Landlords and Tenant Data: The File You Keep Is the Case You Have
8 April 2026 · Mary Molloy Solicitors
Every landlord is a data controller, and the tenancy file leads a double life: it is the compliance record data protection law expects, and it is the evidence an RTB hearing or deposit dispute will eventually read. Keeping it properly serves both masters at once.
Collect like it will be audited
Vetting proportionately — identity, references, ability to pay from the tenant you proceed with, short-cycle deletion for the unsuccessful — and PPS numbers handled as the restricted, single-purpose data they are. The discipline pays twice: less data means less exposure when something leaks, and a clean intake file reads well in any later dispute about how the tenancy began.
Write like it will be read aloud
Arrears and dispute records are the most sensitive processing a landlord does, and the standard is factual and dispassionate: dates, amounts, communications, agreements. The tenant can access the file by request — deposit disputes now routinely open with one — and the RTB may hear it quoted. Editorial commentary about tenants ages badly in both venues; disclosure of a tenant's situation to employers, family or other landlords out of frustration converts a rent problem into a liability.
Retain like you mean it
After the tenancy: tax-supporting records for the statutory periods (your accountant's territory), dispute-relevant documents while the matter is live, the core tenancy record for a defined period against later claims — and then deletion, actually performed. Indefinite everything is the default that fails audits and inflates breach exposure. A retention schedule for a landlord fits on an index card; the difference is running it.
Read more in our main guide: GDPR for Landlords: Tenant Data Done Right · or back to the blog.
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