Renters' Rights Bill

Written evidence submitted by Peter Donnelly to The Renters’ Rights Public Bill Committee (RRB38).

Written evidence submitted by Peter Donnelly in a private capacity as a private sector landlord since 2010 who has been subject to negative events due to my home address and details being in a publicly searchable online landlord database.

I would like to request that the committee consider that the Renters’ Rights Bill (RRB) does not allow for a, fully public, searchable database of landlords and their private details.

1. Owing to the Housing Act 2004 many landlords, myself included, have been subject to their full name and full home address being published on a searchable database on the internet that can be directly accessed via a Google search. This runs contrary to all advice given by the government to protect your personal information

2. .I submit to the committee that a landlord can create a create a licence ‘check code’, with an expiry date, to share your landlord register record with someone, for example a prospective tenant. This can be done in the same format as the current driver’s licence check code. https://www.gov.uk/view-driving-licence

3. The Housing Act 2004, Section 232 allows for the publication of the home address of some landlords

https://www.legislation.gov.uk/ukpga/2004/34/part/7/crossheading/register-of-licences-and-management-orders

However the act was drafted ambiguously which ultimately led to the Information Commissioner’s office (ICO) having to issue a clarification of what was acceptable under the data protection legislation

4. The clarification was issued to the London Borough of Hammersmith and Fulham

https://www.lbhf.gov.uk/housing/private-housing/property-licensing-landlords-and-letting-agents/register-licences

‘However, it is the form in which the register is provided where it may be considered unfair and subsequently breach the DPA, such as publishing the full register on the internet. The requirement under the Housing Act is just to provide a copy of the register on request, there is no obligation to make it available electronically since publication on the internet may be unfair and excessive given the potential for ease of access by a large number of people."

5. Hammersmith and Fulham have corrected their register and it is now only searchable in person upon payment of a fee. This still allows interested parties access to the information whilst granting a degree of privacy to a landlord. However, several local authorities still publish a fully searchable database, due to the ambiguity of the Housing Act 2004.

6. I have approached 2 local authorities. who refused to remove my home address, from the searchable database both stating that the Housing Act 2004 means that this information must be published. However once shown the ICO advice they have corrected their online register.

Recommendation

I submit that the committee finds that the proposed RRB unambiguously states that a landlord’s personal details cannot be searched for on any public online database that is created as a result of the enactment of the Renters Reform Bill. This is inline with guidance issued by the ICO to ensure compliance with data protection legislation. The details can instead be searched by an interested party with the permission of the landlord via a ‘check code’.

October 2024.

 

Prepared 29th October 2024