Smuts & Taylor Ltd Privacy Policy
Last updated: 20 May 2026
Smuts and Taylor Ltd respects your privacy and is committed to protecting your personal information.
This Privacy Policy explains what personal information we collect, how we use it, who we share it with, how long we keep it, and what rights you have.
This policy applies to our residential property services, including lettings, property management, landlord services, tenant administration, property search and acquisition support, sales support, investment property services, portfolio management, property consultancy, contractor, supplier, website and general business activities in England.
1. Who we are
Smuts and Taylor Ltd is a private client property business providing residential property services in England. Our services include lettings, property management, landlord support, tenant administration, property search and acquisition support, sales support, investment property services, portfolio management, property consultancy and related property services.
We act for a range of clients, including private landlords, property owners, investors, tenants, prospective tenants, purchasers, occupiers and other private clients.
We do not provide regulated financial, mortgage, tax, legal or investment advice unless this is expressly agreed in writing and provided by an appropriately authorised professional. Where specialist advice is required, clients should obtain advice from a suitably qualified adviser.
For data protection purposes, we are usually the "data controller" of the personal information described in this Privacy Policy. This means we decide how and why personal information is used.
In some cases, a landlord, property owner, professional adviser, referencing provider, deposit protection scheme, redress scheme or other organisation may also be a separate data controller. Where we process personal information on behalf of another controller, we will do so in accordance with appropriate instructions and contractual safeguards.
Company details
Smuts and Taylor Ltd
Company number: 06538652
ICO registration number: Z3330711
Registered office
Ground Floor Marlborough House
298 Regents Park Road
London
N3 2SZ
United Kingdom
Trading and correspondence address
5 St John's Lane
London
EC1M 4BH
Data protection contact
Smuts and Taylor Ltd
Email: info@smutsandtaylor.com
Website: www.smutsandtaylor.com
2. Who this policy applies to
This policy applies to personal information we collect and use about:
prospective tenants and applicants; tenants and former tenants; permitted occupiers and other adult occupiers; guarantors and proposed guarantors; landlords and prospective landlords; property owners; sellers; buyers; prospective buyers; investors; private clients; contractors; suppliers; tradespeople; service providers; emergency contacts; next of kin; complainants; witnesses; neighbours; and other people involved in property-related matters.
It also applies to website users and people who contact us by email, telephone, portal, messaging app, social media, post or in person.
3. Personal information we collect
The personal information we collect depends on your relationship with us and the services involved.
Identity and contact information
This may include your name, title, date of birth, address, previous addresses, email address, telephone number, signature, photographic identification, proof of address and customer reference details.
Application and referencing information
This may include employment status, employer details, income, affordability information, bank details, credit reference information, previous landlord references, employer references, guarantor information, proposed household details and information needed to assess whether you are suitable for a tenancy.
Right to rent information
Where required by law, we may collect information needed to check whether adult occupiers have the right to rent in England. This may include passport or other identity document details, share codes, Home Office online check results, immigration status evidence and records of the date checks were completed.
Tenancy and property management information
This may include tenancy agreements, written statements of tenancy terms, statutory notices, Renters' Rights Act information, rent records, arrears records, deposit information, inventory and check-out reports, inspection notes, maintenance records, contractor reports, photographs, videos, safety certificates, access arrangements, keys, complaints, disputes and general correspondence.
Landlord, owner and client information
This may include property ownership information, proof of identity, proof of address, bank details, tax-related information, property details, mortgage or leasehold information where relevant, management instructions, service preferences, landlord statements, client account information, compliance records and communications.
Buyer, seller and property search information
Where we assist with property search, acquisition, sales support, consultancy or investment property services, we may collect information about your property requirements, budget, source of funds information, identity verification, transaction details, viewing history, offers, negotiations, professional advisers and communications.
Financial information
This may include rent payments, deposit payments, holding deposits, permitted payments, invoices, landlord statements, client money records, bank account details, payment references, arrears information and debt recovery records.
Special category information
We may occasionally process more sensitive personal information, such as health, disability or vulnerability information. We will only do this where necessary and lawful, for example to make reasonable adjustments, manage a tenancy or property safely, respond to an emergency, deal with safeguarding concerns, resolve a complaint, or handle legal claims.
Criminal offence, fraud, sanctions or compliance information
We do not routinely request criminal conviction information. We may process criminal offence, fraud, sanctions or allegation-related information only where necessary and legally permitted, for example for fraud prevention, safeguarding, anti-money laundering checks where applicable, regulatory compliance, legal claims, or where a lawful third-party referencing or screening provider supplies relevant information.
