The short version
Effective 1st September 2026 · Version 1.1
We're Harther Ltd, and we make Harthing, a record-keeping platform for landlords. Here's what you actually need to know about how we handle your data:
- We collect your email if you sign up for early access or complete our survey. We'll use it for exactly what we said we would, then delete it.
- If you use Harthing, we store the property and tenancy data you give us. That's the whole point of the product.
- If you connect a bank account, we import your transactions so you don't have to type them in. We can read them. We can't move money.
- If you use Making Tax Digital, we hold your National Insurance number and the permission HMRC gives us to file on your behalf. Both are encrypted, and you can disconnect at any time.
- We use Google Analytics (with IP anonymisation) to understand how people use our site. We use the Meta Pixel to measure whether our ads are working. You can say no to the Meta Pixel.
- We keep compliance records for six years after a tenancy ends, because that's how long you could face a legal claim. We're not hoarding data for fun.
- If you cancel, we don't delete anything. You keep read-only access for twelve months, and we email you before that ends.
- If you're a tenant and your landlord uses Harthing, your landlord decides what's held about you and is the person to ask about it. Section 3 explains your rights and how to use them.
Questions? Email us: privacy@harthing.co.uk
The full policy follows below, covering the same ground in the detail UK GDPR requires.
1. Who we are
Harther Ltd ("we", "us", "our") is registered in England and Wales.
Registered address: 124-128 City Road, London, England, EC1V 2NX
Company number: 17075829
Privacy contact: privacy@harthing.co.uk
ICO registration: ZC113403
We operate two products: Harthing (a landlord compliance and property management portal at app.harthing.co.uk) and Letterlea (a tenant portal, not yet launched). Our marketing site is at www.harthing.co.uk.
1.1 Our two roles, and why the difference matters
Harther Ltd handles two kinds of personal data, and our legal role is different for each. This is the single most important thing to understand about this policy.
- Data about a landlord, where we are the controller. This covers a landlord's own account details, National Insurance number, HMRC connection, imported bank data, and subscription records. We decide how long to keep it and how we meet our own obligations, so we are the controller and this policy governs it directly.
- Data about a tenant or other third party, where we are the processor. When a landlord enters a tenant's details, the landlord is the controller. We hold and organise that data on the landlord's instructions. The landlord decides what is collected, why, and what happens to it. Our obligations to the landlord are set out in Schedule 1 of the Terms of Use.
One thing changes over time. If a landlord's account closes, we continue to hold certain tenancy records for the periods set out in Section 6, and at that point we hold them as an independent controller rather than on the landlord's behalf. Section 6.1 explains this.
2. What data we collect and why
2.1 Marketing site (www.harthing.co.uk)
| Data | Source | Purpose | Lawful basis |
|---|---|---|---|
| Email address | Early access sign-up form (via Formspree) | To send you a single launch notification email | Consent (Article 6(1)(a)) |
| Email address | Landlord survey | Research purposes | Consent (Article 6(1)(a)) |
| IP address and device data | Google Analytics 4 (IP anonymisation enabled) | Website analytics, understanding how visitors use the site | Legitimate interests (Article 6(1)(f)) |
| Cookie preferences | Cookie consent banner | Recording your cookie choices | Legal obligation (PECR compliance) |
| Click and browsing data | Meta Pixel | Measuring ad performance | Consent (Article 6(1)(a), PECR Regulation 6) |
2.2 Harthing product (app.harthing.co.uk)
| Data | Source | Purpose | Lawful basis |
|---|---|---|---|
| Name, email, phone number | Account registration | Service delivery | Contract (Article 6(1)(b)) |
| Property addresses | Landlord input | Service delivery | Contract (Article 6(1)(b)) |
| Tenancy details and documents (including ASTs) | Landlord input and upload | Compliance record-keeping | Processed on the landlord's instructions as processor (Article 28). The landlord determines the lawful basis. |
| Compliance certificates (gas safety, EICR, EPC) | Landlord upload | Compliance record-keeping | Legal obligation (Art. 6(1)(c)) and legitimate interests (Art. 6(1)(f)) |
| Maintenance invoices | Landlord upload | Property management | Contract (Article 6(1)(b)) |
| Fault and repair records | Landlord input | Property management | Contract (Article 6(1)(b)) |
| Tenant name and contact details | Entered by landlord | Compliance record-keeping on the landlord's behalf | Processed on the landlord's instructions as processor (Article 28). The landlord determines the lawful basis. See Section 3. |
| National Insurance number | Landlord input, for Making Tax Digital | Identifying the landlord to HMRC when submitting under Making Tax Digital | Legal obligation (Art. 6(1)(c)) and contract (Art. 6(1)(b)) |
| HMRC connection credentials | Issued by HMRC when the landlord authorises the connection | Authorising the Service to submit to HMRC on the landlord's behalf | Contract (Article 6(1)(b)) |
