Data Retention Policy

This policy explains what personal data Rental Trust collects, how long we retain it, and the legal basis for each retention period — in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Last Reviewed

22 April 2026

Next Review Due

22 April 2027

Privacy Improvement — April 2026

Rental Trust no longer collects or stores household composition data (family structure descriptions such as "2 adults, 1 child"). This field has been permanently removed from our platform. Any previously stored household composition data has been deleted from our database. Only a neutral household size (person count) is retained where provided by the tenant.

1. Overview and Scope

Rental Trust Ltd ("we", "us", "our") is the data controller for all personal data processed through the Rental Trust platform at www.rentaltrust.co.uk. This Data Retention Policy applies to all personal data we hold about tenants, landlords, letting agents, and visitors to our platform.

Under UK GDPR Article 5(1)(e), personal data must not be kept in a form that permits identification of data subjects for longer than is necessary for the purposes for which the data is processed (the storage limitation principle). This policy sets out our retention periods for each category of personal data and the legal justification for each period.

For questions about this policy or to exercise your data rights, contact our Data Protection Officer at [email protected].

2. Data We No Longer Collect

The following categories of data were previously collected but have been permanently removed from our platform as part of our ongoing privacy improvement programme. We do not collect, store, or process this data in any form.

Removed Data FieldDescriptionDate RemovedReason
Household Composition DescriptionFree-text description of family structure (e.g. "2 adults, 1 child", "single professional"). This field was displayed on tenant profiles visible to landlords and agents.April 2026Privacy concern — family composition details are not necessary for tenancy referencing and could facilitate indirect discrimination. All previously stored values have been permanently deleted.

Note on household size: We continue to collect a neutral household size (a simple integer, e.g. "2 persons") where voluntarily provided by the tenant. This is a count only — it contains no information about the age, relationship, or family structure of the occupants.

3. Tenant Profile Data

Tenant profiles are created voluntarily by tenants seeking to present their rental credentials to prospective landlords and agents. The table below details each data field, whether it is mandatory or optional, and the applicable retention period.

Data FieldRequired / OptionalRetention PeriodLegal Basis
Full nameRequiredDuration of active profile + 30 days after deletionContract performance
Email addressRequiredDuration of active profile + 30 days after deletionContract performance
Phone numberRequiredDuration of active profile + 30 days after deletionContract performance
Current addressRequiredDuration of active profile + 30 days after deletionContract performance
NationalityOptionalDuration of active profile + 30 days after deletionConsent
Household size (person count only)OptionalDuration of active profile + 30 days after deletionConsent
Household composition descriptionREMOVED — no longer collectedN/A — all prior data deleted April 2026N/A
Employment status & lengthOptionalDuration of active profile + 30 days after deletionConsent
Income range (band only)OptionalDuration of active profile + 30 days after deletionConsent
Gross annual income (for affordability indicator)OptionalDuration of active profile + 30 days after deletionLegitimate interests
Target monthly rent (for affordability indicator)OptionalDuration of active profile + 30 days after deletionLegitimate interests
Profile photoOptionalDuration of active profile + 30 days after deletionConsent
Identity document (Right to Rent)OptionalMinimum 12 months after tenancy end (legal obligation)Legal obligation
Income proof documentOptionalDuration of active profile + 30 days after deletionConsent
Personal summaryOptionalDuration of active profile + 30 days after deletionConsent
University / educational institutionOptionalDuration of active profile + 30 days after deletionConsent

4. Landlord Account Data

Data FieldRetention PeriodLegal Basis
Full name, email, phoneDuration of active account + 30 days after closureContract performance
Hashed passwordDuration of active account + 30 days after closureContract performance
Unlock history (which profiles were accessed)7 years from transaction dateLegal obligation (tax/accounting)
Unlock credit balanceDuration of active account + 30 days after closureContract performance
Favourited profilesDuration of active account + 30 days after closureLegitimate interests
Login activity logs90 daysLegitimate interests (security)

5. Letting Agent Account Data

Data FieldRetention PeriodLegal Basis
Agency name, contact name, email, phoneDuration of active account + 30 days after closureContract performance
Business address and locationDuration of active account + 30 days after closureContract performance
Hashed passwordDuration of active account + 30 days after closureContract performance
Subscription and billing records7 years from transaction dateLegal obligation (tax/accounting)
Tenant access history7 years from transaction dateLegal obligation (tax/accounting)
Login activity logs90 daysLegitimate interests (security)

6. Payment and Transaction Data

All payment processing is handled by Stripe, a PCI-DSS Level 1 certified payment processor. Rental Trust does not store full card numbers, CVV codes, or raw bank account details. We retain only the metadata necessary for accounting, dispute resolution, and legal compliance.

