Decision 238/2026 | Scottish Information Commissioner

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Decision 238/2026

Decision 238/2026: Fit and Proper Person declarations under the Property Factors Act

Authority: Scottish Ministers
Case Ref: 202501809

Summary

The Applicant asked the Authority for the Fit and Proper Person Declarations (and all supporting evidence) relating to named individuals, in relation to their applications for entry onto the Property Factors Register. The Authority withheld the information on the basis that it was third party personal data, disclosure of which would breach data protection principles. The Commissioner investigated and found that the Authority was entitled to withhold the information requested.

Relevant statutory provisions

Freedom of Information (Scotland) Act 2002 (FOISA) sections 1(1), (2) and (6) (General entitlement); (2)(e)(ii) (Effect of exemptions); 38(1)(b), (2A), (5) (definitions of “the data protection principles”, “data subject”, “personal data” and “processing”, “the UK GDPR”) and (5A) (Personal information); 47(1) and (2) (Application for decision by Commissioner).

United Kingdom General Data Protection Regulation (the UK GDPR) articles 4(1) (definition of “personal data”) (Definitions); 5(1)(a) (Principles relating to the processing of personal data); 6(1)(f) (Lawfulness of processing).

Data Protection Act 2018 (the DPA 2018) sections 3(2), (3), (4)(d), (10) and (14)(a), (c) and (d) (Terms relating to the processing of personal data).

Background

On 23 June 2025 the Applicant made a three-part request for information to the Authority. In part 2 of his request, he asked the Authority to publish all the Fit and Proper Person declarations (and all supporting evidence) for named individuals, in relation to all their applications for entry onto the Property Factors Register for two specified property factors. The full text of part 2 of the Applicant’s request is set out in Appendix 1 to this Decision Notice. The Appendix forms part of this Decision Notice.
Only part 2 of the Applicant’s request (as set out in the preceding paragraph) is under consideration here. The remaining parts of the request do not form part of the Applicant’s application to the Commissioner.
The Authority responded on 21 July 2025. It refused to provide the information requested on the basis that it was third party personal data, disclosure of which would breach data protection principles.
On 1 August 2025, the Applicant wrote to the Authority requesting a review of its decision. The Applicant stated that he was dissatisfied with the decision because the Property Factors Act required these personal details to be made public and published on the public Property Factors Register. The Applicant noted that these details had been published on the Property Factors Register until September 2024 when they were removed by the Authority. He argued that, as these details were already published on the Companies House website, there was no GDPR issue regarding publication.
The Authority notified the Applicant of the outcome of its review on 1 September 2025, fully upholding its original decision. The Authority explained that it was withholding the personal data contained within registration applications under section 38(1)(b) of FOISA and that the Property Factors Register provided business contact details for each property factor. The Authority stated that it was satisfied that the Applicant had the names and business contact details for the responsible persons associated with the factors, as required by the Property Factors (Scotland) Act 2011 (the PFA).
On 8 October 2025, the Applicant wrote to the Commissioner, applying for a decision in terms of section 47(1) of FOISA. The Applicant stated that he was dissatisfied with the outcome of the Authority’s review because the PFA and the Property Factors Register privacy statement required these details to be published on the Property Factors Register. He also challenged the Authority’s statement that it had provided him with the property factors’ names and business contact details, arguing that he had obtained the names himself from the public register in 2024 and, as these were no longer included in the public register, he was now seeking the latest 2025 data.

Investigation

The Commissioner determined that the application complied with section 47(2) of FOISA and that he had the power to carry out an investigation.
On 28 October 2025, the Authority was notified in writing that the Applicant had made a valid application and the case was subsequently allocated to an investigating officer.
Section 49(3)(a) of FOISA requires the Commissioner to give public authorities an opportunity to provide comments on an application. The Authority was invited to comment on this application and to answer specific questions. These focused on its justification for withholding the information requested under section 38(1)(b) of FOISA.
The Applicant was also invited to submit any comments he wished to make on his legitimate interests in accessing the third party personal data being withheld under section 38(1)(b).
Both parties provided submissions to the Commissioner during the investigation.

Commissioner’s analysis and findings

The Commissioner has considered all of the submissions made to him by the Applicant and the Authority.