| Figures prepared and submitted to HMRC | Derived from the landlord's records in the Service | Meeting the landlord's Making Tax Digital obligations | Legal obligation (Art. 6(1)(c)) and contract (Art. 6(1)(b)) |
| Bank account details and transaction data | Imported from the landlord's bank via open banking, with the landlord's authorisation | Bookkeeping, reconciliation, and tax reporting for the landlord's let properties | Contract (Article 6(1)(b)) |
| Open banking connection and consent records | Generated when a landlord connects or disconnects a bank account | Evidencing that a connection was authorised, and when it ended | Legal obligation (Art. 6(1)(c)) and legitimate interests (Art. 6(1)(f)) |
| Subscription and payment records | Account activity and our payment processor | Billing, accounting, and tax records | Contract (Art. 6(1)(b)) and legal obligation (Art. 6(1)(c)) |
| Record of which version of our Terms and Privacy Policy you accepted, and when | Automated system log | Demonstrating what was agreed | Legal obligation (Art. 6(1)(c)) and legitimate interests (Art. 6(1)(f)) |
| System-generated audit logs (Accountability Record) | Automated system logs | Core product function: immutable compliance record | Legal obligation (Art. 6(1)(c)) and legitimate interests (Art. 6(1)(f)) |
We do not hold your card details: payment card information is handled by our payment processor and never reaches our systems. We do not use data brokers, and we do not sell or share your personal data with third parties for their own marketing purposes.
2.3 Bank data and open banking
If you choose to connect a bank account, we import account and transaction information so that your income and expenses do not have to be entered by hand.
Who provides the connection. The connection is provided by Yapily Connect Ltd, which is authorised and regulated by the Financial Conduct Authority as an account information service provider. Harther Ltd is not itself authorised by the FCA. You authorise the connection with your own bank, and the consent wording shown to you at that point governs what you are agreeing to.
What we can and cannot do. The connection is read-only. We can see account details and transactions. We cannot make payments, transfers, or any other instruction on your account.
What we use it for. Bookkeeping, reconciliation, and tax reporting in respect of your own let properties, and nothing else. Bank data is not used for profiling, marketing, credit assessment, or resale.
Withdrawing your consent. You can disconnect at any time from within the Service. Disconnecting withdraws the consent with the provider, destroys the access we hold, and stops any further data being imported. It happens immediately and does not require a request to us.
Data already imported. Disconnecting stops future imports. It does not remove transactions already imported, because those form part of your financial records and your Accountability Record. If you want imported data removed as well, contact us and we will handle it as an erasure request under Section 5.
2.4 HMRC and Making Tax Digital
If you choose to use Making Tax Digital through Harthing, we hold your National Insurance number and the credentials HMRC issues when you authorise the connection. Both are encrypted using a separate key for each record, and access is restricted.
Your National Insurance number is not a special category of data under Article 9, but it is a durable government-issued identifier that can cause real harm if exposed, so we treat it with the same protection we apply to credentials rather than as ordinary account data.
Correcting a submission. While your connection is active, you can correct figures for the current period and submit again. Whether an older period can still be amended is governed by HMRC's own time limits rather than by us.
Disconnecting. You can disconnect at any time. When you do, we delete the credentials we hold, and we can no longer submit anything on your behalf, including a correction. To be precise about what that does and does not do: we delete our own access. We do not cancel, revoke, or alter anything held by HMRC. Anything recorded on HMRC's own systems has to be dealt with directly with HMRC.
HMRC as a recipient. When you submit, information about you goes to HMRC. HMRC is not our processor and does not act on our instructions. It receives the data as a public authority exercising its statutory functions, and once submitted, HMRC's own privacy terms govern what happens to it.
3. Information for tenants
If your landlord uses Harthing and has entered your details, this section is for you.
Who decides what is held about you. Your landlord does. Under UK GDPR your landlord is the data controller for your personal data, and Harther Ltd is a processor acting on your landlord's instructions. We do not decide what is collected about you, why, or what is done with it. Your landlord is also the person who is required to tell you that your data is being processed and on what basis.
Categories of data typically held: your name, contact details (email address and/or phone number), and tenancy information (property address, tenancy dates, rent and deposit details, associated compliance documents, and records of maintenance and correspondence).
Source of data: your landlord.
Purpose: maintaining a verifiable record of the tenancy so that your landlord can meet their legal obligations under housing regulations, including the Renters' Rights Act, and demonstrate that they have done so.
