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Privacy notice

How MatchKey Technology Limited, which runs Golden Ledger, uses personal information, and the part your council plays.

The short version

  • Golden Ledger is run by MatchKey Technology Limited. Your council uses Golden Ledger to collect building fire safety information from building owners.
  • If you got a letter from your council, your council found you through HM Land Registry: from our data on companies that own property, or from a copy of the title register that your council ordered through Golden Ledger.
  • What you send through Golden Ledger (answers and documents) is held for your council. Your council decides what happens to it. We process it on the council's instructions.
  • If you choose, computer services in Microsoft's UK South data centre read your documents and suggest answers. You check and confirm every answer. A computer never decides anything about you on its own.
  • With your consent, we use analytics and advertising cookies to understand how people use Golden Ledger and to reach councils and owners who may need it. We never share your answers, documents or building details with analytics or advertisers.
  • You have rights over your information, including to see it, correct it and complain. Email privacy@goldenledger.co.uk.
On this page

Who we are

Golden Ledger is a trading name of MatchKey Technology Limited, a company registered in England and Wales (company number 16292336). Registered office: 100 High Ash Drive, Leeds LS17 8RE. We are registered with the Information Commissioner's Office (ICO), registration number ZB962065.

In this notice "we" and "us" means MatchKey Technology Limited. "Your council" means the local council that wrote to you about your building or invited you to Golden Ledger.

Contact us:

Data protection officer: we have not appointed one, because UK GDPR Article 37 does not require it for the work we do. A director of MatchKey Technology Limited is responsible for data protection and reads every message sent to privacy@goldenledger.co.uk.

Who is responsible for your information

UK data protection law (the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018) calls the organisation that decides why and how information is used the "controller". The organisation that uses it only on a controller's instructions is the "processor". Golden Ledger has two kinds of information, with a different controller for each.

Who is the controller for each kind of information
InformationWho is the controllerOur role
What you submit about a building: questionnaire answers, documents you upload, the values read from them and your confirmationsYour councilProcessor, acting on the council's written instructions under a data processing agreement (UK GDPR Article 28)
Your company's document reading choice, and the record of who did what with a submission (for example who submitted an answer or downloaded a document)Your councilProcessor. We keep these records for the council so it can show what happened (UK GDPR Article 28(3)(h))
A copy of a title register that your council orders from HM Land Registry through Golden LedgerYour councilProcessor, acting on the council's instructions
Our own building and ownership data that we supply to councils: building heights from Ordnance Survey data, and the companies that own buildings from HM Land RegistryMatchKey Technology LimitedController. We disclose it to councils that use Golden Ledger
Your Golden Ledger account, sign-in, and our security and sign-in recordsMatchKey Technology LimitedController
Enquiries you send to us through our website or by emailMatchKey Technology LimitedController
Work contact details of council officers we sell to or supportMatchKey Technology LimitedController
How you use the Golden Ledger website and app, if you allow analytics or advertising cookiesMatchKey Technology LimitedController. We use it for our own purposes, including our marketing

We do not use what you submit for our own purposes unless your council instructs us to. For anything in the first row, your council's own privacy notice also applies, and your council is the main place to exercise your rights. We will pass any request about it to your council and help them answer it.

If you act for an owner company, or are its managing agent, your company is a separate controller of the records it chooses to send to the council. It does not control how Golden Ledger processes them.

Where your information comes from

From you. When you enter your letter's access code, create an account, answer the questionnaire, upload documents or email us.

From other sources (UK GDPR Article 14). Before you ever use Golden Ledger, we may hold:

Information we may hold before you use Golden Ledger
InformationSourceWhy it is held
The name and registered address of a company that owns a buildingHM Land Registry's datasets of UK companies and of overseas companies that own property in England and WalesSo your council can identify and write to the owner responsible for a building
Your name and the address registered for you as owner of a propertyAn official copy of the title register that your council orders from HM Land Registry through Golden Ledger. Your council controls itSo your council can identify and write to the person responsible for a building
Building address, height and number of storeysOrdnance Survey dataSo your council can identify buildings that may fall under fire safety law
Company number, name, status and registered office, where the owner is a companyCompanies HouseTo check which company owns a building

We send Companies House company names and numbers only. We never send it a private individual's name.

