Privacy Notice

Privacy Notice

Khmer Top Service Limited trading as Top Recruitment Cambodia with registered address at 072, Ground Floor, Phnom Penh Centre, corner Sihanouk & SOthearos Boulevards, Phnom Penh, Kingdom of Cambodia (“We”, “Us”) are committed to protecting and respecting your privacy. This Privacy Notice (together with any other documents referred to herein) sets out the basis on which the personal data collected from you, or that you provide to Us, will be processed by Us in connection with Our recruitment processes. Please read the following carefully to understand Our views and practices regarding your personal data and how We will treat it.

For the purpose of the General Data Protection Regulation (“GDPR”) the Data Controller is Kevin Britten.


Our Appointed Representative In The European Economic Area (EEA)

As We are based in Cambodia, We have no appointed representative within the EEA. We operate in full compliance with the laws and regulations of the Kingdom of Cambodia.

We use an online application to assist with Our recruitment process. We use this software to process personal information as a data processor on Our behalf. Our online application provider is only entitled to process your personal data in accordance with Our instructions.

Where you apply for a job opening posted by Us, these Privacy Notice provisions will apply to Our processing of your personal information.

Where you apply for a job opening via the application function on a job site or similar online service provider (“Partner”), you should note that the relevant Partner may retain your personal data and may also collect data from Us in respect of the progress of your application. Any use by the Partner of your data will be in accordance with the Partner’s Privacy Notice.


Your Personal Information

Information We collect from You

We collect and process some or all of the following types of information from you:

  • Information that you provide when you apply for a role. This includes information provided through an online job site, via email, in person at interviews and/or by any other method.
  • In particular, We process personal details such as name, email address, address, telephone number, date of birth, qualifications, experience, information relating to your employment history, skills experience that you provide to Us, as well as your video in case you conduct your interview using a Video Interview feature.
  • If you contact Us, We may keep a record of that correspondence.
  • A record of your progress through any hiring process that we may conduct.
  • Details of your visits to our Website including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to our Website and the resources that you access.

Information We Collect From Other Sources

Our online application provides Us with the facility to link the data you provide to Us, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.

We may receive your personal data from a third party who recommends you as a candidate for a specific job opening or for our business more generally.


Uses Made Of Your Information

Lawful basis for processing

We rely on legitimate interest as the lawful basis on which We collect and use your personal data. Our legitimate interests are the recruitment of staff by Our business.

Where you apply for a job opening we rely on your consent, which is freely given by you during the application process, to disclose your personal data to our Clients on the basis described below.

Purposes of processing

We use information held about you in the following ways:

  • To consider your application in respect of a role for which you have applied.
  • To consider your application in respect of other roles.
  • To communicate with you in respect of the recruitment process.
  • To enhance any information that we receive from you with information obtained from third party data providers.
  • To find appropriate candidates to fill Our job openings.

Automated decision making/profiling

We may use our online technology to select appropriate candidates for Us to consider based on criteria expressly identified by us in relation to the role for which you have applied. The process of finding suitable candidates is automatic, however, any decision as to who We will contact will be made by Our staff.


Disclosure of Your Information

As set out above, we pass your information to our third party service providers, who use it only in accordance with our instructions and as otherwise required by law.

We will disclose to our Clients certain personal data that We hold, including but not limited information about your progress through our hiring process for the applicable job opening, as well as tangible, intangible, visual, electronic, present, or future information that we hold about you, such as your name, contact details and other information involving analysis of data relating to you as an applicant for employment (collectively “Disposition Data”).


How we store your Personal Data


We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do Our best to protect your personal data, We cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.

Where We store your Personal Data

Where we store your personal data in our own systems, it is stored in our secure servers at out office address or on our secure cloud servers.

By submitting your personal data, you agree to this transfer, storing or processing outside the EEA.

If you would like further information please contact Us (see ‘Contact’ below).

How long we keep your Personal Data

We will hold all the data for five years.

Your personal information will be deleted on one of the following occurrences:

  • deletion of your personal information by you (or by another person engaged by the Customer); or
  • receipt of a written request by you (or another person engaged by you) to us.


How to complain

We hope that We can resolve any query or concern you raise about Our use of your information.



All questions, comments and requests regarding this Privacy Notice should be addressed to Kevin Britten, Managing Director, Khmer Top Service Limited using the Client Enquiries form on this website.

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