Yes – a consequence of being a landlord is that you control personal data I.e. data about your tenant – in data protection law you are known as a data controller.

In the law of agency, a principal (in this context a landlord) expressly or implicitly, authorises an agent (in this context a letting agent, gas engineer, inventory clerk etc.) to work under his or her control and on his or her behalf. In terms of data protection, an agent is acting as a data processor, processing data on behalf of the principal who is the data controller.

In accordance with section 2 of The Data Protection (Charges and Information) Regulations 2018 a data controller must pay a charge to the Information Commissioner unless all of the processing of personal data they undertake is exempt processing. The same instrument provides that a data controller must provide to the Information Commissioner certain information such as the name and address of the data controller. Section 137 of Data Protection Act 2018 also refers to controllers paying charges to the Commissioner.

Within the context of data protection, the term ‘register’ originates in the now repealed Data Protection Act 1998 which required data controllers to notify the Commissioner for inclusion in the register maintained by the Commissioner. Interestingly the 2018 Acts make no reference to ‘register’ but the term continues to be widely used including on the Information Commissioner’s Office (ICO) website.

To pay your data protection fee here

Further Reading

The Data Protection (Charges and Information) Regulations 2018

Data Protection Act 2018

Data Protection Act 1998

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