If you are a managing agent, a fire risk assessor, an engineer or a resident named in a document an owner uploads, we receive your details from that owner. See "People named in documents" below.

HM Land Registry's two company datasets list companies and other organisations only: HM Land Registry leaves out private individuals. A private individual's name reaches Golden Ledger only from a title register a council orders, and the council tells you about that in its letter and its own privacy notice (UK GDPR Article 14).

What we hold and why

UK GDPR Article 6 says we must have a lawful basis for each use of your information. Where the council is the controller, the council decides the lawful basis and its privacy notice states it.

What we hold, why, who controls it and the lawful basis
WhatExamplesWhyControllerLawful basis
Ownership dataCompany name, registered address, title number, company numberTo let councils find and write to the owner responsible for a buildingMatchKeyLegitimate interests, Article 6(1)(f): helping councils carry out their fire and building safety duties, which protects residents. We have recorded a legitimate interests assessment
Title registers a council ordersOwner name and address for service, title numberSo the council can name and contact the freeholderYour councilSet by your council, in its own privacy notice
Account detailsName, email address, phone number if given, the company you act for, your roleTo create your account, sign you in and keep it secureMatchKeyContract, Article 6(1)(b), where you use the service for yourself; legitimate interests, Article 6(1)(f), where you act for a company or another person
Access code useThe access code you enter, the time, and your IP addressTo link your account to the right building and stop people guessing codesMatchKeyLegitimate interests, Article 6(1)(f): keeping the service secure
Security and sign-in recordsWhen you signed in, changes to your account, attempts that were refusedTo keep the service secure and investigate misuseMatchKeyLegitimate interests, Article 6(1)(f)
SubmissionsQuestionnaire answers, uploaded documents, values read from documents, your confirmationsSo your council can carry out its fire and building safety functionsYour councilSet by your council, in its own privacy notice
Your document reading choiceWhich option was chosen, who chose it, when, and the wording shownTo prove what your company chose and honour itYour councilSet by your council, in its own privacy notice
Submission recordsWho did what and when, for example who submitted an answer or downloaded a documentTo give your council an accurate recordYour councilSet by your council, in its own privacy notice
Emails we send youYour email address, which notices you have turned off, whether an email bouncedTo send you service messages and respect your choicesMatchKeyLegitimate interests, Article 6(1)(f)
Website enquiriesYour name, email address and messageTo answer youMatchKeyLegitimate interests, Article 6(1)(f)
Council officers' business contact detailsName, job title, work email address, work phone number, where we found them and whenTo offer Golden Ledger to councils and support councils that use itMatchKeyLegitimate interests, Article 6(1)(f). See "Business contacts" below
Usage analytics, only if you allow analytics cookiesPages opened, with access codes, account numbers and building references removed from the address; how you arrived (the website or advert that sent you); steps such as starting to enter an access code or clicking to book a demo; how far you scroll, links to other websites you follow and files you download; your device, browser and rough location worked out from your IP address; a random number in the _ga cookie. Once you are signed in, Google Analytics does not run in your browser: our server sends it how you signed in (for example with Google or an email code) and whether it was your first time, which questions were answered and on which screen (never the answers), the type of each document uploaded, that a building was claimed, a company set up or answers sent to the council (with a count of answers, never the answers), and counts of answers a council accepted, with your role (owner, managing agent or council), your council and a coded version of your account number that cannot be turned back into itTo understand how people use Golden Ledger and improve it, and for MatchKey's own marketing: to find and reach councils and owners who may need Golden Ledger, including by advertisingMatchKeyYour consent, Article 6(1)(a). You can withdraw it at any time with Cookie settings
Advertising, only if you allow advertising cookies tooThe usage analytics above, used by Google to measure our adverts and show them to people who may need Golden LedgerTo advertise Golden Ledger to councils and ownersMatchKey, and Google for its own advertising servicesYour consent, Article 6(1)(a). You can withdraw it at any time with Cookie settings

Special category information. Fire safety documents can sometimes include information about a resident's health or disability, for example in a personal emergency evacuation plan. This is "special category" data under UK GDPR Article 9. Your council, as controller, decides the condition it relies on under Article 9(2) and the Data Protection Act 2018, Schedule 1, and states it in its own privacy notice. We hold such information only as part of the submission, on the council's instructions. Please do not upload documents containing residents' health information unless your council asks for them.

