Privacy Policy
1. Who We Are and How to Contact Us
Milards ("we", "us", "our") is a residential lettings agency operating in Scotland. We are registered with the Information Commissioner’s Office (ICO) as a data controller.
Company Name
Milards Ltd
Registered Address
11 Ashlands, Ford, Salisbury, England SP4 6DY
ICO Registration No.
ZA283192
Email (Data Queries)
Phone
0131 235 2391
Scottish Letting Agent Register No.
LARN 1902094
We are registered on the Scottish Letting Agent Register maintained by the Scottish Government, as required by the Housing (Scotland) Act 2014.
2. What Personal Data We Collect
2.1 Prospective and Current Tenants
Full name, date of birth, and national insurance number
Contact details: address, email address, and telephone number
Employment details, employer name, and salary information
Bank account details and payment history
Credit check and referencing data (including CCJs, bankruptcies)
Guarantor information (if applicable)
Photographic identity documents (e.g. passport, driving licence)
Right to Rent documentation – note: Scotland does not have mandatory Right to Rent checks, but we may request identity verification for anti-fraud purposes
Maintenance requests and communication records
Details of any complaints or disputes
Emergency contact details
2.2 Landlords and Property Owners
Full name and contact details
Property address(es) and title details
Bank account details for rent payments
Tax information (HMRC Non-Resident Landlord Scheme where applicable)
Copies of property compliance certificates (e.g. EPC, EICR, Gas Safety)
Insurance and mortgage details (where relevant)
2.3 Third Parties
Referees and employers (name, contact details, confirmation of employment)
Guarantors (name, address, financial information)
Contractors (name, contact details, professional credentials)
2.4 Website Visitors
IP address and browser type
Pages visited and time spent on site
Enquiry form submissions
Cookie preferences (see our separate Cookie Policy)
3. How and Why We Use Your Personal Data
We only use your personal data where we have a valid lawful basis to do so under UK GDPR. The table below sets out the main purposes for which we process personal data.
Purpose
Types of Data
Lawful Basis
Legitimate Interest (if applicable)
Tenant referencing and vetting
Identity, financial, employment
Legitimate interests / Contract
Protecting landlord property and ensuring tenancy viability
Tenancy agreement and management
Identity, contact, financial
Contract
N/A
Rent collection and arrears management
Financial, contact
Contract / Legitimate interests
Recovering monies legitimately owed
Property maintenance and inspections
Contact, tenancy details
Contract / Legitimate interests
Maintaining property condition and compliance
Legal compliance (AML, HMRC reporting)
Identity, financial
Legal obligation
N/A
Marketing our services (with consent)
Contact, preferences
Consent
N/A – consent only
Complaints and dispute resolution
All relevant data
Legitimate interests / Legal obligation
Resolving disputes fairly and lawfully
Referencing for future tenancies
Tenancy history
Legitimate interests
Providing accurate references to future landlords
Special Category Data
We do not routinely collect special category data (e.g. health, ethnicity, religion). Where such data is provided – for example, a disability-related maintenance request – we will process it only with your explicit consent or where it is necessary to protect your vital interests.
4. Who We Share Your Data With
We may share your personal data with the following categories of recipients, only to the extent necessary:
Referencing agencies (e.g. Homelet, Let Alliance, Experian, My Rental CV)
Credit reference agencies
The landlord of the property you are renting
Contractors and tradespeople engaged to carry out repairs or maintenance
Solicitors or legal representatives (in the event of a dispute)
First-tier Tribunal for Scotland (Housing and Property Chamber) if required
Rent Service Scotland / Local authorities (where legally required)
HMRC (for Non-Resident Landlord Scheme obligations)
Accountants and auditors
Our IT systems and cloud service providers (data processors under contract)
Debt collection agencies (in cases of persistent rent arrears)
We do not sell your personal data to third parties. Where we engage third-party processors, we ensure appropriate Data Processing Agreements are in place.
We do not transfer your personal data outside the UK or EEA. Where any processor is located outside the UK, we ensure an adequacy decision or appropriate safeguards (e.g. Standard Contractual Clauses) are in place.