Section 38(1)(b) – Personal information

Section 38(1)(b) of FOISA, read in conjunction with section 38(2A)(a) or (b), exempts information from disclosure if it is "personal data" (as defined in section 3(2) of the DPA 2018) and its disclosure would contravene one or more of the data protection principles set out in Article 5(1) of the UK GDPR or (where relevant) in the DPA 2018.
The exemption in section 38(1)(b) of FOISA, applied on the basis set out in the preceding paragraph, is an absolute exemption. This means that it is not subject to the public interest test contained in section 2(1)(b) of FOISA.
To rely on this exemption, the Authority must show that the information withheld is personal data for the purposes of the DPA 2018 and that disclosure of the information into the public domain (which is the effect of disclosure under FOISA) would contravene one or more of the data protection principles to be found in Article 5(1) of the UK GDPR.
The Commissioner must decide whether the Authority was correct to withhold the information requested under section 38(1)(b) of FOISA.

Is the withheld information personal data?

The first question that the Commissioner must address is whether the withheld information is personal data for the purposes of section 3(2) of the DPA 2018, i.e. any information relating to an identified or identifiable living individual. "Identifiable living individual" is defined in section 3(3) of the DPA 2018. (This definition reflects the definition of personal data in Article 4(1) of the UK GDPR.)
Information which could identify individuals will only be personal data if it relates to those individuals. Information will "relate to" a person if it is about them, linked to them, has biographical significance for them, is used to inform decisions affecting them or has them as its main focus.
Along with its submissions to the Commissioner, the Authority supplied the questions contained within the Fit and Proper Person form, together with a sample of how the personal data provided in response to the questions asked in the form was held. It explained that the information withheld under section 38(1)(b) comprised names, addresses, telephone numbers, email addresses and dates of birth. As this information related directly to the identifiable individuals named in the Applicant’s request, the Authority considered it to be personal data as defined by section 3(2) of the DPA 2018.
Having considered the Authority’s submissions along with the sample personal data provided, the Commissioner is satisfied that the information being withheld as personal data “relates to” identifiable living individuals.
The Commissioner therefore concludes that the withheld information is personal data for the purposes of section 3(2) of the DPA 2018.

Which of the data protection principles would be contravened by disclosure?

The Authority stated that disclosure of the personal data in this case would contravene the first data protection principle (Article 5(1)(a)). Article 5(1)(a) states that personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject.
In terms of section 3(4) of the DPA 2018, disclosure is a form of processing. In the case of FOISA, personal data is processed when it is disclosed in response to a request.
The Commissioner must now consider if disclosure of the personal data would be lawful (Article 5(1)(a)). In considering lawfulness, he must consider whether any of the conditions in Article 6 of the UK GDPR would allow the data to be disclosed. The Commissioner considers condition (f) in Article 6(1) to be the only one which could potentially apply in the circumstances of this case.

Condition (f): legitimate interests

Condition (f) states that the processing shall be lawful only if it is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data (in particular where the data subject is a child).
Although Article 6 states that this condition cannot apply to processing carried out by a public authority in the performance of their tasks, section 38(5A) of FOISA makes it clear that public authorities can rely on Article 6(1)(f) when responding to requests under FOISA.
The tests which must be fulfilled before Article 6(1)(f) can be met are as follows:
1. Does the Applicant have a legitimate interest in obtaining the personal data?
2. If so, would the disclosure of the personal data be necessary to achieve that legitimate interest?
3. Even if the processing would be necessary to achieve that legitimate interest, would that be overridden by the interests or fundamental rights and freedoms of the data subjects?

Does the Applicant have a legitimate interest in obtaining the personal data?

