Applicants Privacy Notice – Duncan & Toplis Group

Duncan & Toplis Group Privacy Notice – Applicants

Data controller: Duncan & Toplis

Data protection officer: David Mowbray

At Duncan & Toplis we understand that your privacy is important to you. We are committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person.

This Recruitment Privacy Notice (“Privacy Notice”) describes how we handle and protect your personal data in connection with our recruiting processes.

What information does the organisation collect?

Duncan & Toplis collects a range of information about you. This includes:

  • your name, address and contact details, including email address and telephone number;
  • details of your qualifications, skills, experience and employment history;
  • information about your current level of remuneration, including benefit entitlements;
  • whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process;
  • information about your entitlement to work in the UK;

The organisation collects this information in a variety of ways. For example, data might be contained in application forms, CVs, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment including online tests.

Duncan & Toplis will also collect personal data about you from third parties, such as references supplied by former employers though only once a job offer and with your permission.

Data will be stored in a range of different places, including on your application record file, our HR management system and on other IT systems (including email).

Why does the organisation process personal data?

We need to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.

In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.

Duncan & Toplis has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job.  We may also need to process data from job applicants to respond to and defend against legal claims.

As an organisation we also processes health information on occasions if we need to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out our obligations and exercise specific rights in relation to employment.

Where the organisation relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of applicants and has concluded that they are not.

Who has access to data?

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

The organisation will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The organisation will then share your data with former employers to obtain references for you

The company may share CV’s between our sister companies (Bishopgate, CFM, Queensgate and Datcom) where we feel it may be applicable for a vacancy in one of those areas.  This sits under the Duncan & Toplis Group and the same process and security will apply.

We will not transfer your data outside the European Economic Area.

How does Duncan & Toplis protect data?

As an organisation we take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

For how long does the organisation keep data?

If your application for employment is unsuccessful, the organisation will hold your data on file for 6 months after the end of the relevant recruitment process.

In some cases we would like to retain your personal data on file in case there are future employment opportunities for which you may be suited to   after the 6 month period. If this is the case we will ask for your consent before we keep your data for this purpose and you are free to withdraw your consent at any time.

At the end of the 6 month period or once you withdraw your consent if we request to retain the documents longer your data is securely deleted or destroyed.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.

Your rights

As a data subject, you have a number of rights. You can:

  • access and obtain a copy of your data on request;
  • require Duncan & Toplis to change incorrect or incomplete data;
  • require Duncan & Toplis to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
  • object to the processing of your data where Duncan & Toplis is relying on its legitimate interests as the legal ground for processing; and
  • ask Duncan & Toplis to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override our legitimate grounds for processing data.

If you would like to exercise any of these rights, please contact You can make a subject access request by contacting the Data Protection Officer at

If you believe that Duncan & Toplis has not complied with your data protection rights, you can complain to the Information Commissioner.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to Duncan & Toplis during the recruitment process. However, if you do not provide the information, Duncan & Toplis will not be able to process your application any further.

Automated decision-making

Our recruitment processes are not based on automated decision-making in any way.