Leasehold officer data

What data we hold

When a report covers a leasehold property, we fetch the officer list for the freeholder or managing-agent company from the public Companies House API. We retrieve officer names (as they appear on the public register) and their appointment dates.

This data is used exclusively as an internal cross-reference list — it lets us identify whether a company officer name appears in First-tier Tribunal (Property Chamber) decisions about that property. Officer names, dates of birth, nationalities, and addresses are never written to our database and never appear in any generated report, PDF, or user-facing output.

The in-memory list is discarded at the end of the report-generation request. We do not build or maintain a corpus of officer names.

Legal basis

The lawful basis for this processing is legitimate interests (UK GDPR Article 6(1)(f)). Our interest is providing accurate leasehold due diligence to property buyers by cross-referencing publicly available tribunal records. We have balanced this against the interests of the individuals named and concluded that the impact is negligible because:

• The source data is already public (Companies House is a statutory public register under the Companies Act 2006).
• We hold the data in memory only — it is never persisted to any database or storage layer.
• The data is never rendered in any output seen by a report purchaser.

A copy of our legitimate interests assessment is available on request.

Your rights

If you are a Companies House officer and wish to exercise a right under UK GDPR — access, erasure, restriction, or objection — you can do so by writing to privacy@eavesdrop.app. Please include:

• Your full name as it appears on the Companies House register.
• The company number or company name.
• The right you wish to exercise and the reason, if relevant.

We will respond within one calendar month. Because the officer list is held in memory only and not persisted, an erasure request will be acknowledged with confirmation that no record exists to delete after any ongoing report generation has completed.

If you are not satisfied with our response, you may complain to the Information Commissioner’s Office at ico.org.uk/make-a-complaint.

Contact

Data controller: Not Another Brand Limited (Companies House 17074425), trading as Eavesdrop. Privacy queries: privacy@eavesdrop.app.