In his submissions to the Commissioner, the Applicant noted that the Authority had not specified what data they claimed to be personal data, and so he had assumed that this meant the names and contact details of the responsible persons. He submitted that the PFA placed a statutory duty on the Authority to publish the application data submitted by property factors (i.e. names and contact details, amongst other data) on the Property Factors Register website for public viewing. In this regard, he made reference to the information published on the privacy page of the Property Factors Register website which, he submitted, made clear that the personal data submitted by property factors would be used by the Authority “To be displayed as required on the public register”, and that where a property factor did not wish its personal data to be made public, it could withdraw its application to register and be removed from the register, leaving it unable to operate as a property factor in Scotland. He further submitted that the privacy page also made clear that “Any request for information other than what is available through the public register will be considered under Freedom of Information legislation”. As such, the Applicant argued, there was no excuse for not publishing the names of the responsible persons of property factors, given the property factors were well aware and had consented to their personal data being published when making their application to register.
The Applicant further submitted that the information requested was previously published by the Authority on the public Property Factors Register since it went live in October 2014 until September 2024. In his view, this rendered the Authority’s sudden objection to providing information they were legally required to make public (and had previously done so) extremely suspicious and dodgy.
In addition, the Applicant argued that the information requested was published on the Companies House website with no concerns, i.e. the names, dates of birth, job titles and addresses of the property factors’ Directors who, he stated, were the responsible persons as defined by the PFA. As such, the Applicant believed the Authority could have no valid objections to publishing and disclosing the requested information.
The Applicant also provided further background information in support of his legitimate interest in disclosure of the information. This included links to articles published on the websites of the Authority, the UK Parliament, the Scottish Parliament, the Scottish Courts and Tribunals Service and one of the property factors named in the request, plus media articles in local and national press.
In this regard, the Applicant believed that it was clear that the issues he had raised, and the information that he had requested, stemmed from a wider problem affecting homeowners across Scotland. He argued that the Authority’s secrecy and attempts to shut down anyone who sought information which would expose its failure to take action on such issues was not helpful and would only make matters worse.
In its submissions to the Commissioner, the Authority stated that it was not aware of any legitimate interests the Applicant had in the information requested. It explained that the Applicant’s request formed part of a large body of correspondence relating to the registration of property factors, during the course of which the Applicant had made numerous accusations of staff dishonesty, incompetence, criminality and maladministration against named individuals, the team and civil servants in general. The Authority submitted that the Applicant had explicitly stated that he would not stop until his allegations had been proven which, in the Authority’s view, amounted to a pattern of threatening and harassing behaviour.
In the Authority’s view, the Applicant was asking for this personal data because he was making allegations against those persons, and this was not a legitimate interest in obtaining their personal data (contact details, names, address history and dates of birth). It submitted that, if the Applicant suspected that a law had been broken, he could report it to the police for investigation as necessary.
The Authority contended that the Applicant was mistaken in his belief that the legislation required the information to be published in the public Property Factors Register; there was no provision in the legislation compelling it to publicly disclose personal and sensitive data, and so it was under no obligation to do so.
In this regard, the Authority explained that section 1(2) of the PFA required that “The register must be available for public inspection at all reasonable times”, and that section 4(6) (with reference to section 3(2)) set out the information that required to be included in an entry in the Property Factors Register.
As such, the Authority submitted, section 4(6) set out the information that was required to be contained in the Property Factors Register and section 1(2) provided that the public must be able to inspect that information at all reasonable times. However, this did not require it to publish the information in the online system, rather it meant that an individual might, at any time, seek to inspect the register and the Authority would afford that opportunity. In practice, the Authority explained, this was often in response to a request for specific information, but it could also be facilitated by providing opportunity for inspection of the register in person at the Authority’s premises. The Authority confirmed that it discharged its legal obligation to make the information publicly available by these means.
The Authority further confirmed that no previous versions of the online system had ever shown all of the information requested, although a previous version did show the names of individuals associated with each property factor (but the current version did not). It stated that the Property Factors Register had recently moved onto a new system for operational reasons. As part of that move, the Authority had identified that, as there was no legal obligation to display that specific information on the public-facing register, it would not be included in the new system. The Authority confirmed that this aligned with its legal responsibilities and simply represented an operational decision made in line with value for money considerations.
The Commissioner notes the Authority’s position that it is under no obligation to publish the information requested in the online system, and that it discharges its legal obligation to make the information in the Property Factors Register publicly available by way of responding to information requests, or by facilitating in-person viewing of the register at its premises. However, the issue for the Commissioner to consider in this case is not concerned with the online publication of the information, rather he must decide whether the Authority was correct to withhold the particular information requested by the Applicant under section 38(1)(b) of FOISA, in response to his information request.
Turning to the matter of legitimate interests, the Commissioner has considered the submissions from both parties. Having done so, he recognises that the Applicant may have a legitimate interest in knowing how decisions regarding property factors are considered and dealt with, whether the named individuals were fit and proper persons in terms of the PFA and whether the Authority adequately discharged its duties in ensuring that only fit and proper persons were added to the register (while acknowledging that responsibility for that discharge remains with the Authority) – and there is clearly a legitimate interest in the wider public being aware of such matters. He accepts that disclosure of the personal data would assist in the understanding of these. The Commissioner therefore accepts that the Applicant has a legitimate interest in the withheld information.