Communications and records
We may keep records of emails, letters, telephone notes, portal messages, SMS/WhatsApp messages, social media messages, maintenance communications, complaint records and meeting notes.
We do not record telephone calls. Staff may keep written notes of calls where this is necessary for enquiries, applications, tenancy administration, property management, maintenance, complaints, arrears, disputes, legal compliance, client service or audit purposes.
Website and cookie information
When you use our website, we may collect technical information such as IP address, browser type, device information, website usage information, cookie identifiers, preferences and analytics data, depending on your cookie settings.
4. How we collect personal information
We may collect personal information directly from you when you enquire about a property or service, arrange or attend a viewing, apply for a tenancy, instruct us, complete an application or declaration form, enter into a tenancy, guarantee, management or client arrangement, request maintenance or repairs, make or receive payments, contact us, use our website, make a complaint or raise a dispute.
We may also receive personal information from landlords, tenants, occupiers, guarantors, property owners, buyers, sellers, investors, private clients, employers, previous landlords, referees, referencing agencies, credit reference agencies, Home Office right to rent services, contractors, inventory clerks, surveyors, cleaners, managing agents, building managers, utility providers, local authorities, tenancy deposit schemes, client money protection schemes, professional bodies, redress schemes, insurers, legal advisers, accountants, banks, payment providers, public registers, government bodies and regulators.
5. Why we use personal information and our lawful bases
We only use personal information where we have a lawful basis under data protection law.
| Purpose | Examples | Lawful basis usually relied on |
|---|---|---|
| Responding to enquiries | Contacting prospective landlords, tenants, buyers, sellers, investors, applicants, contractors or clients | Legitimate interests; steps before a contract |
| Arranging viewings and appointments | Booking appointments, confirming attendance, following up interest | Legitimate interests; steps before a contract |
| Tenancy applications and referencing | Assessing identity, affordability, references and suitability | Steps before a contract; legitimate interests; legal obligation where applicable |
| Right to rent checks | Checking adult occupiers' right to rent in England and keeping required evidence | Legal obligation; legitimate interests |
| Preparing tenancy documents | Tenancy agreements, written statements of terms, guarantor documents and prescribed documents | Contract; legal obligation; legitimate interests |
| Managing tenancies | Rent collection, inspections, maintenance, notices, renewals, variations, assignments and communications | Contract; legitimate interests; legal obligation |
| Property management | Repairs, contractor access, safety checks, inspections, landlord reporting and property records | Contract; legitimate interests; legal obligation |
| Landlord and client services | Managing instructions, reporting, statements, compliance, service delivery and communications | Contract; legitimate interests; legal obligation |
| Property search and acquisition support | Understanding requirements, arranging viewings, liaising with sellers/agents/advisers, offer support and transaction administration | Contract; legitimate interests; legal obligation where applicable |
| Sales support and consultancy | Property advice, introductions, negotiations, communications and transaction support | Contract; legitimate interests; legal obligation where applicable |
| Deposits and client money | Protecting deposits, dealing with deposit disputes, operating client accounts and producing statements | Contract; legal obligation; legitimate interests |
| Rent arrears and debt recovery | Arrears management, payment plans, legal action and enforcement | Contract; legitimate interests; legal claims |
| Safety and compliance | Gas safety, electrical safety, fire safety, building safety, right to rent, housing obligations and related compliance | Legal obligation; legitimate interests |
| Complaints and disputes | Handling complaints, deposit disputes, disrepair claims, tribunal/court matters and insurance claims | Legitimate interests; legal obligation; legal claims |
| Professional and regulatory compliance | Responding to regulators, redress schemes, professional bodies, auditors and legal advisers | Legal obligation; legitimate interests |
| Marketing | Sending relevant service updates, market updates and business communications | Consent where required; legitimate interests where permitted; PECR compliance |
| Website operation and analytics | Running the website, essential cookies, security, analytics and improving user experience | Legitimate interests; consent for non-essential cookies where required |
| Protecting our business | Audit trails, fraud prevention, IT security, insurance, legal advice and record keeping | Legitimate interests; legal obligation |
We do not rely on consent for core tenancy, property management, legal, compliance or contractual processing where another lawful basis is more appropriate.
Where we do rely on consent, you may withdraw it at any time. This will not affect processing already carried out lawfully before consent was withdrawn.
