Social housing associations: destroying tenant files and archives
A social housing association processes personal data of thousands to tens of thousands of tenants. Income statements, copies of identity documents, housing-urgency evidence, complaints, payment arrangements, eviction files. The sector operates under the Housing Act, Aw supervision (Authority for Social Housing Associations) and the GDPR. This article describes the retention periods and the practical clear-out route.
Which data is held?
- Housing application files: name and address, income data, BSN, housing-urgency evidence.
- Tenancy agreements and amendments: the full contractual history.
- Income-test documents: testing against allocation requirements, annual recalibration.
- Repair notifications and maintenance: customer correspondence, photos.
- Payment arrangements and debt collection: arrears correspondence, bailiff documents.
- Eviction files: court rulings, execution documents.
- Complaints and disputes: via complaints committee or management.
- Camera footage: entrance halls, car parks.
Retention periods per category
| Category | Period |
|---|---|
| Tenancy agreement and amendments | 7 years after end of agreement (tax plus civil law) |
| Income statements for testing | 2 years after testing (GDPR proportionality) |
| Copy of identity document | Maximum the duration of the tenancy (GDPR); render BSN unreadable if there is no Wbsn ground |
| Repair and maintenance notifications | 2 to 5 years depending on building-law relevance |
| Payment arrangements | 7 years after last payment |
| Debt collection and bailiff files | 5 years after last action, 7 years on judgment |
| Eviction files | 10 years (legal) plus possibly longer on claim |
| Complaint files | 5 years after handling |
| Camera footage | 4 weeks (read camera footage retention period) |
Specific attention: BSN and copy of ID
Social housing associations long had a habit of making a copy of ID at every new tenancy "just in case". The Dutch Data Protection Authority has repeatedly pointed out: for regular tenancy there is no Wwft or employer basis, so no copy of ID. Identification by sight of passport is allowed, with a note "ID seen on date".
For the broader context, read BSN in old administration.
Almost all social housing associations have a legacy archive full of ID copies that were never anonymised. A clear-out here is not a luxury, it is GDPR maintenance.
The clear-out process
Phase 1: inventory
- Number of cabinets per location.
- Sub-division per file type.
- Presence of BSN-holding documents.
- Digital storage (CRM, financial system).
Phase 2: test per category
- Which period has expired?
- Which files relate to ongoing disputes (not to be destroyed)?
- Which files have archival value for heritage (separate)?
Phase 3: destroy
- DIN P-5 standard.
- P-6 for files holding BSN.
- Mobile destruction on site for a short chain.
- Certificate per job.
Hardware and digital streams
- Old backup tapes with financial archives; read clearing out backup tapes and LTO.
- HDDs from old servers; read shredding HDDs.
- Access badges of departed staff.
- NVR systems at replacement.
Special: files of deceased tenants
When a tenant dies, the question arises what to do with the file. In practice:
- Tenancy ends; financial settlement with heirs.
- Keep the file for 7 years for possible claims or tax authority.
- Remove BSN-holding documents earlier (no active ground left).
Aw supervision and visitation
Social housing associations are visited periodically by the Authority for Social Housing Associations. Good archive administration and a demonstrable destruction policy are part of the governance criteria. Specific focus:
- Up-to-date record of processing.
- Destruction certificates of the last 5 years available.
- Processor agreements with suppliers.
- Up-to-date data breach register.
Mobile destruction on site for social housing associations.
We serve associations in Noord-Holland with a mobile truck. Destruction at DIN P-5 or P-6 for files holding BSN, with a certificate that fits the Aw visitation file.
Request a quoteIs your association working on a major clear-out? Email us via desnipperaar.nl with an estimate of volume and schedule.