Is disclosure of the personal data necessary?

Having accepted that the Applicant has a legitimate interest in the withheld information, the Commissioner must consider whether its disclosure is necessary to meet the Applicant's legitimate interests. In doing so, he must consider whether these interests might reasonably be met by any alternative means.
The Commissioner has considered this carefully in light of the decision by the Supreme Court in South Lanarkshire Council v Scottish Information Commissioner [2013] UKSC 55. In this case, the Supreme Court stated (at paragraph 27):

“A measure which interferes with a right protected by Community law must be the least restrictive for the achievement of a legitimate aim. Indeed, in ordinary language we would understand that a measure would not be necessary if the legitimate aim could be achieved by something less.”

"Necessary" means "reasonably" rather than "absolutely" or "strictly" necessary. When considering whether disclosure would be necessary, public authorities should consider whether the disclosure is proportionate as a means and fairly balanced as to the aims to be achieved, or whether the requester's legitimate interests can be met by means which interfere less with the privacy of the data subject.
In its submissions to the Commissioner, the Authority stated that, were the Commissioner to find that the Applicant had a legitimate interest in the personal data, it accepted that disclosure of the data would be necessary to satisfy that legitimate interest. Given the terms of the Applicant’s request, the Authority could identify no way of disclosing the information in a way that would not disclose personal data.
Having considered the Authority’s submissions along with the sample personal data provided, the Commissioner accepts that disclosure of the personal data is necessary to achieve the Applicant’s legitimate interests. He notes that the Authority already publishes certain information in the public register, which takes the Applicant some way to satisfying his legitimate interest. However, the more specific details requested might well be considered relevant to fully satisfying that legitimate interest and would be quite appropriate for transparency and accountability in this context. The Commissioner can identify no viable means of fully meeting the Applicant’s legitimate interests which would interfere less with the privacy of the data subjects than providing the withheld information in full. In all the circumstances, therefore, the Commissioner is satisfied that disclosure of the personal data is necessary for the purposes of the Applicant's legitimate interests.
The Commissioner will now consider whether the Applicant’s legitimate interest in obtaining the withheld information outweighs the rights and freedoms of the data subjects.

The data subjects' interests or fundamental rights and freedoms

It is necessary for the Commissioner to balance the legitimate interests in disclosure against the data subjects' interests or fundamental rights and freedoms. In doing so, he must consider the impact of disclosure. For example, if the data subjects would not reasonably expect that the information would be disclosed to the public under FOISA in response to the request, or if such disclosure would cause unjustified harm, their interests or rights are likely to override any legitimate interests in disclosure. Only if the legitimate interests of the Applicant outweigh those of the data subjects can the information be disclosed without breaching the first data protection principle.
The Commissioner's guidance on section 38 of FOISA notes factors that should be taken into account in balancing the interests of parties. He notes that, although no longer specifically applicable in the UK, Recital (47) of the General Data Protection Regulation states that much will depend on the reasonable expectations of the data subjects. These are some of the factors public authorities should consider:
1. Does the information relate to an individual's public life (their work as a public official or employee) or to their private life (their home, family, social life or finances)?
2. Would the disclosure cause harm or distress?
3. Whether the individual has objected to the disclosure.

Does the information relate to public or private life?

Disclosure under FOISA is public disclosure; information disclosed under FOISA is effectively placed into the public domain.
The Commissioner acknowledges that the withheld information relates to the individuals' private lives, in that it comprises their names, contact details, dates of birth and address history. Given that this information was provided to the Authority by these individuals in relation to their capacity as a property factor’s responsible person, the Commissioner is of the view that the information also relates, by association, to the individual’s public lives.
In the circumstances, the Commissioner concludes that the withheld information relates to both the private and public lives of the data subjects (the named individuals).

Would disclosure cause harm or distress to the data subjects?

