Privacy Notice
Last updated: 8 July 2026
Status: draft. Fill every [BRACKET] value before publishing. Not legal advice; have it checked by a solicitor or publish as a working version with that caveat understood.
Sawubona ("we", "us") provides cultural companionship services for African elders in the UK. This notice explains what personal information we collect, why, and your rights.
1. Who we are
- Data controller: Sawubona UK Ltd
- Registered address: [ADDRESS]
- ICO registration number: [NUMBER]
- Contact for privacy matters: keno@onlinewebpresence.net
2. What we collect and why
If you join our waitlist or become a client family:
| Information | Why we collect it | Lawful basis |
|---|---|---|
| Your name, email, phone | To contact you about our service | Legitimate interest (waitlist), contract (clients) |
| Your elder's name, age range, area | To assess whether we can serve you | Legitimate interest, then contract |
| Your elder's languages and cultural background | To match them with a culturally compatible companion. This is the core of our service | Explicit consent (special category: ethnic origin) |
| Notes on your elder's needs, personality, and wellbeing | To match appropriately and keep visits safe | Explicit consent (may reveal health information) |
| Payment details (when you subscribe) | To take payment | Contract. Card details are held by our payment provider, not by us |
If you apply to be a companion:
| Information | Why we collect it | Lawful basis |
|---|---|---|
| Name, contact details, area, availability | To process your application | Contract (steps prior to entering one) |
| Heritage, languages, cultural background | Matching is based on shared culture and language. This is the core of the role | Explicit consent (special category: ethnic origin) |
| References | To vet you for work with vulnerable adults | Legitimate interest, legal obligation considerations |
| DBS certificate number, issue date, and status | To confirm you are safe to work with vulnerable adults. We record the certificate number and dates only. We never store a copy or image of the certificate | Legitimate interest / employment and safeguarding condition (DPA 2018 Schedule 1) |
| Visit records, check-in and check-out times, visit notes | To evidence visits, pay you, and keep elders safe | Contract |
Safeguarding records: if a concern is raised about the welfare or safety of an elder or companion, we record it, investigate, and where necessary share it with appropriate authorities. Lawful basis: safeguarding of individuals at risk (DPA 2018 Schedule 1, Part 2) and legal obligation.
3. Consent for cultural and wellbeing information
Cultural background and ethnicity are special category data under UK GDPR. Matching by culture and language is the entire purpose of Sawubona, so we ask for your explicit consent to process it when you fill in our forms. You can withdraw consent at any time by emailing keno@onlinewebpresence.net. If you withdraw consent, we will not be able to provide or continue the matching service, because we cannot match without this information.
4. Who we share it with
We do not sell personal information. We share it only with service providers who process it on our instructions:
| Provider | Purpose | Location |
|---|---|---|
| Convex | Database hosting | EU (Ireland) |
| Clerk | Secure login | US, covered by the UK IDTA / Addendum and their DPA |
| Vercel | Website hosting | US, covered by the UK IDTA / Addendum and their DPA |
| Emailit | Transactional email | EU (Czech Republic; operated by FunFirst s.r.o., which states data is not transferred outside the EU) |
| Stripe (when billing launches) | Payments | Stripe holds card data; we never see it |
Where providers store data outside the UK, transfers are protected by the UK International Data Transfer Addendum or equivalent safeguards in each provider's data processing agreement.
We may also share information where the law requires it, or where necessary to protect someone at risk (for example, a safeguarding referral to a local authority).
5. How long we keep it
| Record | Retention |
|---|---|
| Waitlist entries that do not become clients | 12 months from last contact, then deleted |
| Client family and elder records | Duration of the service plus 24 months |
| Unsuccessful companion applications | 6 months from decision |
| Companion records (engaged companions) | Duration of engagement plus 24 months |
| DBS check records (number, dates, outcome) | Duration of engagement plus 6 months |
| Safeguarding records | 6 years from resolution |
| Financial records | 6 years (HMRC requirement) |
6. Your rights
You have the right to: access a copy of your information; correct it; ask us to delete it; restrict or object to processing; data portability; and withdraw consent where consent is the basis. To exercise any right, email keno@onlinewebpresence.net. We respond within one calendar month.
If you are unhappy with how we handle your information, you can complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113. We would appreciate the chance to resolve it first.
7. Security
Information is stored in access-controlled systems. Access is limited by role: companions see only their own records, families see only their own elder's records. All access to sensitive records is logged.
8. Changes
We will update this notice as the service develops and note the date of the latest version above.