Privacy Policy

Modular Data Ltd customer privacy notice

This privacy notice tells you what to expect us to do with your personal information.

• Contact details
• What information we collect, use, and why
• Lawful bases and data protection rights
• Where we get personal information from
• How long we keep information
• Who we share information with
• How to complain

Contact details

Email

people@modulardata.co.uk

What information we collect, use, and why

We collect or use the following information to provide and improve products and services for clients:

We collect or use the following information to provide and improve our services for clients:

• Names and contact details
• Addresses
• Occupation and job title
• Payment details (including bank information for transfers)
• Transaction data (details about payments to and from you and services you have purchased)
• Usage data (how you interact with our website, products, and services)
• Information relating to compliments or complaints
• Records of meetings and decisions
• Audio recordings of meetings and training sessions (e.g. recorded calls or video conference sessions)
• Video recordings of meetings and training sessions
• Account access information

We collect or use the following information for the operation of client accounts:

• Names and contact details
• Addresses
• Purchase or service history
• Account information, including registration details
• Marketing preferences
• Technical data, including browser and operating system information

We collect or use the following information for marketing or service updates:

• Names and contact details
• Marketing preferences
• Website enquiry and usage information
• IP addresses

We collect or use the following information to comply with legal requirements:

• Name and contact information
• Identification documents
• Any other personal information required to comply with our legal obligations

We collect or use the following information for recruitment purposes:

• Contact details (name, address, telephone number, email address)
• Employment history (job applications, employment references)
• Education history and qualifications
• Right to work information
• Copies of passports or other photo identification
• Baseline Personnel Security Standard (BPSS) check information, including identity verification, employment history, and nationality checks
• Background check results provided by Secure Screening Services

We collect or use the following information for dealing with queries, complaints, or claims:

• Names and contact details
• Relevant account and service records
• Details of the query, complaint, or claim

Lawful bases and data protection rights

Under UK data protection law, we must have a lawful basis for collecting and using your personal information. The lawful bases we rely on are explained below alongside the data protection rights that apply in each case.

You can find out more about lawful bases and your rights on the ICO’s website at ico.org.uk.

Your data protection rights at a glance:

• Right of access,  you can ask us for copies of your personal information
• Right to rectification, you can ask us to correct inaccurate or incomplete information
• Right to erasure,  you can ask us to delete your personal information in certain circumstances
• Right to restriction of processing, you can ask us to limit how we use your information
• Right to object to processing, you can object to us processing your information in certain circumstances
• Right to data portability, you can ask us to transfer your information to another organisation or to you
• Right to withdraw consent, where we rely on consent, you can withdraw it at any time
• Right to complain, you can complain to the ICO if you are unhappy with how we have handled your data (UK GDPR Article 77)

If you make a request, we will respond within one calendar month. To make a data protection rights request, contact us using the details at the top of this notice.

Our lawful bases for providing and improving services for clients:

• Contract (UK GDPR Article 6(1)(b)), we must process your information to enter into or carry out a contract with you
• Legal obligation (UK GDPR Article 6(1)(c)), we must process your information to comply with the law
• Legitimate interests (UK GDPR Article 6(1)(f)), we have a legitimate interest in developing and improving our services. We may contact you about products or solutions that may be beneficial, or ask for feedback. You can opt out at any time

Our lawful bases for operating client accounts:

• Contract (UK GDPR Article 6(1)(b))
• Legal obligation (UK GDPR Article 6(1)(c))
• Consent (UK GDPR Article 6(1)(a)),  where we have asked for and received your permission

Our lawful bases for marketing and service updates:

• Consent (UK GDPR Article 6(1)(a)), where you have opted in to receive marketing communications
• Legitimate interests (UK GDPR Article 6(1)(f)), from time to time we may contact you about our services and content that may be of interest. We will never sell your data and you can opt out at any time

Our lawful bases for complying with legal requirements:

• Legal obligation (UK GDPR Article 6(1)(c))
• Contract (UK GDPR Article 6(1)(b))

Our lawful bases for recruitment:

• Legitimate interests (UK GDPR Article 6(1)(f)), assessing candidates for roles
• Legal obligation (UK GDPR Article 6(1)(c)), right to work verification
• Consent (UK GDPR Article 6(1)(a)), where you agree to us retaining your details for future roles

Our lawful bases for dealing with queries, complaints, or claims:

• Legal obligation (UK GDPR Article 6(1)(c))
• Legitimate interests (UK GDPR Article 6(1)(f)), resolving disputes and enforcing our rights

Where we get personal information from

• Directly from you
• Recruitment platforms (including Jobtrain)
• Publicly available sources
• Previous employers (references)
• Legal bodies or professionals (such as courts or solicitors), where required
• Suppliers and service providers

How long we keep information

1. We do not keep your personal information longer than is necessary. Our retention periods are:

Type of Information	How Long We Keep It
Client and business contact records	6 years from the end of the relationship or last contact
Financial and billing records	6 years (HMRC requirement)
Website contact form enquiries	12 months, unless the enquiry leads to an ongoing relationship
Unsuccessful job applications	12 months from the end of the recruitment process, unless you consent to longer
Right to work documents	2 years after the end of any employment or engagement

2. Where we are unable to give a specific period, we will keep your information only as long as we need it to provide our services or to comply with our legal obligations.

1. Who we share information with
   1. We do not sell your personal data. We may share it with:

• IT and cloud service providers who process data on our behalf,  including Google (Google Workspace), Slack, HubSpot, Atlassian, and Docusign. These providers are contractually bound to process data only on our instructions
• Professional or legal advisers,  including accountants and solicitors, on a confidential basis
• Insurance companies or brokers where relevant
• Recruitment platforms, including Jobtrain
• Organisations we are legally required to share information with,  including HMRC and the ICO

Some of our service providers are based in the United States. Where personal data is transferred outside the UK, we ensure appropriate safeguards are in place, including International Data Transfer Agreements (IDTAs). You can request further information about these safeguards by contacting us at people@modulardata.co.uk.

How to complain

1. If you have any concerns about our use of your personal data, please contact us in the first instance:

Email	people@modulardata.co.uk
Address	Modular Data Limited, 35 Ballards Lane, London, N3 1XW

2. If you remain unhappy after raising a complaint with us, you can complain to the Information Commissioner’s Office (ICO):

Website	ico.org.uk/make-a-complaint
Telephone	0303 123 1113
Address	Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Last updated

16 June 2026