Legitimate interests assessment
Last updated 27 August 2026 · Controller: Xpectrum Ltd, trading as Dulycore
This is the published summary of the assessment behind our processing of public-register personal data under UK GDPR Article 6(1)(f) — the processing described in the Article 14 notice.
1. The purpose test — what interest is pursued?
UK companies owe statutory deadlines whether or not anyone tracks them, and late filing carries penalties set by law. Our interest is commercial: building a service that maps those deadlines from the public record and reminds the companies that owe them. The interest is also the recipient's: the deadline in a briefing is the company's own, already running against it.
2. The necessity test — is the processing needed for it?
A deadline calendar derived from the register cannot be built without processing the register, and the register's officer entries are personal data. There is no less-intrusive way to compute a company's confirmation-statement or accounts date than reading the public record that defines it. For briefings, the published business contact point is the only route to the company that does not involve buying enriched personal data — which we do not do.
3. The balancing test — do individual rights override it?
We concluded no, on these grounds and with these safeguards:
- The data is published by law for transparency about companies, so a company officer has a clear expectation that it will be read and used in relation to that company;
- we process the published record and do not combine it with private sources;
- special category data is neither sought nor held;
- briefing email is addressed to the company at its published business contact point, concerns only that company's own statutory position, is sent without tracking pixels, and carries a working objection route;
- objections are honoured as permanent suppression within one month;
- data is held in the UK and refreshed against the register rather than hoarded.
Review
This assessment is reviewed when the processing changes and at least annually. Questions and objections: hello@dulycore.com.