Record Keeping and Data Protection (Wales)

GDPR and ICO Requirements – Landlord 1 House and Paper Records

27 May 2018 | 2 comments


I’ve got 1 house in Wales which I let out to a long term tenant with no deposit, The only documents I have with the Tenants details are the Tenancy Agreement and a reference which are both paper copies and I don’t currently have any electronic files stored. I keep electronic files for my accounts which don’t contain details about the Tenant.

1)With regards to GDPR , I have my paper Tenancy Agreement and Refs in a locked filing cabinet, and if I
a) issue my Tenant with GDPR Privicy notice (I assume as per your template they don’t need to sign?)
b) keep a log of all information I hold (as above) and where it’s held (i.e. paper file)
is there anything else I need to do?

2)Would I need to register with the ICO based on my current paper only records?

3)Should I register with the ICO just in case say I get an email about my Tenant or want to electronically store a copy of the Tenancy agreement? If I do what are my obligations?




  1. guildy

    From what you describe, registration shouldn’t be necessary. You can check for certain here.

    Otherwise everything you say sounds just fine to us.

    In respect of receiving an email, you could always immediately print the email and store it with the file and delete the email. Although technically, you have still processed information by electronic means, we’re not sure how seriously the ICO would take that. Perhaps speak to them and see if that would be sufficient to avoid registration.

    Of course, as you suggest, you could just register and then you can process information however you like (within the GDPR rules).

  2. JungleProperty

    If you collect or store data about a person on any device such as a smartphone you may need to register. It must be nigh on impossible not to process personal data on electronic equipment these days. Printing stuff off is ok but immediately the tenant calls you on your smartphone or an e-mail from the tenant hits your inbox you have processed data about a person.

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