Property managers: what to mask in owners' meeting minutes and building documents

Inside the circle of owners, the full minutes are normal. Once a document leaves that circle, mask the names, flat numbers, votes and arrears the new reader does not need. Keep the signed original untouched and share a masked copy.

This guide covers England, France and Germany, as of October 2026. It is general information, not legal advice.

Who is allowed to see which building document?

England. GOV.UK says leaseholders can ask for a summary of how a service charge is worked out and see the paperwork behind it, such as receipts. Section 22 of the Landlord and Tenant Act 1985 lets them take copies. A 2024 Act will replace it once in force, so check the current text.

France. ANIL, the national housing information agency, says the minutes must name owners who opposed, abstained or were absent with no proxy. The minutes also show how many votes each of them holds. Opposing or absent owners get them by registered letter within one month. The syndic, the French manager, usually sends a copy to the others. The CNIL adds that the syndic must give the owners' council any document on running the building when it asks.

Germany. Section 24(6) of the WEG, the condominium act, says resolutions must be recorded without delay. The chair, one owner and the advisory board chair, if there is one, sign them. Under section 18(4), every owner can ask to inspect the management documents. The Rhineland-Palatinate data protection authority says this covers personal data, and owners may make copies.

When does a document leave the circle?

The circle is the owners, the manager and the owners' council, which may use the data only within its mandate, says the CNIL. Even inside it, the Rhineland-Palatinate authority wants each personal detail checked for need. Outside, the CNIL names three cases for a French syndic. Either a law requires or allows it, the people agree, or a legal or disciplinary defence needs it. Six cases call for care.

• Lobby or staircase board: tenants, visitors and delivery staff read it. In France, ANIL says the syndic must post decisions on works, occupancy or charges.
• Online space: every owner with a login can open what you upload.
• A buyer or the buyer's notary.
• A contractor who needs a quote, not the votes.
• A lawyer or bailiff chasing one debtor.
• An insurer or a court.

What hides in minutes and building files?

Start with the obvious: names, votes against, abstentions and arrears. Then look wider. ANIL says a French attendance sheet shows each owner's name, home address and share of the building. The German resolution register (Beschluss-Sammlung) names the parties in court rulings. Payslips of building staff carry a social security number and home address, and the CNIL says to mask these and the tax withholding rate.

Flat and lot numbers are indirect identifiers. The CNIL explains that people can be identified by combining data, such as an address, a birth date and an association membership. A lot number or “the second-floor owner” points to one household once anyone holds the owners list. Mask them in copies for outsiders, unless the flat is the point.

Health details need the most care. A note that a resident uses a wheelchair, or an adaptation request backed by a medical letter, reveals health data. Article 9 of the GDPR puts it in a special category with stricter rules. Write only what the decision needs: “an owner asked for a ramp”.

What should you mask for each recipient?

Sending arrears to a lawyer or bailiff? Send only the file of the owner concerned: name, flat, amount and dates. Remove the other owners' lines. Ask the lawyer which papers are needed and send only those.

How do you share a masked copy and keep the original safe?

1. Keep the signed minutes as they are. They record what the meeting decided.
2. Name the reader and the purpose: buyer, contractor, lawyer or insurer.
3. Work on a copy. Mask the names, flat numbers, votes, arrears and health details this reader does not need.
4. Use a method that removes the text. Try to select the text under each mask.
5. Label the copy with its reader and date. Note who masked what, when and why.
6. Send it through a channel you control, never the lobby board.

The ICO, the UK data protection authority, warns against black rectangles laid over live text. A reader pastes it into Notepad and sees everything. It also advises recording who redacted a document, when and why.

ONYRI Sanitize runs in your browser, so the minutes are not uploaded. It masks names, postal addresses (in England, the postcode only), emails, phone numbers, IBANs and amounts with a currency. It reads scanned minutes with OCR, and “Draw an area” covers a signature. Limit: lot numbers, floors and words describing a health condition are not detected as such. Add them with “Also mask”, or select them by hand, then check the preview.

Who should you ask when the rule depends on the case?

Rules differ by country, building and contract. Ask your data protection officer first, then the authority: the ICO in the UK, the CNIL in France, or your state authority in Germany. For a dispute about what an owner may see, ask a lawyer who knows condominium or leasehold law.

Frequently asked questions

Sources & references