Privacy Policy

Sterling Advisory

Last updated: March 2026

Sterling Advisory is a sole trader business operated by Scott Barley, providing credit control and accounts receivable consultancy services. This Privacy Policy explains how we collect, use, store, and protect personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Sterling Advisory is registered with the Information Commissioner’s Office (ICO).

1. Data Controller

The data controller responsible for your personal data is:

Scott Barley, trading as Sterling Advisory
Email: scott@sterlingadvisory.uk
Website: sterlingadvisory.uk

2. What Data We Collect

We may collect and process the following categories of personal data:

From website visitors:

• Name, email address, and message content submitted through our contact form.

From clients:

• Business name, contact name, email address, telephone number, and postal address.
• Financial information including invoice details, payment records, and outstanding balances.
• Any other information provided to us in the course of an engagement.

From client customers (in the course of credit control work):

• Contact names, email addresses, and telephone numbers.
• Invoice and payment information.

When processing personal data belonging to a client’s customers, Sterling Advisory acts as a data processor on behalf of the client, who remains the data controller.

3. How We Use Your Data

We use personal data for the following purposes:

• To respond to enquiries submitted through our website or by email.
• To provide credit control and accounts receivable services as agreed with clients.
• To issue invoices and manage payment of fees.
• To comply with legal and regulatory obligations.

4. Lawful Basis for Processing

We process personal data on the following lawful bases:

• Contract: Processing is necessary for the performance of a contract with the client, or to take steps at the client’s request prior to entering into a contract.
• Legitimate interests: Processing is necessary for our legitimate business interests, such as responding to enquiries, managing client relationships, and improving our services, where those interests are not overridden by the individual’s rights.
• Legal obligation: Processing is necessary to comply with a legal obligation, such as maintaining financial records.

5. Data Sharing

We do not sell, rent, or trade personal data to third parties.

We may share personal data with:

• Formspree (contact form processor) — to receive and process website enquiries.
• Our accountant or tax adviser — where necessary for financial reporting.
• Legal or regulatory authorities — where required by law.

We will not share client data with any other third party without prior written consent, except where required by law.

6. Data Storage and Security

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

• Secure, password-protected devices and accounts.
• Encrypted email communication where appropriate.
• Limiting access to personal data to only those who need it.

Personal data is stored within the United Kingdom. Where any data is processed by third-party services (such as Formspree), we ensure appropriate safeguards are in place.

7. Data Retention

We retain personal data only for as long as necessary:

• Website enquiry data: Deleted within 12 months of the enquiry being resolved, unless a client relationship is established.
• Client engagement data: Retained for 6 years from the end of the engagement, in accordance with HMRC requirements for business records.
• Client customer data: Returned or deleted upon completion of the engagement, unless retention is required by law or agreed with the client.

8. Your Rights

Under the UK GDPR, you have the following rights in relation to your personal data: the right to access your personal data and request a copy of the information we hold about you; the right to rectification of inaccurate or incomplete data; the right to erasure of your personal data where there is no compelling reason for continued processing; the right to restrict processing in certain circumstances; the right to data portability; and the right to object to processing based on legitimate interests.

To exercise any of these rights, please contact us at scott@sterlingadvisory.uk. We will respond within one month of receiving your request.

9. Cookies

The Sterling Advisory website does not use cookies or tracking technologies. We do not use analytics services. No data is collected about your browsing behaviour.

10. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices of those websites and encourage you to read their privacy policies.

11. Changes to This Policy

We may update this Privacy Policy from time to time. The latest version will always be available on our website. Material changes will be communicated to active clients in writing.

12. Complaints

If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office:

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