Privacy Policy

We pride ourselves in being able to find made-to-measure candidates for jobs in a way that’s never been done before – saving employers weeks of hassle

The purpose of this Privacy Notice is to explain how we handle your personal data, how we store it,
and our commitment to keeping it safe. It explains what your rights are, and how you can access the
data we hold about you.

Top Five Percent is a Limited Company registered in England and Wales, with the company
registration number 07681663.

Our registered office is 56 Leman Street, London, United Kingdom, E1 8EU and we conduct our
trading business from 38 Chancery Lane, London WC2A 1EL.

Legitimate interest

In most situations, we need access to your data to pursue our legitimate interests in a way which
might reasonably be expected as part of running our business and which does not materially impact
your rights, freedom or interests.

For example, we will use your information to contact you about job opportunities which we believe you
may be interested in us putting you forward for. We might also use your contact details in order for us
to keep you up to date with hiring trends in your market, or to tell you about candidate profiles we
think might interest you.

Contractual obligations

In certain circumstances, we will need to process your personal data in order to comply with our
contractual obligations. For example, if you apply to register with us as a candidate, we’ll need to
collect your reference details in order to verify your work history and fulfil our contractual obligations to
our clients.


In particular situations, we’ll ask for your consent to collect and process your data. For example, we’ll
ask you to check a box or actively sign up to receive email newsletters from us.

When do we collect your personal data?

  • When you apply for any job we are advertising, either on our own website or on any jobs boards we advertise on (including, but not limited to, Reed and City Jobs).
  • When you have demonstrated your interest in a new job, and thus in our services, by posting your CV to a jobs board (including, but not limited to, Reed and City Jobs).
  • When you register with us as a candidate, prospective Top Five Percent employee, or client.
  • When you ask us to act on your behalf, either to find you work or find you or your company employees.
  • When you engage with us on social media.
  • When you contact us by any means with queries, complaints or comments.
  • When you’ve given a third party permission to share with us the information they hold about you – for example, your employment referees.

What sort of data do we collect about you?

  • If you are a candidate, we hold the data that you provide us when you register with Top
    Five Percent seeing employment. This includes your CV, name, date of birth, home
    address, employment history, email and telephone number.
  •  If you are temping through Top Five Percent, this will also include your PAYE information,
    such as your bank details, National Insurance Number and tax code.
  • We also hold copies of documents you provide to prove your identity and employment
    history for legal reasons, including your passport or documentation showing your right to
    work in the UK. This will include details of your full name, address, date of birth and
    usually an image of you. If you provide a passport, the data will also include your place of
    birth, gender and nationality.
  • If you are an employer, we hold the data that you provide us when you engage us to
    provide you with candidates. This includes your company name, contact details,
    registration number, and details of any credit check we perform on you before we agree to
    provide you with services. Further details of the way we use and protect this data can be
    found in our Partnership Agreement.
  • We also collect details of your interactions with us, in order for us to ensure that we are
    able to look after your needs efficiently. For example, we collect notes from our
    conversations with you, and details of any comments or feedback you make to us.

How do we use your data and why?

  • To enable us to perform the role you’ve asked us to: whether that’s to help find you a job,
    or to identify suitable candidates for you or your company. If we don’t collect your data
    when you engage our services, we won’t be able to fulfil our remit, and comply with our
    legal obligations. For example, if you are temping through Top Five Percent, we’ll need to
    hold and use your bank details in order for us to be able to pay you.
  • To respond to your queries and questions. Holding your data allows us to respond and
    continue to engage with you. We usually also keep a record of your interactions with us,
    to inform any future communication, and to demonstrate how we communicated with you
    throughout. We do this on the basis of our contractual obligations to you, our legal
    obligations and our legitimate interests in providing you with the best possible service.
  • To protect our business and our employers’ businesses, and to comply with our legal
    obligations. This includes using your personal data to maintain and update your record
    with us. We’ll do all of this as part of our legitimate interest and to fulfil our legal
  • To send you communications required by law or which are necessary to inform you about
    our changes to the services we provide you. For example, updates to this Privacy Notice,
    updates to our Partnership Agreement, or Payroll related documentation, such as your
    Payslip, P45 or P60.
  • If you actively choose to opt into our newsletter, we will use your personal data to keep
    you informed by email about news, promotions, events, and competitions. You are free to
    opt out of these communications at any time.
  • To develop, test and improve the systems, services and products we provide to you. We’ll
    do this on the basis of our legitimate business interests.

Protecting your data

Protecting your data is of the utmost importance to us. We commit to treating your personal
information with great care, and taking all possible steps to protect it.

The CRM system that your data is held on is password protected, and heavily encrypted.
Each member of the Top Five Percent team has received one to one Data Training to help them take
steps to keep your data safe. These steps include policies such as not allowing computers to
auto-save and input passwords, clearing desktops and maintaining a paperless office.

We maintain a Risk Register to ensure that we are fully aware of any possible weaknesses in our
system, and to enable us to ensure our procedures as as robust as possible.

How long will we keep your data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary. At
the end of that retention period, your data will be deleted completely. Retention periods vary
depending on the ways you have chosen to interact with us.

For example, if you’re a candidate, we’ll keep your personal data (including your CV) for up to three
years after you’ve registered with us, so we can provide you with the best possible service, and
comply with our legal and contractual obligations.

For full details of our retention policies, please contact our Data Controller, Ellie Knapp, at

Who will we share your data with?

  • We will share your data with individuals or companies who require it in order to allow us to
    perform the job you’ve engaged us to do. For example, if you are a candidate we could
    share your data with an employer’s HR representative for the purposes of finding you
  • In the future, we may expand, reduce or sell the Partnership and this may involve the
    transfer of divisions or the whole business to new owners. If this happens, your personal
    data will, where relevant, be transferred to the new owner or controlling party, under the
    terms of this Privacy Notice.
  • For further information please contact our Data Controller, Ellie Knapp, at

Where is my data held?

The vast majority of the data we hold is kept within the European Economic Area (EEA), including the
location of our servers, and those of our suppliers.

Very occasionally, we may have cause to send your data outside the EEA – for example, if you are a
candidate and we send your information to an employer in the United States of America – but this will
only ever be done with your knowledge and consent.

If we do this, we have procedures in place to ensure your data receives the same protection as if it
were being processed inside the EEA. For example, our contracts with our employers stipulate the
standards they must follow at all times.

We hope that our Privacy Notice has been helpful, and has answered some of your questions
regarding how we use, store and protect your data.

If you have any questions you’d like to ask us, please contact our Data Controller, Ellie Knapp by
email at