In its submissions to the Commissioner, the Authority referred to its privacy statement (published on its website) relating to the Property Factors Register which stated:

“If an application to join the register is approved, the name(s) of the person(s) directly involved in the control or governance of the property factor will be provided on request. Any request for information other than what is available through the public register will be considered under Freedom of Information legislation. Information is exempt from being released under Freedom of Information if releasing it would breach the Data Protection Principles.”

The Authority submitted that the Applicant had made his request, which had been considered under FOISA with exemptions appropriately applied. It stated that consideration under FOISA did not automatically enable disclosure, and it had therefore conducted its business in line with legislation and its privacy statement.
The Authority explained that it had a general approach of disclosing information about senior members of staff within senior civil service roles and relatively senior public-facing roles, but withholding those details for more junior members of staff. It took broadly the same approach to individuals within third party organisations, where their level of seniority may not be known and based on whether they had a high public profile or not. In this case, the Authority submitted, the individuals named in the request did not have a high public profile and would not expect their personal information to be disclosed publicly in response to an information request, which was the effect of disclosure under FOISA.
In light of this, the Authority took the view that it would be unfair to disclose the information in this way. It did not consider that it had a lawful basis under which to process the personal data for the purposes of satisfying the Applicant’s request.
The Authority submitted that, even if the Applicant did have legitimate interests in the withheld personal data, it did not believe that these would outweigh the interests of the data subjects in protecting their privacy. It contended that the Applicant was fixated on this matter and it was important that relatively junior members of staff at other organisations should have their privacy protected so that they did not personally become the target of his dissatisfaction. As it believed the safety, security and privacy of the individuals concerned overrode the Applicant’s interest in the information, the Authority submitted that it could not disclose the personal details requested.
The Authority confirmed that, while it did not accept that the Applicant had a legitimate interest in the information, any such identified interest would be heavily outweighed by the rights and freedoms of the individuals concerned. In the Authority’s view, the information was exempt from disclosure under section 38(1)(b) when it responded to the Applicant’s request and request for review, and it remained so now.
The Commissioner has considered the harm or distress that might be caused by disclosure. He notes that disclosure of any information under FOISA – although in response to a request made by a specific applicant – effectively places that information into the public domain. As such, he must also consider the effects of publicly disclosing any personal data under FOISA.
The Commissioner has considered the relevant submissions from both parties, together with the sample personal data. He recognises that it identifies the individuals concerned, corresponding with their applications for inclusion as responsible persons on the Property Factors Register.
The Commissioner has considered what reasonable expectations these individuals would have in relation to the disclosure of their personal data in response to the request under consideration here. In doing so, he has taken into account:
1. the privacy statement relating to the Property Factors Register, published on the Authority’s website;
2. the requirements of sections 1(2) and 4(6) of the PFA and the manner in which the Authority discharges its legal obligations to make publicly available the information in the Property Factors Register, in line with this legislation, and
3. the information which is publicly available in the public-facing online system.
In the Commissioner’s view, none of these would have led to the data subjects having any reasonable expectation that their personal data, as contained in the withheld information, would be published, or disclosed in response to an information request under FOISA. He accepts, therefore, that the individuals named in the Applicant’s request would have a reasonable expectation that their personal data would remain confidential.

Balance of legitimate interests

The Commissioner has carefully balanced the legitimate interests of the data subjects against those of the Applicant. He has concluded that the Applicant’s legitimate interest in the personal data is overridden by the interests or fundamental rights and freedoms of the data subjects and that the requirements of condition (f) cannot be met here. In the absence of a condition which would permit disclosure of the remaining withheld personal data, the Commissioner must conclude that disclosure would be unlawful.
Given that the Commissioner has concluded that the processing of the third party personal data requested would be unlawful, he is not required to go on to consider whether disclosure of that personal data would otherwise be fair and transparent.

Conclusion on the data protection principles

The Commissioner finds that disclosure of the third party personal data under consideration here would breach the first data protection principle and that this information is therefore exempt from disclosure (and was properly withheld) under section 38(1)(b) of FOISA.

Decision

The Commissioner finds that the Authority complied with Part 1 of the Freedom of Information (Scotland) Act 2002 in responding to the information request made by the Applicant.

Appeal

Should either the Applicant or the Authority wish to appeal against this decision, they have the right to appeal to the Court of Session on a point of law only. Any such appeal must be made within 42 days after the date of intimation of this decision.