DataRetention PeriodLegal Basis
Transaction amount, date, and reference7 yearsLegal obligation (HMRC / Companies Act 2006)
Stripe customer ID and payment intent ID7 yearsLegal obligation
Subscription plan and billing cycle7 yearsLegal obligation
Refund and chargeback records7 yearsLegal obligation
Card last 4 digits (for display only)Duration of active account + 30 daysContract performance

7. Complaint and Dispute Records

When a complaint is submitted through our formal complaints procedure, we create a complaint record with a unique reference number (format: RT-YYYY-NNNN). This record is retained to allow us to investigate, respond, and demonstrate compliance with our complaints handling obligations.

DataRetention PeriodLegal Basis
Complaint reference number and submission date6 years from resolutionLegitimate interests (legal defence)
Complainant name and contact details6 years from resolutionLegitimate interests (legal defence)
Complaint description and category6 years from resolutionLegitimate interests (legal defence)
Internal notes and assignee records6 years from resolutionLegitimate interests (legal defence)
Status history and resolution outcome6 years from resolutionLegitimate interests (legal defence)

8. Email and Communications Data

DataRetention PeriodLegal Basis
Transactional email logs (sent/delivered status)90 daysLegitimate interests (debugging, delivery confirmation)
Support email correspondence3 years from last contactLegitimate interests (dispute resolution)
Marketing email consent recordsUntil consent withdrawn + 3 yearsLegal obligation (PECR compliance)
In-platform messages between tenants and landlordsDuration of active accounts + 30 daysContract performance

9. Technical and Log Data

DataRetention PeriodLegal Basis
Server access logs (IP address, request path, timestamp)90 daysLegitimate interests (security, fraud prevention)
Authentication event logs (login attempts, failures, lockouts)90 daysLegitimate interests (security)
Session tokensUntil session expiry or logoutContract performance
Cookie consent recordsUntil consent withdrawn + 3 yearsLegal obligation (PECR)
Analytics data (anonymised, aggregated)Indefinite (no personal identifiers)Legitimate interests

10. Deletion and Erasure Procedures

When a retention period expires, or when a valid erasure request is received, personal data is deleted or anonymised using the following procedures:

Account Deletion

When a user requests account deletion, their profile data is flagged for deletion and permanently removed within 30 days. Payment records required for legal compliance are anonymised rather than deleted.

Automated Expiry

Log data and session tokens are automatically purged on a rolling basis according to the retention periods above. No manual intervention is required.

Right to Erasure (Article 17)

Erasure requests are processed within 30 days. Where data must be retained for legal reasons (e.g. payment records), we will inform you of the applicable legal obligation.

Anonymisation

Where deletion is not possible due to legal obligations, we anonymise data by removing all direct and indirect identifiers, so the remaining record cannot be linked back to any individual.

11. Your Data Rights

Under UK GDPR, you have the right to access, correct, delete, restrict, or port your personal data. You may also object to processing based on legitimate interests. To exercise any of these rights, contact:

Data Protection Officer

[email protected]

We will acknowledge your request within 5 working days and respond in full within 30 calendar days. Complex requests may be extended by a further 60 days, in which case we will notify you.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

12. Changes to This Policy

We review this Data Retention Policy at least annually and whenever there is a material change to our data processing activities. When we make significant changes, we will notify registered users by email and update the "Last updated" date at the top of this page. Continued use of the platform after notification constitutes acceptance of the revised policy.

Related Policies

Rental Trust

www.rentaltrust.co.uk

Clearer tenant profiles, better rental decisions. Rental Trust is a technology platform that presents self-reported tenant information in a structured format. All information is provided by tenants and is not independently verified by Rental Trust.

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Platform Disclaimer: Rental Trust is a technology platform only. All tenant profile information is self-reported by tenants and is not independently verified, authenticated, or guaranteed by Rental Trust Ltd. Landlords and agents remain solely responsible for conducting their own affordability checks, reference checks, and Right to Rent checks in accordance with the Immigration Act 2014. The affordability indicator (where shown) is based on tenant-supplied information and does not constitute financial advice or a credit assessment. Rental Trust does not act as a letting agent, landlord, or credit reference agency.

© 2026 Rental Trust Ltd. All rights reserved.

www.rentaltrust.co.uk

Registered in England & Wales · Company No. [PENDING REGISTRATION] · ICO Registration No. [PENDING ICO]

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