Modern Academy Assessment Privacy Notice

Last revised – November 12, 2026

This notice explains how Modern Executive Solutions LLC handles your information for your Modern Academy assessment and agreed Academy development support, including the potential use of AI assistance and optional interview recording or transcription.  It also explains the assessment-quality, methodology, and tool-development activities described below. This notice supplements Modern’s Global Privacy Policy located at https://www.modernexecutivesolutions.com/legal/privacy-policy. The assessment-specific purposes, sharing restrictions, and retention rules in this notice apply to the activities covered here, including where they differ from general statements in that policy.  

1. Summary Key points about how we use your information. Each is explained in more detail below.

• Who is responsible: Modern Executive Solutions, LLC, 3343 Peachtree Road NE Ste 145-338, Atlanta, GA 30326. Questions: datacompliance@modernexec.com  

• What we use: your contact and professional details, your Hogan results, the assessor’s written interview notes, and your Academy assessment results and report, and any recording or transcript you separately agree to. Where AI assistance is used, this may also include AI-generated analyses, scoring suggestions, report drafts and personalized development recommendations

• Why: to arrange and conduct your assessment and provide agreed Academy development, including potential AI assistance, and to undertake the assessment-quality and methodology-improvement activities explained in section 2. The separate conditions for benchmarking and tool development are also explained there.  

• Who sees it: access to your individual Hogan reports and assessor interview notes is restricted to your assessor and the person carrying out quality-control checks. Your final assessment report is provided to you. We do not share your individual assessment results with your employer or sponsor without your written authorization.

• How long: only as long as needed for these purposes (see section 2).

• Your choice: you will be asked to confirm participation in the assessment and acknowledge receipt of this notice. Our legal bases for handling your information are explained in section 2. Recording or transcription is optional and requires your separate consent before it begins. Declining does not affect your assessment, readout, Academy participation or fees.  

• Your rights: you can ask to access, correct, or delete your information by contacting datacompliance@modernexec.com. Where EU or UK data protection law applies, you may complain to the relevant data protection authority (including the UK ICO or an EU/EEA supervisory authority), as applicable.  

• Your right to object: where we rely on legitimate interests, you have the right to object at any time to our use of your information by contacting datacompliance@modernexec.com. Where we rely on consent for recording or transcription, you may withdraw that consent at any time.

2. Full notice

What we collect

We use your name, contact details, Academy affiliation, and relevant professional background; the transcript from the assessment interview (if applicable); the written notes your assessor takes during your interview; any information supplied by your employer when nominating you; your Academy assessment results and scoring outputs; and your final report to arrange and conduct your assessment, prepare and explain the findings, and provide the agreed Academy development support. Where AI assistance is used, this may generate analyses, leadership themes, scoring suggestions, report drafts, and personalized development recommendations.

You complete your Hogan assessment under Hogan’s own terms. For your Academy assessment, we receive Hogan Insight Series reports for the Hogan Personality Inventory (HPI), Hogan Development Survey (HDS), and Motives, Values, Preferences Inventory (MVPI), together with the Hogan Flash report. Hogan’s terms cover Hogan’s handling of your information; this notice covers ours. We use these Hogan reports as inputs to your Modern Academy assessment. This notice covers Modern’s use of the information it receives for your Academy assessment.

Please do not share health information, details about other people, or confidential employer or client information during your interview unless it is necessary.

How the assessment works

The Modern Academy assessment includes Hogan pre-work and a leadership assessment interview, typically lasting 90 minutes. Your assessor considers your Hogan reports alongside the information discussed during the interview and takes written notes to support preparation of your assessment report.

Only you and the assessor attend the interview. The interview may be recorded or transcribed with your verbal consent at the outset of the interview. Before asking for consent, we will explain the tool being used, what will be captured, whether an audio or video recording will be retained, and how the resulting material will be used. You may decline, ask us to stop, or withdraw your consent without affecting your assessment, readout, Academy participation or fees. If you decline, the assessor will use written notes instead.

We may use AI tools to analyze assessment information, identify leadership themes, support scoring against Modern’s assessment framework, draft and review reports, check quality and consistency, and generate personalized development recommendations.  An appropriately qualified Modern professional reviews the assessment conclusions before they are communicated to you, can correct or reject AI-generated suggestions, and remains responsible for the final assessment report.

Your assessor prepares a qualitative written assessment report, which undergoes quality-control review before being provided to you. Your assessor explains the findings during your assessment readout.

Improving our assessment methods and tools.

We may use selected assessment materials to evaluate and improve the accuracy, consistency, fairness and usefulness of Modern’s assessment methodologies and development services; develop leadership benchmarks; and develop, test and validate AI-enabled assessment and development tools.

