Last updated: 27 October 2025
Version: 1.0
1. Who we are
True North Virtual Assistance (“TNVA”, “we”, “us”) provides virtual assistant services in the UK.
- Data Controller: Andrea Clayson (sole trader)
- Email: andrea@tnva.co.uk
- Registered/Business Address: 170 High Street West, Sunderland, SR1 1UP
We are responsible for deciding how and why we process your personal data, in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
2. Scope of this policy
This policy covers personal data we process when you:
- use our website https://tnva.co.uk (the “Site”), including our Contact Me form;
- communicate with us by email, phone, or social media;
- receive our services or enquire about them.
For information about cookies and similar technologies, please see Section 8 (Cookies & tracking) and our separate Cookie Policy linked in the Site footer.
3. What data we collect
We only collect data that is adequate, relevant, and limited to what is necessary.
Data you provide directly
- Enquiries/Contact forms: name, email address, phone number, message content, and any files you upload.
- Client onboarding: business name, billing details, service preferences, and (where applicable) accounting or scheduling information you choose to share.
Data we collect automatically (website)
- Technical/usage data: IP address, device type, browser, pages viewed, and referral source.
[If you use analytics:] This is collected via analytics cookies or similar tools only with your consent. See Section 8.
Special category data
We do not intentionally collect special category data (e.g., health data) via our Site. Please do not include such information in contact messages. If our service engagement requires it, we will explain why and the lawful basis before processing.
4. How we use your data (purposes)
We use your personal data to:
- Respond to enquiries and provide quotes.
- Deliver and administer services you request.
- Operate and secure the Site, prevent fraud/abuse, and keep records.
- [Optional] Send marketing you’ve opted in to (e.g., newsletters, service updates).
We will not use your data for purposes that are incompatible with those listed above.
5. Lawful bases for processing
We rely on one or more of the following lawful bases under UK GDPR:
- Contract: to take steps at your request before entering into a contract or to perform a contract with you (e.g., provide services, handle support).
- Legitimate interests: to run and improve our business and Site (e.g., fraud prevention, record-keeping, basic analytics that are strictly necessary). We balance these interests against your rights.
- Consent: for non-essential cookies/analytics and for direct marketing. You can withdraw consent at any time (see Section 11).
- Legal obligation: to comply with laws (e.g., tax/audit requirements).
6. Who we share your data with (recipients)
We share data only when necessary, under contracts that protect your information. Typical recipients include:
- Hosting & infrastructure: our website host and email provider (e.g., EasyWP/Namecheap for hosting; Microsoft 365/Outlook for email).
- IT & operations tools: [Insert any tools you actually use—e.g., project management, ticketing].
- Analytics/consent tools: [e.g., Cookie banner provider; analytics vendor, if enabled].
- Marketing tools (only if you opt in): [e.g., Mailchimp or equivalent].
- Professional advisers: accountants, legal advisers.
- Authorities: where required by law.
We do not sell your personal data.
7. International transfers
Some providers may store data outside the UK. Where this occurs, we ensure appropriate safeguards (e.g., UK International Data Transfer Agreement or adequacy regulations) are in place. [State specific countries/tools if known.]
8. Cookies & tracking
Our Site uses cookies and similar technologies.
- Strictly necessary cookies run to make the Site work and do not require consent.
- Non-essential cookies (e.g., analytics, advertising, embedded third-party content) require your prior consent. You can accept/reject by using our cookie banner and update choices any time.
Full details (types, purposes, duration, and third parties) are set out in our Cookie Policy. We do not set non-essential cookies until you consent.
9. Data retention
We keep personal data only as long as needed for the purposes collected, including legal/accounting requirements, after which we delete or anonymise it. Typical periods:
- Enquiry data: [e.g., 12 months] after last contact if no contract follows.
- Client records/invoices: [e.g., 6 years] to meet tax/audit obligations.
- Marketing lists: until you withdraw consent or we identify inactivity for [e.g., 24 months].
We review retention periodically.
10. Security
We use appropriate technical and organisational measures to protect your data (e.g., HTTPS encryption, access controls, least-privilege, regular updates). However, no system is 100% secure.
11. Your rights
You have the following rights (subject to conditions): Access, rectification, erasure, restriction, objection, data portability, and the right to withdraw consent at any time without affecting prior processing. You also have rights regarding automated decision-making and profiling (we do not perform these on the Site).
To exercise your rights, contact andrea@tnva.co.uk. We aim to respond within one month.
12. Children
Our services are aimed at adults and are not intended for children. We do not knowingly collect children’s data.
13. Complaints
If you are concerned about our handling of your data, please contact us first. You also have the right to complain to the Information Commissioner’s Office (ICO): ZB954785
Website: https://ico.org.uk/
Telephone: 0303 123 1113
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
14. Changes to this policy
We may update this policy from time to time. If changes are material, we will post a clear notice on the Site and update the date/version above.
15. Contact
Questions about this policy or your data?
Email: andrea@tnva.co.uk
Registered Address: 170 High Street West, Sunderland, SR1 1UP