Privacy & Cookies Policy

Top Virtual Assistance Ltd trading as Top Recruitment Research (“we”, “us”, “our”) is committed to protecting personal data and respecting privacy. This Privacy & Cookies Policy explains how we collect, use, store, and share personal data when you visit https://toprecruitmentresearch.co.uk/, contact us, or where we process data as part of our candidate sourcing and outreach services.

This Policy is intended to comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations (PECR).

1. Who We Are (Data Controller)

Legal entity: Top Virtual Assistance Ltd
Trading name: Top Recruitment Research
Company number: 10395452
Registered in: England and Wales
Registered address:
The Watermark, 9 Ribbleton Lane, Preston, England, PR1 5EZ

For the purposes of data protection law, we act as a Data Controller for personal data we collect and determine the purpose and means of processing.

2. Scope of This Policy

This Policy applies to:

  • Visitors to our website
  • People who contact us via web forms, email or calls
  • Our clients (recruitment agencies / staffing firms) and their representatives
  • Candidates whose data we source and/or contact as part of our services

3. What Data We Collect

A) Website Visitors (Technical Data)

  • IP address
  • Browser/device type
  • Pages visited and time spent
  • Referring website/source
  • Cookie identifiers (where applicable)

B) Business Enquiries and Client Data

If you enquire or become a client, we may collect:

  • Name, job title, company name
  • Business email address and phone number
  • Billing details (where applicable)
  • Communications and meeting notes
  • Role requirements you provide (job specs, salary range, location etc.)

C) Candidate Data (Recruitment Sourcing)

As part of our candidate sourcing service, we may process:

  • Name
  • Job title and employment history
  • Skills and qualifications
  • Location (e.g., city/region)
  • LinkedIn profile URL and other professional profile links
  • CV/resume (where provided or shared by the candidate/client)
  • Contact details (e.g., email/phone if publicly available or provided by the candidate)
  • Outreach communications and responses
  • Notes relevant to role fit (non-sensitive)

We do not intentionally collect “special category” data (e.g., health, ethnicity, religion) and we request that clients do not send it to us unless necessary and lawful.

4. Where We Get Candidate Data From

We may obtain candidate data from:

  • Professional networks (e.g., LinkedIn)
  • Job boards and professional databases
  • Publicly available professional sources (e.g., personal portfolio sites)
  • Referrals
  • Candidates directly (e.g., when they respond to outreach)
  • Our clients (e.g., where clients share candidate information with us)

5. How We Use Personal Data

We use personal data to:

  • Respond to enquiries and manage relationships with clients
  • Deliver candidate sourcing and (where agreed) outreach services
  • Communicate with candidates about relevant opportunities (where appropriate)
  • Share candidate profiles with clients for recruitment and placement purposes
  • Maintain sourcing/outreach records for transparency and auditing
  • Improve our website and services
  • Comply with legal requirements and protect our legal rights

6. Lawful Bases for Processing (UK GDPR)

We rely on the following lawful bases:

For website visitors

  • Legitimate interests (site security, basic analytics)
  • Consent (for non-essential cookies, where used)

For client contacts and enquiries

  • Contract (where needed to deliver our services)
  • Legitimate interests (business communications, service improvement)
  • Legal obligation (accounting/tax records where applicable)

For candidate data

Depending on context, we rely on:

  • Legitimate interests (recruitment sourcing, contacting candidates about relevant roles, assessing suitability at a high level)
  • Contract (where the candidate engages with us/our client and processing is necessary for recruitment steps)
  • Consent (where required or appropriate, e.g., if a candidate asks us to retain details for future roles)

We balance our legitimate interests against the rights and freedoms of individuals and support opt-out/objection rights.

7. Candidate Outreach (Email/LinkedIn) and PECR

Where we contact candidates or professionals via LinkedIn and/or email:

  • We do so in a professional recruitment context
  • We aim to keep communications relevant and proportionate
  • We provide a clear way to opt out of further contact

If you wish to opt out, you can reply requesting no further contact or contact us at: info@toprecruitmentresearch.co.uk.

8. Sharing Personal Data

We do not sell personal data.

We may share personal data with:

  • Our clients (recruitment agencies/staffing firms) for the purpose of recruitment and placement
  • Client end-clients, where the client submits the candidate for a role (typically via the client, not us directly)
  • Service providers who help operate our business (e.g., email systems, CRM/ATS tools, analytics providers)
  • Professional advisers (legal/accounting) where necessary
  • Authorities where required by law

All third parties are required to protect data and process it in line with applicable laws.

9. Data Processors and Controller/Processor Roles

In most cases:

  • We are a Data Controller for candidate data we source and store for recruitment sourcing purposes.
  • Our client is typically an independent Data Controller for candidate data once we share it with them for recruitment/placement.

Where we process personal data strictly on a client’s instructions (e.g., uploading to a client ATS/CRM), we may act as a Data Processor for that limited activity.

10. International Transfers

Where personal data is transferred outside the UK/EEA (for example, where our service providers host data internationally), we ensure safeguards such as:

  • UK adequacy regulations, and/or
  • Standard Contractual Clauses / International Data Transfer Agreements (as applicable)

11. Data Retention

We retain data only as long as necessary for the purposes described above.

Typical retention periods:

  • Client enquiry data: up to 12 months
  • Client contract and billing records: as required by legal/accounting obligations
  • Candidate sourcing data and outreach records: typically up to 12 months (or longer only where there is a lawful basis and continued relevance)

Candidates may request deletion at any time where applicable.

12. Your Rights Under UK GDPR

Individuals have rights to:

  • Access personal data
  • Rectify inaccuracies
  • Request erasure (where applicable)
  • Restrict processing
  • Object to processing (including outreach where legitimate interests are relied upon)
  • Data portability (where applicable)

To exercise rights, email: info@toprecruitmentresearch.co.uk.

13. Cookies Policy

What are cookies?

Cookies are small files stored on your device when you browse a website. They help the website function and help us understand usage.

Cookies we may use

  • Strictly necessary cookies (essential site functions)
  • Analytics cookies (to understand site usage and improve pages)
  • Functional cookies (remember preferences)

Managing cookies

You can control cookies through:

  • Your browser settings, and/or
  • A cookie banner/consent tool (if implemented)

Disabling cookies may affect the website’s functionality.

14. Security

We use appropriate technical and organisational measures to protect personal data, including:

  • Access controls and least-privilege access
  • Secure systems and reputable providers
  • Organisational measures to reduce unauthorised access

No system is 100% secure, but we take reasonable steps to protect data.

15. Third-Party Links

Our website may link to third-party sites (e.g., LinkedIn). We are not responsible for the privacy practices of third-party websites.

16. Changes to this Policy

We may update this Policy from time to time. The latest version will always be published on this page with the updated date.

17. Complaints

You can raise concerns with us first at info@toprecruitmentresearch.co.uk.
You also have the right to complain to the UK regulator:

Information Commissioner’s Office (ICO)
Website: https://www.ico.org.uk

18. Contact

If you have any questions about this Policy or how we handle personal data, contact:

Top Virtual Assistance Ltd, The Watermark, 9 Ribbleton Lane, Preston, England, PR1 5EZ

Last updated: 16/12/2025

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