Euan McCulloch

Head of Enforcement

17 September 2026

Appendix 1: Full text of part 2 of Applicant’s request

The Property Factors Act makes it clear that the persons on the Register can only be on the Register for one firm at a time. A previous FOI by myself shows [the Authority] failed to seek legal guidance before allowing property factors to be “responsible persons” for more than one firm! Had [the Authority] sought the appropriate legal guidance they would have been told to remove the persons named from the register from one of the property factors!

Section 4 of the Property Factors Act states that “where the person is, or has previously been, registered, that—

(i) the person is a fit and proper person to be a property factor,
(ii) the person has demonstrated compliance with section 13(3),
(iii) the person has, while registered, demonstrated compliance with the property factor code of conduct, and
(iv) the person has demonstrated compliance with a property factor enforcement order made against the person by a homeowner housing committee.”

“Otherwise, the Scottish Ministers must refuse to enter the person in the register.”

Section 5 of the Property Factors Act then explains what the requirements are for passing the “fit and proper test” and subsection 3 clearly states that they must have “demonstrated compliance with – (a) the property factor code of conduct, and (b) [any] property factor enforcement order made against that property factor by a homeowner housing committee.”

This makes it clear that they FAIL the “fit and proper test” if they have failed to demonstrate compliance with the code of conduct! They also FAIL the “fit and proper test” if they have failed to comply with a Property Factors Enforcement Order!

A previous FOI by myself shows that [the Authority] failed to obtain legal guidance before incorrectly interpreting this rule and allowing Hacking and Paterson and Your Local Factor to be entered/remain on the Register.

And just in case you were in any doubt [the Authority’s] Property Factors Act Fit and Proper Person Declaration Factsheet states that:

(https://www.gov.scot/binaries/content/documents/govscot/publications/factsheet/2016/05/property-factors-scotland-act-2011-fit-and-proper-person-factsheet/documents/property-factors-scotland-act-2011-fit-proper-person-declaration-factsheet-pdf/property-factors-scotland-act-2011-fit-proper-person-declaration-factsheet-pdf/govscot%3Adocument/Property%2BFactors%2B%2528Scotland%2529%2BAct%2B2011%2B-%2Bfit%2Band%2Bproper%2Bperson%2Bdeclaration%2Bfactsheet.pdf

“All applicants must complete a Fit and Proper Person Declaration. Each application should provide details of the responsible/relevant person acting for the factor who wishes to become registered. Scottish Ministers consider certain information in relation to determining whether the property factor should be put on the register. This includes:

considering information held on the Companies in the UK website and how this relates to the information provided in the application
whether the responsible and relevant person has or had previous links to another property factor and any information held which provides details in relation to previous compliance with the Property Factors (Scotland) Act 2011”

I request the following Freedom of Information requests:

Publish all the Fit and Proper Person Declarations (and all supporting evidence) for [named individual] in relation to all his applications for entry on to the Property Factors Register for Hacking and Paterson
Publish all the Fit and Proper Declarations (and all supporting evidence) for [named individual] in relation to all his applications for entry on to the Property Factors Register for Your Local Factor Ltd
Publish all the Fit and Proper Declarations (and all supporting evidence) for [named individual] in relation to all his applications for entry on to the Property Factors Register for Hacking and Paterson
Publish all the Fit and Proper Declarations (and all supporting evidence) for [named individual] in relation to all his applications for entry on to the Property Factors Register for Your Local Factor Ltd
Publish all the Fit and Proper Declarations (and all supporting evidence) for [named individual] in relation to all his applications for entry on to the Property Factors Register for Hacking and Paterson
Publish all the Fit and Proper Declarations (and all supporting evidence) for [named individual] in relation to all his applications for entry on to the Property Factors Register for Your Local Factor Ltd
Publish all the Fit and Proper Declarations (and all supporting evidence) for [named individual] in relation to all his applications for entry on to the Property Factors Register for Hacking and Paterson
Publish all the Fit and Proper Declarations (and all supporting evidence) for [named individual] in relation to all his applications for entry on to the Property Factors Register for Hacking and Paterson
Publish all the Fit and Proper Declarations (and all supporting evidence) for [named individual] in relation to all his applications for entry on to the Property Factors Register for Hacking and Paterson

END