Why Does the Management Collect Tenant Details?
Knowing who occupies each unit is a legal necessity for the management. Notices convening the general assembly and the operating budget must also be served on those making continuous use of a unit. Without knowing who lives there, these notifications cannot be properly served.
In addition, under Article 22 of the Condominium Law a tenant is liable for common expenses together with the owner, up to the amount of rent they owe. Identifying the tenant and their contact details is necessary for that liability to be applied.
What Information May Be Requested?
- Necessary: full name, unit number, telephone, move-in date, owner's details
- Where justified by purpose: vehicle registration (if parking is allocated), emergency contact, number of occupants
- Should not be requested: income details, occupation details, health data, copies of identity documents where there is no legal basis
Proportionality governs the collection of personal data: only information necessary for the purpose should be requested. Collecting unnecessary data increases the controller's exposure.
Data Protection Duties
Resident records are personal data. The data controller is the general assembly, with the management carrying out the operations. The core duties are:
- Providing the privacy notice when information is collected
- Using the data only for the stated purposes
- Keeping records in a locked cabinet or a digital environment with restricted access
- Not publishing resident lists in messaging groups or on the noticeboard
- Deleting data within a reasonable period after the resident moves out
Copyable Tenant Information Form Sample
……………………… APARTMENT / COMPLEX
RESIDENT INFORMATION FORM
Date of form: …/…/20…
UNIT DETAILS
Block / Unit No: ………………
Occupancy: Owner / Tenant / Other: ………………
Move-in date: …/…/20…RESIDENT DETAILS
Full Name: ………………………
Telephone: ………………………
E-mail: ………………………
Number of occupants: ………OWNER DETAILS (complete if tenant)
Full Name: ………………………
Telephone: ………………………VEHICLE DETAILS (if parking is allocated)
Registration: ……………… Make/Model: ………………EMERGENCY CONTACT
Full Name: ……………… Telephone: ………………
Relationship: ………………DECLARATION
I declare that the above information is correct, that I will inform the management of any change, and that I have read the attached privacy notice.Full Name: ……………………… Signature: ……………… Date: …/…/20…
Copyable Privacy Notice Sample
……………………… APARTMENT / COMPLEX
RESIDENT RECORDS PRIVACY NOTICE
Data Controller: ……………………… Apartment/Complex General Assembly, represented by Manager ……………… (Full Name)
1. Data processed: Full name, unit number, contact details, move-in date, occupancy type (owner/tenant), and where applicable vehicle registration and emergency contact details.
2. Purposes:
– Assessing and collecting common expenses (dues)
– Proper service of assembly notices, the operating budget and other statutory notifications
– Safe use of common areas and contact in emergencies
– Administering parking allocation and similar arrangements3. Legal basis: Compliance with obligations arising from the Condominium Law and the controller's legitimate interest.
4. Transfers: Your data is not shared with third parties. It is transferred only to competent judicial and administrative authorities on request. Resident lists are not posted on noticeboards or shared in messaging groups.
5. Retention: After you leave the unit, your records are deleted or anonymised at the end of the period necessary in view of possible legal disputes.
6. Your rights: You may apply to us in writing to learn whether your data is processed, request information, ask for correction or deletion, and exercise your other statutory rights.
Address for applications: ………………………
Contact: ……………………………………………… Apartment/Complex Management — …/…/20…
Filling Guide
Keep only the fields you will actually use. Fields that are never completed or used amount to unnecessary data collection.
Attach the privacy notice to the form and include a line in which the resident confirms having read it.
Do not collect copies of identity documents. Where identity must be verified, viewing the document and returning it is far safer than keeping a copy.
Storing the Records
Paper forms should be kept in a locked cabinet and digital records in an environment with restricted access. Only the manager and, where applicable, the auditor should have access.
On a change of management these records pass to the new management under the handover record; the former manager should keep no copies.
Common Mistakes
- Posting the resident list: an unlawful disclosure of personal data.
- Sharing phone numbers in groups: contact details cannot be shared without consent.
- Collecting identity copies: contrary to the principle of proportionality.
- Collecting data without a privacy notice: a clear breach of duty.
- Keeping a former resident's data indefinitely: a retention period must be set.
This content and these templates are for information only and are examples. Adapt them to your situation; seek expert advice if in doubt about personal data processes.
Download as PDF and Word
You can download the petition text above in two different formats. The PDF version is ready to print and submit directly; the Word (DOCX) version can be opened with Microsoft Word or LibreOffice and edited to add your own details.
Download the petition above as PDF or Word and adapt it to your situation.
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Frequently Asked Questions
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The content is prepared by the Apt Yönet team, drawing on 8 years of hands-on experience in apartment and residential-complex management, in line with current legislation and Court of Cassation rulings.