How to exercise your rights. Because your landlord is the controller, requests to see, correct, or object to the processing of your data should go to your landlord in the first instance. If you contact us instead, we will direct you to your landlord and, where we can identify them, let them know a request has been made. We will help your landlord respond, but we cannot decide the outcome for them.
If your landlord's account with us has closed, our role changes: we then hold retained tenancy records as an independent controller (see Section 6.1), and you can contact us directly at privacy@harthing.co.uk.
Retention: generally six years from the end of the tenancy (see Section 6).
Limits on erasure. Some entries in the Accountability Record cannot be removed even where a request would otherwise succeed. Section 5.1 explains why, and that reasoning protects tenants as much as landlords: a record that could be edited after the fact would be worth nothing to either of you.
If you are unhappy with how your data has been handled, you can complain to the ICO (see Section 11).
4. Who else handles your data
4.1 Marketing site processors. These handle data collected through www.harthing.co.uk:
- Google LLC (Google Analytics 4), website analytics. IP anonymisation is enabled. Privacy: policies.google.com/privacy
- Meta Platforms, Inc. (Meta Pixel), ad performance measurement. Activated only with your consent. Privacy: facebook.com/privacy/policy
- Formspree, Inc., early access sign-up form processing. Privacy: formspree.io/legal/privacy-policy
4.2 Product processors. Running the Harthing application requires a number of specialist providers, each engaged only to deliver the service and each bound by contract to process data solely on our instructions. They fall into the following categories:
- Cloud hosting, storage, and encryption key management
- Account authentication and sign-in security
- Transactional email and in-app notifications
- Payment and subscription processing
- Open banking connectivity
- Automated analysis of documents you upload, to extract information such as dates, names, and amounts so you do not have to type them in
- Error monitoring and service reliability
- Address lookup and validation
We keep a current list naming every provider in each category and what data it touches. You can request it at any time from privacy@harthing.co.uk. Where a landlord's tenant data is involved, we will give at least 14 days' notice before a new provider begins processing, as set out in Schedule 1 of the Terms of Use.
4.3 Recipients who are not processors. Some organisations receive data from us but do not act on our instructions:
- HM Revenue and Customs, where you use Making Tax Digital. HMRC receives your submissions as a public authority exercising its statutory functions. See Section 2.4.
- Your bank and the open banking provider, where you connect an account. See Section 2.3.
4.4 We do not use any other third-party cookies, data brokers, or advertising networks, and we do not sell your data.
5. Your rights
Under UK GDPR, you have the following rights in relation to your personal data:
- Right of access, to request a copy of the personal data we hold about you.
- Right to rectification, to request that we correct inaccurate data or complete incomplete data.
- Right to erasure, to request deletion of your data, subject to the limitations set out below.
- Right to restriction of processing, to request that we limit the way we use your data.
- Right to data portability, to receive your data in a structured, commonly used format.
- Right to object, to object to processing based on legitimate interests.
- Right to withdraw consent, where processing is based on consent (for example the Meta Pixel, early access sign-up, or a bank connection), you may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
Landlords can raise a request from within the Service, or by emailing privacy@harthing.co.uk. Tenants should see Section 3, because during a landlord's account life the landlord is the controller and the right route is through them. We will respond within one month.
5.1 Limitations on erasure, audit logs
Harthing generates system audit logs (the "Accountability Record") that create an immutable, timestamped record of actions taken within the platform. Erasure requests relating to audit log entries will generally be refused.
This is because the audit log exists to protect both landlords and tenants by maintaining an independent, verifiable record of compliance actions. Deleting entries from this record would compromise its integrity and defeat its purpose. The legal grounds for this refusal are:
- Legal obligation (Article 17(3)(b)), the record is necessary for compliance with a legal obligation requiring processing under UK law.
- Legal claims (Article 17(3)(e)), the record may be necessary for the establishment, exercise, or defence of legal claims during the limitation period.
- Legitimate interests, the record serves the legitimate interests of both the landlord (demonstrating compliance) and the tenant (holding the landlord accountable), and these interests outweigh the privacy impact of retaining the log entries.
If you believe there are exceptional circumstances warranting erasure of a specific audit log entry, please contact us at privacy@harthing.co.uk and we will consider your request on a case-by-case basis.