6. Legitimate interests
Where we rely on legitimate interests, we will only do so where we have considered your rights and interests and concluded that our use of the information is necessary and proportionate.
Our legitimate interests include operating a private client property business; providing residential property services; acting for landlords, property owners, tenants, buyers, sellers, investors and private clients; assessing applications; reducing the risk of fraud, arrears and disputes; protecting landlords' and clients' properties and financial interests; managing repairs, inspections, safety and compliance; keeping proper records and audit trails; dealing with complaints, disputes, legal claims and insurance matters; recovering unpaid sums where legally recoverable; improving our services and website; and protecting our systems, business and staff.
7. If you do not provide personal information
Some personal information is needed so that we can provide services, consider applications, manage tenancies, manage property, comply with legal obligations or protect legal rights.
If you do not provide information we reasonably need, we may not be able to respond to your enquiry, arrange a viewing, consider your application, complete referencing, carry out right to rent checks, prepare or complete documents, manage a tenancy or property, arrange maintenance or repairs, process payments, provide client services, comply with legal obligations, or deal with complaints, disputes or legal claims.
8. Tenant Fees Act and permitted payments
This Privacy Policy does not create any payment obligation.
We will only process payment information in connection with rent, deposits, holding deposits and other payments where they are permitted by law or otherwise legally recoverable.
We will not use this policy to require a tenant, guarantor or person acting on their behalf to make a prohibited payment or enter into a paid third-party service where this would breach the Tenant Fees Act 2019 or other applicable law.
9. Right to rent checks
Where right to rent checks are required, we will process the personal information needed to carry out and evidence those checks.
This may include checking original documents, using share codes, using the Home Office online right to rent service, contacting the Home Office Landlord Checking Service where applicable, and keeping records of the check.
Right to rent information may reveal nationality, immigration status or other sensitive information. We will use this information only where necessary for lawful lettings compliance, fraud prevention, legal claims or related purposes.
We will not use right to rent information to unlawfully discriminate. Applicants and occupiers will be given a reasonable opportunity to prove their right to rent using an accepted method.
We will keep right to rent evidence securely for the duration of the tenancy and for at least one year after the tenancy ends. Online right to rent check responses must then be securely destroyed unless another lawful reason requires retention.
10. Children and other occupiers
We may collect limited information about children or other occupiers where this is necessary to understand who will live at a property, assess occupancy, manage safeguarding or emergency issues, administer a tenancy, or comply with legal obligations.
We do not carry out right to rent checks on children under 18.
We will not use information about children, pregnancy, family status, benefits status or disability to unlawfully discriminate against applicants, tenants, occupiers or households.
11. Special category information
Special category information includes information about health, disability, racial or ethnic origin, religious beliefs, trade union membership, sex life, sexual orientation, biometric data and genetic data.
We will only process special category information where we have a lawful basis under UK GDPR and a separate special category condition.
This may include processing information where necessary to make reasonable adjustments, manage health, disability or vulnerability issues affecting a tenancy or property, respond to emergencies, protect vital interests, deal with safeguarding concerns, establish, exercise or defend legal claims, or comply with legal obligations.
We will keep the amount of special category information we collect to the minimum necessary.
12. Criminal offence information
We will only process criminal offence information where necessary, proportionate and legally permitted.
This may include information connected with fraud prevention, sanctions checks, anti-social behaviour, property damage, safeguarding, complaints, disputes, legal claims, enforcement action or information lawfully provided by a third-party referencing or screening provider.
13. Automated decision-making and tenant referencing
We may use third-party referencing providers, credit reference agencies or screening providers. These providers may use automated tools, credit scoring, affordability checks or profiling as part of their services.
We do not make final tenancy decisions solely by automated means where the decision would have a legal or similarly significant effect. A person will review relevant information before a final decision is made.
Applicants may contact us if they want to understand, challenge or ask us to review a decision.
14. Anti-money laundering, fraud and sanctions checks
Depending on the service, transaction or client relationship involved, we may need to carry out identity, fraud, sanctions, source of funds, source of wealth or other compliance checks.
This is more likely to apply where we are involved in property sales, property acquisition support, investment property services, high-value transactions, client money handling, or where a legal or professional obligation requires checks.
We may ask for documents and information and may share relevant information with professional advisers, compliance providers, banks, law enforcement agencies, regulators or other bodies where necessary and lawful.