5. How Long We Keep Your Data
We retain personal data only for as long as necessary for the purposes for which it was collected, and in accordance with legal obligations. Our standard retention periods are:
Category of Data
Retention Period
Tenancy records (active)
5 years after end of tenancy
Former tenant records
5 years after end of tenancy
Financial records (invoices, rent)
6 years
Tenant application (unsuccessful)
6 months from application
Referencing data
6 years from tenancy end
Tenancy agreement
10 years
Landlord records
5 years from end of management agreement
Correspondence about a Landlord’s or Tenant’s complaint
5 years
Marketing consent records
Until consent withdrawn + 1 year
After the applicable retention period, data will be securely deleted or anonymised.
6. Your Rights Under UK GDPR
As a data subject, you have the following rights. You may exercise any of these rights by contacting us using the details in Section 1.
Right
What This Means
Right of Access
You can request a copy of the personal data we hold about you (Subject Access Request). We will respond within one calendar month.
Right to Rectification
You can ask us to correct inaccurate or incomplete personal data.
Right to Erasure
You can ask us to delete your personal data where there is no longer a lawful reason to retain it, subject to legal obligations.
Right to Restriction
You can ask us to restrict processing of your data in certain circumstances, e.g. while accuracy is contested.
Right to Portability
Where processing is based on consent or contract and carried out by automated means, you may request your data in a structured, machine-readable format.
Right to Object
You have the right to object to processing based on legitimate interests or for direct marketing purposes.
Rights re: Automated Decisions
You have the right not to be subject to solely automated decisions that produce significant effects on you. We do not make such decisions.
Right to Withdraw Consent
Where processing is based on consent, you may withdraw it at any time. This does not affect the lawfulness of prior processing.
There is no charge for exercising your rights. We may ask you to verify your identity before processing a request. We aim to respond within one month; complex or numerous requests may take up to three months, with notice given.
7. Marketing
We will only send you marketing communications where you have given us your explicit consent to do so. You may withdraw consent at any time by:
Clicking ‘unsubscribe’ in any marketing email
Emailing us at hello@milards.com
Calling us on 0131 235 2391
We do not share your data with third parties for their own marketing purposes.
8. Automated Decision-Making and Profiling
We use third-party referencing agencies who may use automated credit scoring as part of the tenant referencing process. Where a decision significantly affects you, you have the right to request human review of any automated decision. Please contact us if you wish to exercise this right.
We do not engage in any other automated decision-making or profiling activities that produce significant legal or similarly significant effects.
9. Cookies
Our website uses cookies to improve your browsing experience and to analyse site traffic. You will be presented with a cookie consent banner when you first visit our website. You can manage your cookie preferences at any time via the cookie settings link in our website footer.
Full details of the cookies we use are set out in our separate Cookie Policy available on our website.
10. Data Security
We take the security of your personal data seriously and have implemented appropriate technical and organisational measures, including:
Encryption of data at rest and in transit (TLS/SSL)
Role-based access controls limiting who can access personal data
Regular staff training on data protection
Physical security measures at our premises
Secure disposal of physical documents
Regular review of our data protection practices
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours and, where required, inform affected individuals without undue delay.
11. Scottish Letting Agent Obligations
As a registered letting agent under the Housing (Scotland) Act 2014, we are required to comply with the Letting Agent Code of Practice (Scotland) Regulations 2016. Some data processing activities – including maintaining tenancy records and providing statements of account – are required by law and we cannot fulfil our regulatory obligations without them.
For information about the Scottish Letting Agent Register, visit: www.gov.scot/lettingagentregistration
12. Complaints
If you have a concern about how we handle your personal data, we encourage you to contact us in the first instance so we can address it:
By email: hello@milards.com
By post: Milards, 5 Wemyss Place, Edinburgh EH3 6DH
If you remain dissatisfied, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO):
ICO Website
ICO Helpline
0303 123 1113
ICO Address
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
You also have the right to raise concerns with the Scottish Information Commissioner in relation to freedom of information matters, though your primary route for data protection complaints is the ICO.
13. Changes to This Privacy Notice
We review this Privacy Notice at least annually and whenever there is a significant change to our data processing activities or applicable law. The ‘Last updated’ date at the top of this document reflects when it was last revised.
Where changes are material, we will notify you by email or by posting a prominent notice on our website. Continued use of our services after a change constitutes your acknowledgement of the updated notice.
Milards Ltd | ICO Reg No: ZA283192 | Scottish Letting Agent Reg No: LARN190294 | hello@milards.com