Introduction
This Privacy Policy explains how Sarah Swinburn Virtual Assistant collects, uses, stores and protects your personal data when you use this website or work with us. We will handle your personal information securely, transparently and in accordance with UK data protection legislation.
Our Privacy Policy explains how we process personal information in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
This Privacy Policy was updated on 24th July 2026.
For the purposes of this Privacy Policy:
‘Site’ means the website: Sarah Swinburn Virtual Assistant https://sarahswinburnva.co.uk
‘We’, ‘Us’ and ‘Our’ refers to the Site.
‘You’ refers to you as the user of the Site.
Who We Are
Our Site address is https://sarahswinburnva.co.uk
The responsible person for data within our business is Sarah Swinburn.
Contact details of the responsible person: sarah@sarahswinburnva.co.uk or sarahwinburnva@outlook.com
Our Data Processor is Sarah Swinburn.
Our Data Controller is Sarah Swinburn.
Our data regulator contact details are https://ico.org.uk/, and our registration number is ZB654173.
What Data Do We Collect?
We process information about:
‘Prospects’ – contacts working at or connected with potential Clients;
‘Clients’ – who have bought services from us, and ‘Client Contacts’ who are individuals employed by or contracted to Clients;
‘Suppliers’, ‘Associates’ – suppliers or potential suppliers of services to us;
‘Affiliates/Referrers’ – who have signed up to our affiliate scheme or who have referred Prospects to us;
Our Policy
We promise respectful treatment of the personal information of everyone we have contact with. We want it to be simple and clear.
This Policy explains how, when and why we collect information and how we use it. This includes the situations when other people can see or use it, and how we keep it secure.
This Policy is split into sections:
Section 1 is for everyone and includes information about cookies on our websites.
Section 2 is for you if you are or work for a business prospect.
If you are a Client or a Client Contact, Section 3 is for you.
Section 4 is for you if we have information about you purely because we are providing services to a Client. And if you’re a supplier, associate or Affiliate/Referrer, Section 5 is for you.
Section 1 – For Everyone
Whoever you are, we intend to use your information to make things work smoothly for you. If that’s not how it turns out for you, please make sure to contact us. It’s best to put things in writing, which you can do by emailing the address above.
We keep this Policy under regular review, and we may revise it as time goes on. Please check back here from time to time to make sure you’ve got the latest information.
Our General Approach to Personal Data
We commit to protecting your privacy and honouring your legal rights to control how we use your personal data.
We process personal data to:
- respond to enquiries, (for example, send you a newsletter);
- reply to queries or complaints;
- develop and manage our business relationships;
- help grow our business and fulfil our contracts;
- provide services to clients;
- calculate payments to associates or Affilates/Referrers;
- meet our legal obligations.
We want to make sure the information we hold is accurate, up to date and not held for longer than is necessary.
Categories of Data
The types of information that we will be processing depend on the nature of our relationship with you.
We may process information about you that you have yourself provided to us or published generally on the internet through social media or on other websites.
We only collect information that is relevant and that we can reasonably obtain.
This may also include your name, email address, employer or business name, job title or position, contact address, and social media details.
We may also collect information that you publish on social media where it is relevant to our interactions with you.
If you are or work for a prospect, we will collect information that helps us build a business relationship with you.
This may include information about your business and your professional interests.
In the instance you work for a customer or supplier, we will also keep records of our interactions, the work we have done for you or commissioned from you, the progress of work, and financial and accounting records.
If we are processing information about you purely because we are providing services to others, please see Section 4 below. Please note that your rights may be subject to applicable exemptions.
If you have questions or concerns about our use of your information, or how we have responded to any request about your personal data, please contact us in the first instance by emailing us at the above address.
If we can’t sort it out, the official authority contact details are via https://ico.org.uk/for-the-public/, and you can raise your concerns with them.
Downloads, Newsletters and Services
If we send a newsletter or publish a blog post, we may record whether you open an email or click on a link. We use this information to understand which content is useful and improve future communications.
There may be subroutines that trigger when you click on links or articles. They offer you information about things you are interested in.
If you subscribe to or follow a newsletter or blog, you can unsubscribe from these sequences at any time.
Existing Clients
Existing Clients may receive emails about specific offers relating to things you have already purchased. You can unsubscribe from these at any time.
We use automated email sequences to provide information you have requested, support onboarding and deliver purchased services. You can unsubscribe from these at any time.
We monitor who reads our mailing and automations, and which links you choose to use and read. We use this information to increase the content’s level of interest and help us make improvements. You can remove your information from this monitoring by disabling cookies in your web browser before opening emails from us.
We use anonymised data about you from time to time to target advertising campaigns based on profiling the sort of person who wants to receive information from us.
Prospects
We may contact Prospects from time to time. This is normally because you have requested a call, or because we are actively trying to let you know about something you may benefit from.
Social Media
We have an active presence on social media. If you are using social media they are holding and using your information in accordance with their data privacy policy.
If you ‘like’ any of our posts, ‘follow’ us or contact us on social media, we keep a record.
No Sale or Exchange of Your Data
We do not sell or exchange your personal data with organisations who may want to sell you something or use your data for research or other purposes.
Data Location and Platforms
Like most small businesses, we do not have any tailor-made software – we use mainstream packages for everything from our Client records, to email, to accounting.
As a result, your data may be held in the EEA, while other data may be held in services in the USA or elsewhere. We have picked mainstream suppliers with appropriate security standards.
We May Share Some of Your Data with These People
On occasion, we may outsource support for our own business, which may include Virtual Assistants, Web Designers, IT support, Sales and Marketing, accounting, and more. They have limited access to your data, as the service they provide to us means they need it.