15. Who we share personal information with
Where necessary and lawful, we may share personal information with landlords, joint landlords, superior landlords and their authorised representatives; property owners; buyers; sellers; tenants; occupiers; guarantors; tenant referencing agencies; credit reference agencies; Home Office right to rent services; government bodies; tenancy deposit protection schemes; deposit dispute resolution services; maintenance contractors; inventory clerks; cleaners; surveyors; safety engineers; other property professionals; building owners; freeholders; head landlords; block managers; managing agents; concierge teams; serviced office providers; utility companies; local authorities; council tax departments; banks; payment providers; accountants; insurers; loss adjusters; mortgage lenders; legal advisers; debt recovery agents; courts; tribunals; enforcement agents; redress schemes; professional bodies; regulators; law enforcement agencies; CRM providers; email providers; cloud storage providers; e-signature providers; accounting providers; property management systems; referencing systems; website providers; analytics providers; IT providers; security providers; and prospective buyers or transferees of our business or assets, subject to confidentiality safeguards.
We will only share personal information where there is a proper reason to do so and will limit sharing to what is necessary.
16. Professional memberships, schemes and regulatory bodies
We are members of, registered with, or use the following professional bodies and statutory/property schemes where relevant to our work:
Property Redress Scheme: PRS003577
Client Money Protect: CMP004917
Deposit Protection Service: 1446500
AIPP: 20382
We may share personal information with these bodies or schemes where necessary for client money protection, tenancy deposit protection, complaints, dispute resolution, professional compliance, audit, legal obligations or legitimate business purposes.
17. Landlords, property owners, tenants and clients
Where we act for a landlord or property owner, we may share relevant tenant, occupier, guarantor, arrears, maintenance, inspection, deposit, complaint, dispute and legal information with that landlord or property owner.
Where we act for a tenant, buyer, seller, investor or private client, we may share relevant information with the other parties involved in the matter and their professional advisers where necessary to provide the service, progress a transaction, manage a property, comply with legal obligations, protect legal rights, or deal with complaints or disputes.
Where appropriate, we may share information between tenants, occupiers, landlords, property owners, contractors and other parties where this is necessary to manage the tenancy, arrange repairs, comply with legal obligations, protect the property, deal with complaints, resolve disputes or exercise legal rights.
We will not share more information than is reasonably necessary.
18. Contractors and property access
Where repairs, inspections, safety checks, cleaning, inventories, check-ins, check-outs, viewings, surveys or other works are required, we may share relevant contact details, property details, access arrangements and issue details with contractors or service providers.
Contractors must only use personal information for the purpose for which it is provided and must protect it appropriately.
19. CCTV and building security
We do not operate CCTV at our trading office.
Our trading office is located within a serviced office/building where the building owner, landlord, managing agent or serviced office provider may operate CCTV or other building security systems. Those systems are not operated by us and are outside our control.
If we receive or are given access to building CCTV footage in connection with a security incident, complaint, legal claim, safeguarding concern or property management issue, we will handle any personal information in that footage lawfully, securely and only for the relevant purpose.
Where we manage or visit properties, CCTV or other building security systems may also be operated by landlords, freeholders, block managers, managing agents, concierge providers or other third parties. Those systems are not normally operated by us unless we expressly state otherwise.
20. International transfers
We aim to keep personal information within the UK where reasonably practical.
Some of our software, cloud, email, CRM, e-signature, website, analytics or other service providers may process personal information outside the UK.
Where personal information is transferred outside the UK, we will ensure appropriate safeguards are in place. These may include adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or another lawful transfer mechanism.
21. How long we keep personal information
We keep personal information only for as long as necessary for the purpose for which it was collected, including to comply with legal, accounting, tax, tenancy, property management, regulatory, complaint, insurance and legal claim requirements.
