Government and Public Authority Requests

Smart Property Software Ltd (company number 17126256) operates SmartTenant, the WhatsApp Tech Provider integration, and related SaaS services. This policy sets out how we handle requests for personal data from public authorities under UK GDPR, the UK Data Protection Act 2018, and equivalent regimes.

Scope

This policy covers all requests for personal data, personal information, or Platform Data received from any public authority (UK or overseas), including law enforcement, intelligence services, regulators, tax authorities, and any court or tribunal. It applies whether the request relates to a SmartTenant customer (landlord, agent, staff, tenant, applicant, contractor) or a person whose data we hold on behalf of a customer through an integrated platform such as Meta WhatsApp Business.

Required review of legality

Every request is reviewed by a designated officer of Smart Property Software Ltd before any data is disclosed. The reviewer confirms that the request is lawful under the regime cited, that the requesting authority has jurisdiction over Smart Property Software Ltd or the data subject, and that the legal basis for disclosure (statutory power, warrant, court order, or section of the Data Protection Act 2018) is correctly identified. Requests that do not meet these tests are not actioned.

Provisions for challenging unlawful requests

Where the reviewer considers that a request is unlawful, exceeds the requesting authority’s powers, lacks a valid legal basis, or breaches a fundamental right of the data subject, Smart Property Software Ltd will instruct external legal counsel and challenge the request before complying. Challenges include refusing to action the request pending a court determination, seeking judicial review where appropriate, and notifying the customer or data subject where this is lawful and does not prejudice an ongoing investigation.

Data minimisation

Where a request is determined to be lawful, Smart Property Software Ltd discloses only the minimum information that is strictly necessary to satisfy the lawful scope of the request, in accordance with Article 5(1)(c) of UK GDPR. Bulk responses, speculative disclosure, and disclosure of data not specifically requested are not permitted. The reviewer documents the data fields disclosed and the reasoning that limited the response.

Documentation of requests

Every request is logged in the Smart Property Software Ltd Government Requests Log. Each entry records the date received, the requesting authority, the cited legal basis, the data subjects affected, the data fields disclosed (if any), the reviewer’s legality determination, the actors involved in the decision, and the date of response. The log is retained for the longer of seven years or any period required by applicable law. The log is made available to data protection regulators on request.

Transparency

Smart Property Software Ltd intends to publish an annual transparency report summarising the number of public authority requests received, the number actioned, the number challenged, and the categories of data disclosed. No personally identifying information about data subjects or about individual requests is included in the public report. The first report will cover the calendar year 2026.

Contact

Public authority requests should be addressed in writing to Smart Property Software Ltd, marked for the attention of the Data Protection Officer, at the registered office or by email to [email protected]. We do not action requests received by telephone or social media.

Effective from

This policy is effective from May 30, 2026 and supersedes any prior practice. We may update this policy from time to time; the version on this page is authoritative.