For example, if our IT support wants to check the functionality of a laptop or back up, they may need temporary access to information that may include something about you.
If we invoice you, we need to process the information in the invoice.
We use our software to access any data needed. We do not permit copying or sharing and actively monitor for any potential breaches.
We keep your information and advice strictly confidential. We adhere to strict confidentiality clauses.
If you want to know who is on our team, please email and ask us.
How Long Do We Keep Your Data?
We keep your information for no longer than is necessary. We will retain your personal data (name, email address(es), telephone number(s), IP address for a minimum period of 2 years and a maximum period of 7 years. The detailed table below provides further information:
| Client records | Up to 7 years |
| Enquiry records | Up to 2 years |
| Newsletter subscriptions (if provided) | Until you ask us to unsubscribe |
| Accounting records | 6 to 7 years where legally required |
Want To See What We Hold On You?
If you want to know what information we have about you (if any) send an email to sarahswinburnva@outlook.com or sarah@sarahswinburnva.co.uk and give us your name, email address(es). We may require you to confirm your identity before proceeding.
Provided we can legitimately disclose the information to you (see Section 4), we will happily carry out a search and send you what we have.
What Are Your Rights?
You have the right to know what personal information we are collecting on you, and to amend it if it is inaccurate.
If you feel for some reason we have information we should not be keeping, or it is out of date or otherwise wrong, please let us know and we will take appropriate action.
Most of the information we hold is not based on your individual consent but is based on our needing the information to run our business and provide our products and services.
You have a “right to be forgotten”. However, there are some legal limits to it. If you want us to remove information about you, let us know. If you have been a Client, we may not be able to remove all data, as we will have to ensure that we can continue to comply with legal, accounting, taxation and our insurer’s requirements.
Our Legal Basis for Processing Your Data
If we produce a newsletter and you consent to sign up for it via a newsletter list, it is by your consent – and when you withdraw your consent we stop processing your data.
The information we hold is based on our needing the information to run our business and provide our services – either so we can perform our contract with you, or because we have a legitimate business interest in processing your data.
In some situations, we are processing personal data because we are under a legal obligation to do so. This principally relates to our business, accounting and tax records.
Section 2 – Prospects
Most of the information we process comes from you. We process it so we can reply to you, and when you contact us again we know what you asked before, what you were sent, and what you told us.
Typically, we collect your name, contact details, how we came across you, and background information from you or published by you on social media or freely accessible on the internet, on why you might be interested in our services or a relevant contact for our business.
If we have a newsletter and you sign up to it, you will be sent what you asked for. You can unsubscribe at any time by clicking the unsubscribe button on any email.
You are not automatically subscribed to any lists. You may be invited to join an appropriate one.
If we email you individually using our own email system or respond to an email sent to us at any of our business email addresses, a copy of that email will also be stored.
If you make an enquiry via our website, we will keep details of that enquiry and response for our data retention period (see How Long Do We Keep Your Data For?).
We do not routinely keep special category data. To the extent we hold this, it was supplied or made publicly available by you.
Section 3 – Clients
Once you buy a service from us, we will collect information from you at the point of sale.
This will include the information we collect from Prospects (above). We collect your email address, phone number and postal address so we can provide what we have contracted to, invoice you and keep proper records of our business relationship to support the delivery of the services you have bought.
We keep records of the services provided to you and information you give us, so we can support you when needed and advise you of any additional services you may require.
Third Party Data
As well as your own personal data, we understand that you may need to provide us with personal data relating to your employees, your workers, or third parties (often your clients or suppliers) – depending on the services we are providing to you. We hold all such information under strict confidentiality obligations, as set out in our terms of business.
Financial and Credit Card Payment Details
An external secure processor handles credit card payments in accordance with their data security policies.
We receive limited information from our processor for us to match your payment with your invoice.
You pay us by BACS or direct transfer, we know only what the bank tells us, which is usually the name of the person who paid us and how much and the reference number.
We do not routinely keep credit scores nor use credit reference agencies.
Section 4 – Third Party Information
We will act in accordance with your statutory rights, subject to the exclusions and exemptions that may apply.
When we are processing data about you on behalf of a Client, we are operating under the banner of our Client’s data privacy policy. We will refer any enquiry from you to them, as they are the ‘data controller’ responsible for dealing with your query. But we will support that by providing relevant information to our Client for passing to you.
When we are processing data about you because of a direct connection between you and our business we are acting as a ‘data controller’ (and operating under this policy).
Section 5 – Suppliers, Associates and Affiliates
If you become a supplier, associate or an Affiliate/Referrer we keep a copy of the contract between us, and your bank details so we can pay you. We also keep a record of invoices/payments for accounting purposes.
We keep a record of the work you undertook for us/our clients along with any comments, reviews or suggestions about that work including complaints (if any) and their resolution.
This information is all needed to manage our Client relationships and our supply chain.
In addition, if we set up an Affiliate/Referrer scheme, the data will be held in accordance with this policy. Furthermore, when you apply to join the scheme, we will keep the information to administer it. As a result, we will retain this information for as long as necessary to manage the scheme.
If you are a Referrer, please note that you may only make referrals to us with the knowledge and consent of the person being referred. Therefore, please ensure that you have obtained their consent before sharing their contact details with us.
Section 6 – Complaints
If you send a complaint about the way we handle your information or how we respond to a request for information or removal, you can contact us by email:
sarah@sarahswinburnva.co.uk or,
If you have a data protection complaint, we have a separate Data Protection Complaints Notice. A data protection complaint is any concern you may raise about how we have collected, used, stored, shared or deleted your personal data.
In the event of not being able to resolve the complaint, the relevant supervisory authority details can be found at https://ico.org.uk/for-the-public/.