Privacy Policy

1. Who We Are

Cygnus Professionals UK Ltd is a company registered in England and Wales. We are the official UK and European partner of Cygnus Professionals Inc., headquartered in New Jersey, USA.

Registered Office: 71–75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom

Contact Email: enquiries@cygnuspro.co.uk

ICO Registration Number: [INSERT ICO NUMBER]

For the purposes of UK GDPR, Cygnus Professionals UK Ltd is the Data Controller in respect of personal data collected through this website and our service operations.

2. Data We Collect

Website Visitors

Name, email address and company name submitted via our contact form
Message content and service interest submitted via our contact form
Technical data including IP address, browser type, device type and pages visited (collected automatically via server logs)

Candidates & Job Applicants

Full name, email address, telephone number and location
CV / résumé and supporting documents
Employment history, qualifications and professional certifications
Right to work status and nationality (where legally required)
Security clearance status (where relevant to a specific role)
References and background check results (with your consent)

Client Contacts

Business contact details including name, job title, company and email
Correspondence and contractual documentation

We do not collect special category data (health, ethnicity, religion, biometric data) unless explicitly required and consented to for a specific regulated engagement.

3. How We Use Your Data

Purpose	Data Used
Responding to website enquiries	Name, email, message content
Providing recruitment and talent services	CV, employment history, contact details
Matching candidates to client requirements	CV, skills, availability, right to work
IR35 determination and compliance	Employment status, engagement details
Right to work verification	Nationality, documentation status
Managing client relationships	Business contact details, correspondence
Sending relevant service updates (with consent)	Name, email
Legal and regulatory compliance	All categories as required by law
Improving our website and services	Technical/analytics data (anonymised)

4. Lawful Basis for Processing

Under UK GDPR Article 6, we rely on the following lawful bases:

Legitimate Interests (Art. 6(1)(f)): processing candidate and client data to deliver our core recruitment and consultancy services, where our interests are not overridden by your rights.
Contract (Art. 6(1)(b)): processing necessary to perform a contract with you, or to take steps at your request prior to entering a contract.
Legal Obligation (Art. 6(1)(c)): processing required to comply with UK employment law, tax obligations, right to work checks and IR35 legislation.
Consent (Art. 6(1)(a)): where you have given clear consent, for example to receive marketing communications. You may withdraw consent at any time.

5. How Long We Keep Your Data

Data Type	Retention Period	Reason
Website enquiry data	12 months	To follow up on potential business relationships
Candidate CVs & profiles (active)	2 years from last contact	Recruitment matching and talent pipeline
Candidate CVs (placed candidates)	7 years	Legal and contractual obligations
Client contact data	Duration of relationship + 7 years	Contractual and legal obligations
Financial records	7 years	HMRC and Companies House requirements
Right to work documentation	Duration of engagement + 2 years	Home Office compliance requirements

After these periods, data is securely deleted or anonymised. You may request earlier deletion, see Your Rights below.

6. Who We Share Your Data With

We do not sell your personal data. We share data only where necessary:

Client organisations: candidate profiles are shared with client organisations for the purpose of matching and placement, with your knowledge and agreement.
Cygnus Professionals Inc. (USA): our parent company, for the purpose of delivering global talent and technology services. This is an international transfer (see Section 7).
Background check providers: where security clearance or reference checks are required and consented to.
Professional advisors: lawyers, accountants and insurers, under confidentiality obligations.
Regulatory authorities: HMRC, Home Office and the ICO, where legally required.

7. International Data Transfers

As the UK partner of Cygnus Professionals Inc. (USA), some personal data may be transferred to the United States. The USA is not deemed to have an equivalent level of data protection to the UK under UK GDPR.

Where such transfers occur, we ensure appropriate safeguards are in place, including:

International Data Transfer Agreements (IDTAs) approved by the ICO
Contractual clauses that bind the recipient to UK GDPR-equivalent standards
Transfer only where necessary for the specific service you have engaged us for

You may request details of the specific safeguards in place by contacting us at enquiries@cygnuspro.co.uk.

8. Candidate & Applicant Privacy

When you submit your CV to Cygnus Professionals UK Ltd, whether via our website, by email or through a third-party platform, you are consenting to us holding and processing your data for the purpose of identifying and presenting suitable employment or contract opportunities.

Specifically, we will:

Store your CV and profile securely in our candidate database
Contact you regarding opportunities that match your experience and preferences
Share your profile with prospective client organisations with your prior knowledge
Conduct right to work verification as required by UK law
Assess IR35 status where relevant to a contract engagement

We will not share your CV with any client without first discussing the opportunity with you. You may withdraw from our database at any time by emailing enquiries@cygnuspro.co.uk with the subject line "Remove My Data".

9. Cookies

Our website uses minimal cookies. We do not use advertising or tracking cookies. The cookies we use are:

Cookie	Purpose	Duration
Session cookie	Maintains your session while browsing the site	Session (deleted on browser close)
Preference cookie	Remembers any display preferences you have set	12 months

By continuing to use our website, you consent to our use of these essential cookies. We do not currently use Google Analytics or any third-party tracking. Should this change, we will update this policy and seek fresh consent.

10. Your Rights Under UK GDPR

Under the UK General Data Protection Regulation and the Data Protection Act 2018, you have the following rights:

Right of Access: you may request a copy of all personal data we hold about you (Subject Access Request).
Right to Rectification: you may ask us to correct inaccurate or incomplete data.
Right to Erasure: you may ask us to delete your data where there is no compelling reason for us to continue processing it.
Right to Restriction: you may ask us to restrict processing of your data in certain circumstances.
Right to Data Portability: you may request your data in a structured, commonly used, machine-readable format.
Right to Object: you may object to processing based on legitimate interests or for direct marketing purposes.
Right to Withdraw Consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at enquiries@cygnuspro.co.uk. We will respond within 30 days in accordance with our legal obligations.

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Website: ico.org.uk
Helpline: 0303 123 1113

11. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction or alteration. These measures include:

SSL/TLS encryption on all data transmitted via our website
Restricted access to personal data on a need-to-know basis
Secure storage of candidate and client data
Regular review of our data handling practices
Staff training on data protection obligations

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours and affected individuals without undue delay, as required by UK GDPR Article 33.

12. Contact Us & Data Queries

For any questions regarding this Privacy Policy, to exercise your data rights, or to make a Subject Access Request, please contact us:

Email: enquiries@cygnuspro.co.uk
Post: Cygnus Professionals UK Ltd, 71–75 Shelton Street, Covent Garden, London WC2H 9JQ
Subject line: "Data Privacy Request" or "Subject Access Request"

We will acknowledge your request within 5 working days and respond in full within 30 calendar days.

Note: This policy was last reviewed in June 2025. We reserve the right to update it to reflect changes in law or our data practices. Significant changes will be communicated via our website. We recommend reviewing this page periodically.

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