Last updated: 10/09/26. Version 1.1.
1. About this notice
This notice explains how Reay Smith Property Ltd uses personal information about landlords, prospective landlords, and the individuals who act for them, such as directors, partners, agents and nominated contacts.
It covers you if you enquire about our HMO management service, if we contact you about it, or if we manage a property for you.
2. Who we are
Reay Smith Property Ltd is the data controller for the information described in this notice.
- Registered office: Projects Nile House, FAO Numbers Studio, Nile Street, Brighton, East Sussex, BN1 1HW
- Company number: 08774232
- ICO registration number: ZA141520
- Email: charlie@reaysmithproperty.co.uk
- Telephone: 020 3026 7320
We are members of the Property Redress Scheme, membership number PRS035371.
We hold client money protection through the safeagent Client Money Protection Scheme, membership number A8736.
3. The information we collect
- Identity information. Your name, and where you hold property through a company, the company name and number and the names of its directors.
- Contact information. Postal address, correspondence address, email address, telephone numbers.
- Property information. Addresses of properties you own or let, tenure, room numbers and configuration, condition and works history.
- Licensing information. HMO licence references, licence holder details, licence issue and expiry dates, licence conditions, and the local authority concerned.
- Financial information. Bank account details for rent remittance, rent and arrears records, invoices, fees, and figures needed for statements of account.
- Compliance information. Anti-money laundering and identity verification records, proof of ownership, and information needed to support a licence application.
- Correspondence. Emails, letters, messages, notes of calls and meetings.
- Website information. IP address, pages visited and similar analytics data.
Where we handle information about criminal convictions or cautions because it is needed for a “fit and proper person” declaration in a licence application under the Housing Act 2004, we do so only with your knowledge and only for that purpose.
4. Where we get your information
Most of it comes from you. We also obtain information from:
- Local authority public registers of HMO licences, which councils are required to keep and make available for public inspection under section 232 of the Housing Act 2004. If we have written to you and you had not previously heard from us, this is almost certainly where we obtained your name and address.
- Companies House and the Land Registry, to confirm ownership and company details.
- Publicly available sources such as your own website or letting portal listings.
- Referrals from existing clients, contractors or professional contacts.
- Third parties acting for you, such as your agent, solicitor or accountant.
5. Why we use your information, and our legal basis
- Contacting landlords who may benefit from our HMO management service. Legitimate interests, being the growth of our management business and reaching landlords who may need a specialist manager. We have carried out a balancing assessment and you can object at any time, see section 11.
- Responding to your enquiry and preparing a proposal or quote. Taking steps at your request before entering a contract.
- Managing your property under a management agreement. Performance of our contract with you.
- Handling rent and other money held on your behalf. Performance of our contract, and our legal obligations.
- Making or supporting HMO licence applications and dealing with the council. Performance of our contract, and our legal obligations.
- Anti-money laundering and identity checks. Legal obligation.
- Meeting fire safety, gas, electrical and HMO management regulations. Legal obligation.
- Keeping accounting records and dealing with HMRC. Legal obligation.
- Handling complaints, including through the Property Redress Scheme. Legal obligation, and our legitimate interest in resolving disputes.
- Establishing, exercising or defending legal claims. Legitimate interests, being the protection of our legal position.
Where we rely on legitimate interests, we have assessed whether our interests are outweighed by your rights. You can ask us for a summary of that assessment using the contact details in section 2.
6. Marketing
If you are a landlord we have not dealt with before, we may write to you by post about our management service. We will always tell you where we got your details and how to stop hearing from us.
We will only send you marketing email if you have asked us to, or where the law otherwise permits it because you hold property through a company or LLP.
You can stop all marketing from us at any time, by replying to any message, emailing charlie@reaysmithproperty.co.uk, or writing to us. We will act on it without question and keep a minimal record of your name and contact details for the sole purpose of making sure you are not contacted again.
7. Who we share it with
- Local authorities, for licence applications, variations and compliance matters
- Tenants and prospective tenants, where they must be told who the landlord is, or where the law requires the landlord’s name and address to be given
- Contractors and tradespeople, so repairs and safety works can be carried out
- Our accountants, bookkeepers and, if needed, legal advisers
- The Property Redress Scheme, in connection with redress
- Deposit protection schemes, referencing providers and insurers
- Our IT, email, accounting and property management software providers, who process information on our instructions
- HMRC and other authorities, where we are required to report or disclose
We do not sell your information, and we do not share it with third parties for their own marketing.
8. International transfers
Some of the providers we use to run our business are based outside the UK, or store information outside the UK. This applies to our email and file storage, our call recording software, and our website hosting.
Where information is transferred outside the UK, we rely on either UK adequacy regulations, where the destination country has been formally recognised as providing an equivalent standard of protection, or on the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. The effect is that your information continues to receive a level of protection equivalent to that required under UK data protection law.
If you would like details of the specific safeguards that apply to a particular transfer, contact us using the details in section 2 and we will provide them.
9. How long we keep it
- Landlord contact data used for marketing, where you never engage with us: 24 months from the date we obtained it, then deleted.
- Enquiries that do not become instructions: 12 months from last contact.
- Client records, agreements, accounts and correspondence: 6 years from the end of our contract.
- Anti-money laundering records: 5 years from the end of the business relationship.
- Opt-out and suppression records: kept indefinitely, because we need them to make sure we do not contact you again.
10. Your rights
- Be told how we use your information, which is what this notice does
- Access a copy of the information we hold about you
- Have inaccurate information corrected
- Ask us to delete information, in certain circumstances
- Ask us to restrict how we use it, in certain circumstances
- Object to our use of it where we rely on legitimate interests. Where you object to direct marketing, we must stop, with no exceptions.
- Receive certain information in a portable format
- Withdraw consent at any time, where we rely on it
To exercise any of these, contact us using the details in section 2. We will respond within one month. There is no charge.
11. How to object
If you would like us to stop contacting you, or to remove your details altogether, you do not need to give a reason and you do not need to use any particular form of words.
- Email: charlie@reaysmithproperty.co.uk
- Telephone: 020 3026 7320
We will action it the same working day wherever possible, and confirm in writing that we have done so. Where you ask us to stop marketing, we will keep only your name and contact details on a suppression list, for the sole purpose of ensuring you are not contacted again.
12. Complaints
If you are unhappy with how we have handled your information, please tell us first so we can put it right.
You also have the right to complain to the Information Commissioner’s Office at any time:
- Website: ico.org.uk/make-a-complaint
- Helpline: 0303 123 1113
- Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
13. Cookies
Our website uses cookies. Essential cookies are needed for the site to work. Non-essential cookies, including analytics cookies, are only set once you have given consent, and you can change or withdraw that consent at any time using the cookie settings link in the footer.
Our website analytics are cookieless and the data is stored on our own server, not shared with any third-party analytics provider.
Our Cookie Policy sets out the full list of cookies we use and what each one does.
14. Changes to this notice
We may update this notice. The current version is always published on this page, with the date of the last update at the top. Where a change materially affects how we use your information, we will tell you directly.