As a general guide:
| Record type | Usual retention approach |
|---|---|
| General enquiries and viewing records that do not proceed | Usually up to 12 months after last meaningful contact |
| Unsuccessful tenancy applications | Usually up to 12 months after the application decision, unless there is a complaint, fraud concern, dispute or legal reason to keep the information for longer |
| Successful tenancy applications, tenancy agreements, rent records, deposit records, notices, inspection records, maintenance records, correspondence and property management files | Usually up to 6 years after the tenancy, management relationship or relevant transaction ends |
| Landlord, property owner, buyer, seller, investor and private client records | Usually up to 6 years after the client relationship, instruction, transaction or relevant matter ends |
| Right to rent check evidence | For the duration of the tenancy and for at least 1 year after the tenancy ends, then securely destroyed unless another lawful reason requires retention |
| Client money, accounting, landlord statements, invoices and tax-related records | Usually 6 years plus the current accounting year |
| Complaints, disputes, arrears, deposit disputes, tribunal/court matters and legal claims | For the duration of the matter and then for as long as reasonably necessary to protect our legal position |
| Marketing records | Until you unsubscribe or object, after which we may keep a suppression record so that we do not contact you again |
| Supplier and contractor records | Usually up to 6 years after the relationship or relevant transaction ends |
| Website analytics and cookie data | In accordance with our cookie settings, analytics settings and applicable law |
These periods may be extended where necessary for legal claims, regulatory investigations, fraud prevention, safeguarding, audit, professional advice or other lawful reasons.
22. Security
We use appropriate technical and organisational measures to protect personal information.
These may include access controls, password protection, multi-factor authentication, secure systems, encryption where appropriate, staff training, confidentiality obligations, supplier checks, secure disposal, backup procedures and contractual controls with service providers.
We limit access to personal information to people who need it for legitimate business, property management, compliance or legal purposes.
No system is completely secure, but we take reasonable steps to reduce the risk of accidental loss, unauthorised access, misuse, alteration or disclosure.
23. Email and business communications monitoring
We may monitor email and other business communications where this is necessary for security, compliance, audit, training, service quality, business continuity, legal claims, fraud prevention or protecting our systems.
We will do this only where lawful, necessary and proportionate.
24. Marketing
We may send service messages that are necessary for enquiries, applications, tenancy administration, property management, client services, legal compliance, complaints or our contractual relationship.
We may also send marketing communications about our services, market updates or relevant property-related information where allowed by law.
For individuals, we will only send electronic marketing where we have consent or where we can rely on the soft opt-in under the Privacy and Electronic Communications Regulations.
You can opt out of marketing at any time by following the unsubscribe instructions in the message or contacting us at info@smutsandtaylor.com.
We do not sell personal information to third parties for marketing.
25. Cookies and website tracking
Our website uses cookies and similar technologies.
Necessary cookies are required for the website to work properly. These may be set without consent where they are strictly necessary.
We may also use non-essential cookies, such as analytics or third-party cookies, to understand how visitors use our website and to improve our services. We will only set non-essential cookies where we have obtained the consent required by law.
You can accept, reject or manage non-essential cookies using the cookie settings on our website. You can also change your browser settings to block or delete cookies, although this may affect how the website works.
Our website should provide clear cookie information and allow users to make a genuine choice before non-essential cookies are set.
26. Links to other websites
Our website may contain links to third-party websites.
We are not responsible for the privacy practices, content or security of third-party websites. You should read the privacy policy and cookie information on any third-party website you visit.
27. Your rights
You may have the right to ask for access to your personal information; ask us to correct inaccurate or incomplete information; ask us to erase personal information in certain circumstances; ask us to restrict processing in certain circumstances; object to processing based on legitimate interests; object to direct marketing at any time; ask for a copy of certain information in a portable format; withdraw consent where we rely on consent; and challenge certain automated decisions.
These rights are not absolute. For example, we may need to keep or use certain information to comply with legal obligations, manage a tenancy, provide services, protect legal rights, deal with claims, prevent fraud or maintain proper business records.
To exercise your rights, please contact us at info@smutsandtaylor.com.
We may need to confirm your identity before responding. We will respond within the time required by data protection law.
28. Data protection complaints
Please contact us first if you are concerned about how we use your personal information.
You can contact us at:
Smuts and Taylor Ltd
5 St John's Lane
London
EC1M 4BH
Email: info@smutsandtaylor.com
We will consider your complaint carefully and respond as soon as reasonably practical.
You also have the right to complain to the Information Commissioner's Office:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Website: ico.org.uk
Telephone: 0303 123 1113
29. Property complaints and redress
Data protection complaints are separate from property, lettings, management or service complaints.
Where a complaint relates to our property services, you may also have rights under our complaints procedure and through the Property Redress Scheme.
Property Redress Scheme membership number: PRS003577
30. Changes to this Privacy Policy
We may update this Privacy Policy from time to time, including where there are changes in law, guidance, our services, our systems or the way we process personal information.
The latest version will be available on our website.
Where we make significant changes, we may take additional steps to bring those changes to your attention.
