Dupen Ltd is committed to protecting the privacy of our candidates and clients. We are privileged to hold your data and will ensure that the information you supply us is solely used for the purposes set out in this Data Privacy Notice.
Your new rights under the General Data Protection Regulation (GDPR) are set out in this notice and will apply once the GDPR becomes law on 25th May 2018.
Who we are
Dupen Ltd (formerly Dupen Recruitment Services, 2001 – 2013) is a recruitment business as defined in the Employment Agencies Act 1973. To enable us to carry out our business, we collect personal data from: candidates (either prospective or placed) for permanent or fixed-term contract work; clients (prospective or customers we are currently working for); suppliers (contacts at organisations helping to support or business or service).
Who controls your personal data?
• The Data Controller is Dupen Ltd.
• Dupen Ltd is registered in the UK and our Company Number is 08390914
• Registered Address: 1 Sheffield Road, Southborough, Tunbridge Wells, Kent, TN4 0PD.
• The Data Controller’s data protection representative is Darren Page
• You can contact him at email@example.com or call +44(0)1892 536 860
• Dupen Ltd is registered as a Data Controller with the Information Commissioner’s Office Certificate Number ZA017285
How we obtain your data
You may have applied to us directly or via job advertisements. If we have discovered your details on an online job-board or similar we will advise you of the source when we make initial contact with you.
Where you are an individual, working for an organisation we have dealings with (e.g. a client or supplier), we may obtain your data from: where you have directly provided us with information; marketing databases; your colleagues; social media.
Processing your personal data:
The personal data we collect could include your: name, address, contact details (e.g. your email), date of birth, work history, educational history and qualifications / accreditations, skills, visa / right to work in the UK documentation, referee contact details, information concerning hobbies and interests.
For individuals employed by or representing our clients, we process your data in order to provide Recruitment Services to you. Data could include your name, telephone number, email address, work address, job specifications, extra communications provided to us to enable us to source the right candidates for you. Processing could cover: storing your personal data and using this data to maintain communications with you; sending information to candidates and applicants for your vacancies; necessary actions for our obligation pursuant to a contract existing between Dupen and the organisation you work for; retaining records of our dealings with you; providing information with regulatory or statutory bodies where a request for information for a legal obligation applies.
How we use the data we collect
Under GDPR, there are six legal bases for processing data but Dupen will rely on either: we have a legitimate interest in processing your data; obtaining your consent for certain uses of your data (refer below); the processing is essential to fulfil a contract with you. Our legal basis for the processing of personal data is our legitimate business interest, as per Article 6(1)(f) of the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) or is necessary for the performance of a contract with you. We may also use your consent for certain uses of your data; for instance, if we acquire your details from a source such as a job-board CV database. For when we have entered into a placement agreement with you or your organisation, or any contract to provide services to you (or receive them from you) or your organisation, we will rely on contract.
Processing your personal data may include: collecting and storing your personal data; assessing your suitability for job vacancies; notifying you of potentially suitable job vacancies; introducing you to our clients.
For individuals employed by or representing our clients we must comply with statutory obligations while providing Recruitment Services. For example, the Conduct of Employment Agencies and Employment Business Regulations 2003 where we need to obtain information from clients to assess candidate suitability for requirements.
We have a legitimate interest in providing Recruitment Services and this requires the processing of personal data which, for individuals employed by or representing our clients, we need: to make contact regarding our Recruitment Services; assessing candidate suitability; assessing job vacancies.
For individuals employed by or representing our clients we will also need to keep records of our dealings with you. Where necessary, we will use these records for: client compliance; dealing with any queries or disputes; quality control and compliance.
Consent to Dupen processing your data:
Dupen may process your personal data on the basis that you have consented to us doing so for a specific purpose. For instance, if you apply for a specific role you may have consented to our processing of the data you have given us for the purpose of considering your suitability for the position and managing your journey through the application process. For individuals employed by or representing our clients, you may have consented to the processing of your data for reference requests.
You may withdraw your consent to our processing of your personal data, but please be aware we may need to continue to hold your data where we have a legal or contractual obligation to do so.
Where we have obtained your personal data from a third-party source – e.g. online job-board, or publicly available social media sites, such as LinkedIn; or personal information from former employers or colleagues, or organisations seeking to hire staff – but where this information is of no use to us, or when you have told us that you do not wish us to provide you our services, we will delete the information. We may need to hold a limited record, in order to stop a future duplication of the processing. Where this information may be of use to our undertaking of our recruitment services, any processing will be in accordance with this Privacy Notice.
Who Dupen shares your personal data with:
We will only share your personal data where we are entitled to do so:
For candidates: delivering our Recruitment Services, we would share your information with individuals, hirers and other third parties in the process.
For individuals employed by or representing our clients: we would share your information with candidates, and other third parties in the Recruitment process.
We may be required to share your information with regulatory or statutory bodies where a request for information for a legal obligation applies.
Dupen will take every reasonable care to ensure that our systems and records are secure to unauthorised third-party access.
Retaining your data
It is Dupen’s policy to only store your personal data for as long as is reasonably necessary for us to comply with our legal obligations and for our legitimate business interests.
The following sets out the lengths of time we retain your data or certain elements of your data:
a) for 12 months from the date we last provided our Recruitment Services to you for the purposes of providing evidence of the recruitment services we provided to you (Conduct of Employment Agencies and Employment Businesses Regulations 2003)
b) for 2 years from the end of your last period of engagement or employment.
c) for terms of business with clients: 6yrs in order to deal with any disputes.
If you believe that we should delete your personal data earlier than this, please inform us in writing of your reasons.
Dupen has always taken data protection seriously and will continue to do so. With this, you have the right to:
– Request a copy of the personal data we hold on you. To do this please contact firstname.lastname@example.org
– Object to our processing of your data; where the processing is based on legitimate interest and there are no compelling reasons for the continued processing of the data.
– Request that data is deleted, where the continued use of that data cannot be justified. (Please note that Agencies are required to keep certain records, such as right to work checks, for certain periods of time and that these obligations may override requests to erase data for so long as the agency must retain the data).
– Withdraw your consent to Dupen processing your data or request we restrict processing your data, however we may continue to retain or use your information where we have a legitimate interest, or a legal/contractual obligation to do so. In which case our processing will be limited to what is required in the furtherance of the interest or obligation.
– Request that inaccurate or incomplete data is corrected. Dupen will respond to such a request within 1 month.
– Request that direct marketing by Dupen is ceased.
– Request that data provided by you is transferred to you or another data controller.
Where we have erased or ceased processing data, we may retain a record of this request and action taken to ensure the data is not processing in the future, should it be received again from an external source. This will also show evidence of our compliance.
For any questions concerning your rights, or if you wish to exercise these rights please contact: email@example.com
If you have any enquires you can contact us at: firstname.lastname@example.org or by writing to us at:
Darren Page, Director
6 Carville Avenue