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ICO Data Protection Fee is for a couple as landlord

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Our accountantss contacted us a month ago with regard to the ICO Data Protection Fee for a dormant Ltd company.

We set the Ltd company up in order to flip properties and to hold and rent out other properties. The company is dormant as things haven't gone as planned, so presumably we don't need to register the company for ICO Data Protection Fee until it is trading.


Now for ourselves as individuals. We own two houses, other than the one that we live in ourselves. One is jointly owned by my wife and I and this house is rented out. The other house is owned solely by me but has been in a state of development for two years and is currently empty (long story for another time) and will shortly be placed on the market for sale.


We use an agent to fully manage the property that's let out. We always communicate through the agent. We don't know the tenant's email or mobile. All we know is the address and the landline number. We keep that information stored under the name of the house in our contacts with the name of the tenant in the notes. Our contacts synchronise with our phones and our computers.


So, do we need to register for the ICO Data Protection Fee?

If we need to register for the ICO Data Protection Fee do we do so as a couple or as individuals?




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These *might* help as I have just been Googling this, this morning - not sure how official all of these are (probably not) however I made my decision to go ahead and just pay the £35 (direct debit £5 off on £40) based on the below so don't have to deal with the hassle later.  Hope this helps.

1) https://news.rla.org.uk/gdpr-do-i-really-need-to-register-with-the-ico/

2) https://www.propertyinvestmentproject.co.uk/blog/landlords-comply-gdpr/

3) https://landlords.org.uk/news-campaigns/blogs/the-data-protection-fee-do-landlords-and-letting-agents-need-pay

Quoting from link (2) above / not sure how official 


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