We use effectively anonymized information whenever these purposes can reasonably be achieved without identifying you. Where identifiable information is necessary, we limit the information and access to what is needed for the particular activity and apply the legal bases, retention limits and rights described in this notice.

Interview recordings and transcripts are used only for the purposes covered by your consent. If we propose to use them for the methodology, benchmarking, or tool-development activities described here, we will request your separate consent for those uses. That choice may be offered at the outset of the interview.

Before beginning a use outside the purposes described in this notice, we will provide any additional privacy information and obtain any further consent required by applicable law.

Our legal basis

We rely on legitimate interests (GDPR Article 6(1)(f)) to arrange and deliver your Modern Academy assessment, prepare and explain the findings, provide agreed Academy development support, and address related questions or complaints. These interests include providing an accurate, useful development assessment, including where AI assistance is used. Where limited records are necessary to establish, exercise or defend legal claims, we rely on our legitimate interest in protecting our legal rights. Where retention is required by applicable law, we rely on that legal obligation (GDPR Article 6(1)(c)).

We also rely on legitimate interests in undertaking proportionate assessment-quality reviews, improving our assessment methodologies and development services, developing leadership benchmarks, and developing, testing and validating AI-enabled assessment and development tools. Our interests are improving the accuracy, consistency, fairness and usefulness of these services and tools. We use anonymized information whenever these purposes can reasonably be achieved without identifying you and limit identifiable information to what is necessary for the particular activity. Recordings and transcripts are subject to the separate consent requirements described above.

We rely on your consent (GDPR Article 6(1)(a)) for optional interview recording or transcription and use of the resulting material for your assessment. You may withdraw that consent at any time by telling your assessor or contacting datacompliance@modernexec.com. We will stop further use based on that consent and delete the recording or transcript unless limited retention is necessary for the legal purposes described below. Withdrawal does not affect processing lawfully carried out before withdrawal.

Who receives your information

Access within Modern to your individual Hogan reports and assessor interview notes is restricted to your assessor and the person carrying out quality-control checks on your assessment report. Where AI, recording or transcription tools are used, authorized service providers also process the information necessary to provide those functions. Access within Modern is limited to personnel who need the information for the specific activities described in this notice. We provide your final assessment report to you. You may choose to share it with your employer, coach or others. Modern does not share your individual assessment results directly with your employer or sponsor without your written authorization.

We may use service providers for scheduling, secure storage, assessment administration, recording or transcription, and AI assistance. Where a provider processes information on our behalf, we require contractual restrictions on its use of that information. Such providers may not use the information for their own unrelated purposes, including training their general-purpose AI models.

How long we keep it

We keep your information only for as long as necessary for the purposes described below. Our standard maximum retention period is seven years after your assessment, including the readout, is completed, or after cancellation if it does not proceed. We delete records earlier when they are no longer needed. Limited retention beyond that period may apply for the legal purposes described below.

We may retain limited information for longer where required by an applicable legal obligation or where necessary to establish, exercise, or defend legal claims. We limit this retention to the information and period needed for that purpose, restrict access accordingly, and delete the information when that need ends. Information retained solely for these purposes is not used for ongoing development or other commercial activities.

Information that has been effectively anonymized so that you cannot reasonably be identified may be retained for leadership benchmarking and the development, testing and validation of assessment and development tools. Creating or retaining anonymized information does not authorize a separate use of identifiable assessment information that is not otherwise covered by this notice.

Where it is processed

Your information may be processed in the United States and other countries where Modern or its service providers operate.

Modern’s Global Privacy Policy describes the use of Standard Contractual Clauses approved by the European Commission for transfers of EEA personal information between Modern group companies. It also describes similar safeguards for transfers involving service providers and partners. You can request a copy of the relevant clauses or further information about these safeguards by emailing datacompliance@modernexec.com  

Your rights

Depending on applicable law and the legal basis, you can ask to access, correct, delete, restrict, or receive a portable copy of your information, and object to our use of it. Contact datacompliance@modernexec.com. You may also complain to the UK Information Commissioner’s Office (ico.org.uk) or the data protection authority in the EU country where you live or work. Residents of some U.S. states have similar rights, which we honor in the same way. Where we rely on consent for recording or transcription, you may withdraw that consent at any time.

Modern handles your information on the legal bases explained in section 2. This acknowledgement is not consent to interview recording or transcription. If recording or transcription is proposed, your assessor will explain it and request your separate consent before it begins. The booking system records your name, email, the date, this notice version, and your responses. No separate signature is needed.

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