6. How long we keep your data
| Data | Retention period | Clock starts |
|---|---|---|
| Early access emails | 6 months post-launch, or until unsubscribed (whichever is first) | Launch date |
| Survey emails | 12 months | Collection date |
| Landlord account data | Duration of account + 6 years | Account closure |
| National Insurance number | Duration of account + 6 years | Account closure |
| HMRC connection credentials | Deleted when the connection ends | Disconnection, or the start of the read-only period |
| Records of information submitted to HMRC | 6 years | Submission date |
| Bank account and transaction data imported via open banking | 6 years | Account closure |
| Open banking access credentials | Destroyed when the connection ends | Disconnection, or the start of the read-only period |
| Open banking connection and consent records | 6 years | Account closure |
| Subscription and payment records | 6 years | End of the accounting period the transaction falls in |
| Record of Terms and Privacy Policy acceptance | 6 years | Account closure |
| Tenant personal data | 6 years | Tenancy end date |
| Tenancy documents and compliance certificates | 6 years | Tenancy end date |
| Maintenance invoices | 6 years | Invoice date |
| Fault and repair records | 6 years | Tenancy end date |
| Audit logs (Accountability Record) | 6 years | Tenancy end date |
| Google Analytics data | 14 months (rolling) | Rolling |
Six years appears throughout this table for a reason: under the Limitation Act 1980, most contractual and tortious claims in England and Wales can be brought within six years. It also covers the period HMRC can require records to be produced. Keeping records for that long is what makes them useful when they are needed.
6.1 What happens after you cancel, and the two clocks
Cancelling a subscription does not delete anything. Section 7.9 of the Terms of Use sets out the full sequence. In summary:
- To the end of the paid period, nothing changes. Full access.
- Twelve months read-only. You can sign in, view, and export everything, including your full Accountability Record. You cannot add or change anything. At the start of this period, any connected bank account and any HMRC connection are disconnected, and the access we hold for each is destroyed. We cannot restore either connection; if you return, you reconnect yourself.
- Advance warning. We email you before the read-only period ends, while you can still sign in and export.
- Account closure. Sign-in ends. Records are kept.
- Ninety-day recovery window. The account can be recovered by contacting us. This is not self-service.
- Deletion. Only after all of the above, only subject to the retention periods in the table, and never automatically. A person at Harther has to decide on it.
Two clocks, easily confused. How long you can sign in and look at your records is twelve months from the end of your paid period. How long we keep your records is set out in the table above and is generally six years. The second is much longer than the first.
Losing the ability to sign in does not mean your records have been deleted. You can still ask us for a copy, and we will provide it.
Our role after account closure. Following account closure we continue to hold tenancy-related data (tenant details, compliance documents, audit logs) for the periods in the table above, even though the landlord's account has gone. From that point we hold it as an independent data controller rather than as the landlord's processor, because there is no longer a landlord instructing us. The reasons for holding it are the Limitation Act period described above, and the fact that both former landlords and former tenants may need an independent record during it.
7. Cookies
Our marketing site uses two cookies: Google Analytics (analytics) and the Meta Pixel (advertising). For full details, please see our Cookie Policy.
8. Data security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include:
- Encryption in transit (TLS) and at rest across all storage
- An additional layer of encryption for the most sensitive items, using a separate key for each individual record. This applies to National Insurance numbers, HMRC connection credentials, and open banking access credentials. These are decrypted only momentarily, on our servers, at the point they are needed.
- Multi-factor authentication on accounts, and database-level controls that keep each landlord's data separated from every other landlord's
- Restricted administrative access, granted to named individuals only
- Hosting in the United Kingdom
- Regular security reviews and infrastructure monitoring
No system is perfectly secure, and we would rather say so than imply otherwise. If a breach affects your personal data, we will notify the ICO where required and tell you where the law requires us to.
9. International transfers
Our application and your records are hosted in the United Kingdom. Some of our providers, including those handling analytics, marketing measurement, form processing, error monitoring, and document analysis, are based in or process data in the United States or elsewhere outside the UK.
Where personal data is transferred outside the UK, we ensure that appropriate safeguards are in place, including reliance on the relevant adequacy regulations or the International Data Transfer Agreement or Addendum approved by the Information Commissioner. Details of the mechanism applying to any particular provider are available on request.
10. Changes to this policy
We may update this Privacy Policy from time to time. Where changes are significant, we will notify users by email or by a prominent notice on our website, and we may ask you to accept the updated version before continuing to use the Service. The "Last updated" date at the top of this page indicates when the policy was last revised, and we keep a record of which version you accepted and when. Previous versions are available on request.
We review this policy periodically, and in any event whenever there is a material change to how we handle personal data.
11. Complaints
If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):
Website: ico.org.uk
Telephone: 0303 123 1113
We would appreciate the opportunity to address your concerns before you contact the ICO. Please email privacy@harthing.co.uk in the first instance.