may either not be able to conduct the
employment or supplier relationship with you or, at least, you may not be able to participate in
certain processes such as feedback or career development (which may also not be in line with your
contract with us)
Do we process information about you without any human
intervention at all?
Yes we do at times. The Company may use automated systems/processes and automated decision-making
(like profiling) to provide you, and our clients, with the services you request from us. For
example, when our clients are looking for candidates for jobs, we may conduct a search of our lists
of candidates using automated criteria which takes into account your availability, skillset, pay
rate and in some circumstances previous feedback we have received from clients to compile a
shortlist which ranks which candidates are most likely to fulfil the client’s requirement.
This means that sometimes your position in the rank may be higher than others, depending on how
these factors match the clients’ needs.
How long do you keep my personal information for?
The Company may (and in some circumstances must, depending on the type of data) keep your data for
several years after your employment with us has ended. Generally, we retain data
concerning taxes and your contract of employment, financial information (including payroll data and
data relating to pay, etc.) for 7 years, and other personal information for as long as you wish to
receive our services, and for up to 2 years thereafter. We retain sensitive personal data for no
longer than is reasonably necessary.
Do we transfer your data to third parties?
As mentioned above, we usually disclose your data to third parties. This is done to complete the
purposes set out above. We do this in the following circumstances:
- To our suppliers. We may, for example, engage a
supplier to carry out administrative and operational work in support of our relationship with
you. The supplier(s) will be subject to contractual and other legal obligations to preserve the
confidentiality of your data and to respect your privacy, and will only have access to the data
they need to perform their functions; these suppliers are typically IT suppliers (who host or
support our IT systems, including information about you), premises management companies (who
look after physical security at our buildings, and therefore need to know about you to allow
access to our buildings), HR related providers (who operate payroll or benefits provision on our
behalf, such as on site catering for associates and colleagues), travel providers (who manage or
organise travel for our associates and colleagues) or back office finance and accounting
management providers (who might need to handle details of colleagues and associates in order to
process accounts payable and receivable).
- To members of the Adecco group of companies in other
countries. These may be located in- or outside the European Union; different
members of the group fulfil different functions and as result your information may be shared
with them for different reasons:
- Information is shared with members of the Adecco group that provide IT functions for the
Adecco companies world-wide; those IT functions are located among others in France.
- Information is shared with the head office of the Adecco group in Switzerland for work force
planning, budgeting and feedback purposes; this information may also be used at head office in
Switzerland to propose new opportunities to you within the Adecco group or with clients.
- Information is also shared with Adecco affiliates world-wide where you have expressed an
interest in opportunities in that market, or members of the Adecco Group identify that you may
have particular skills required or helpful in that market. A list of the countries in
which we operate is available in the ‘choose your country’ function of our website
- To our clients (and end clients)/and prospective
employers: we will share your data with clients of ours who are offering
jobs/assignments you may be interested in, or who are interested in your profile or where
required for audit purpose, for colleagues this may be where you are working on-site with our
clients. They owe contractual and other confidentiality obligations in relation to your data to
us, and to you;
- We will share your data with government, police, regulators or law enforcement agencies if, at
our sole discretion, we consider that we are legally obliged or authorised to do so or it would
be prudent to do so; and
- As part of due diligence relating to (or implementation of) a merger, acquisition or other
business transaction we may need to disclose your data to the prospective seller or buyer, new
service provider and their advisers.
Do we transfer your data outside the European Union?
Your data can be transferred and processed in one or more other countries, in- or outside the
European Union. A full list of the countries in which we operate is available in the ‘choose
your country’ function of our website at www.modis.co.uk.
We shall only transfer your data outside the EU to countries which the European Commission believes
offers an adequate level of protection to you (a list of those countries is available here:
or where the Adecco Group has put in place appropriate safeguards to seek to preserve the privacy of
your information (for which we usually use one of the forms of data transfer contracts approved by
the European Commission, copies of which are available here: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm.
What are your rights?
As explained in the “Sharing with third parties” paragraph above, we share your personal
information with the following:
- Right to access and obtain a copy of your personal information
You are entitled to request confirmation whether we process any of your personal information.
Where this is the case, you may have access to some of your personal information (via the
Portal) and to certain information about how it is processed. In some cases you can ask us to
provide you with an electronic copy of your information.
- Right to correct your personal information
If you can demonstrate that personal information we hold about you is not correct, you can
request that this information is updated or otherwise corrected. We would encourage you to
access the self-service Portal where possible and update your personal information directly.
- Right to be forgotten/have data deleted
In certain circumstances you have the right to request that we restrict the processing of your personal data and/or that your personal data is deleted. You may make such a request at any time through the Portal. Modis will evaluate if your request should be granted, however this right is subject to any legal rights or obligations we may have to retain data. For situations where in accordance with the law, we determine that your request to have your personal information deleted must be granted, Modis will do so without undue delay. Please bear in mind, once your data is deleted – that the Company might not be of service to you anymore once this data about you has been deleted. If you want to re-register with the company again, you will need to re-enter your data.
- Right to object
As far as the company’s processing of your data is based on the company’s legitimate
interest (and no other processing ground) or relates to direct marketing, you are entitled to
object to the Company processing your data by reference to your particular situation.
If you want to exercise any of your rights, please log into our self-service Portal (here) so that we
may action your instruction as soon as possible.
The Company may ask you to identify yourself before actioning your request.
Finally, you have the right to lodge a complaint with the data protection authority in the place
where you live or work, or in the place where you think an issue in relation to your data has
Do we carry out any monitoring?
To the extent permitted by law, Modis reserves the right to audit, monitor and record the access, use
and content of any data held or processed by its IT systems. We do this for the purposes (d)-(h) set
out above but call this point out specifically in this notice so that you are aware in particular
that your use of work related IT systems may be monitored by others.
What about data security when using Modis Systems?
You are responsible for keeping your login details to the Portal safe, in particular the password
that we have given you or that you have chosen. These login credentials are for your own use. You
are not permitted to share your credentials or other account details with any other person(s).
How could you contact us?
If you have any questions or concerns regarding our Statement, would like further information about
how we protect your information (for example when we transfer it outside Europe) and/or when you
want to contact the company’s Group Data Protection Officer (DPO) and your local Privacy Lead,
please email us at firstname.lastname@example.org
or your local Privacy Lead directly at email@example.com..
How do we handle changes to this statement?
The terms of this Statement may change from time to time. We shall publish any material changes to
this Statement through appropriate notices either on this website or contacting you using other
The Modis team