We do not sell your information. With your consent, we use analytics and advertising cookies to understand how people use Golden Ledger and to reach councils and owners who may need it. We never share your answers, documents or building details with analytics or advertisers. Nothing you submit to your council is used for our marketing.

How documents are read, and the part computers play

When you upload a document, it is stored and scanned for viruses in Microsoft Azure in the UK South region (London). Nothing is read until the scan has passed. Our application servers, run by Vercel in London, United Kingdom, pass the file and the text read from it between these services; they do not store it.

Your company chooses whether Golden Ledger reads its documents. Nothing is chosen for you, and nothing is read before you choose. You can change the choice at any time in Company settings.

The three document reading options
OptionWhat happens
Do not read my documentsNothing is read. You type every answer yourself.
Read without AIAzure AI Document Intelligence (Microsoft, UK South) picks out the text and tables. Fixed rules match them to questions. No generative AI is used.
Read with AI assistanceAs above, and Azure OpenAI (Microsoft, UK South) suggests an answer for each question, with the page and the exact words it relied on.

Every suggested answer is shown to you with the page and the words it came from. It only becomes an answer when you confirm or correct it. Your council sees only what you confirmed, and anything you have not confirmed is marked as not confirmed.

No decisions by computer alone

No decision about you that has a legal or similarly significant effect is made solely by automated means (UK GDPR Articles 22A to 22D, in force since 5 February 2026 under the Data (Use and Access) Act 2025, section 80).

A person (you) confirms every answer, and your council's staff review what you send.

What Microsoft does with the content

Document Intelligence keeps the file and its result for 24 hours after reading, then deletes them.

Azure OpenAI does not use prompts or answers to train models, and they are not available to OpenAI. Microsoft runs automated abuse monitoring: content it flags may be checked by automated systems and, where those are not sure, by authorised Microsoft staff. Microsoft does not publish a retention period or a reviewer location for UK deployments. If Microsoft approves us for modified abuse monitoring, that human review stops and we will update this notice.

If you choose an option that reads less, values read from your documents that you have not confirmed are deleted. Answers you confirmed stay, because they are your answers.

People named in documents

Documents that owners upload can name other people: fire risk assessors, engineers, managing agents' staff and sometimes residents. We hold those details only as part of the document, as your council's processor. Your council is the controller, and its own privacy notice explains how it uses them (UK GDPR Article 14). If you are named in a document and want to know more, contact your council or privacy@goldenledger.co.uk and we will pass your request on.

Business contacts: council officers

This section is for people who work for a council that we offer Golden Ledger to, or that already uses it. We are the controller of your business contact details, and we use them to offer Golden Ledger to your council, to talk to you about it and to support your council once it uses it.

What we hold. Your name, job title, department, work email address and work phone number, the council you work for, where we found your details and the date we found them, whether your work address was printed by your council or worked out from the address pattern your council publishes (we mark which, and correct or remove an address that turns out to be wrong), and a log of the messages we sent you and the calls we made, with the dates and the meeting times we proposed. We never hold your personal email address, home address or anything about your private life.

Where we find council officers' business contact details
SourceWhat it means
Email with our staffYou emailed one of our staff, or they emailed you, at your council address. We take your name and address from the email itself, not from its content or your signature
Your enquiryYou contacted us, for example through our council enquiry form
Published by your councilYour council's own published information: transparency data, committee and cabinet reports, job adverts and freedom of information disclosure logs. We record the address of the page
Published elsewhereYour own public professional profile, or a press release or news article that names you in your role. We record the address of the page
Given to usYou or a colleague gave us your details, for example at a meeting

Our lawful basis. Legitimate interests, UK GDPR Article 6(1)(f): offering a service that helps councils carry out their building safety duties, which protects residents, and growing our business. We hold only work details about your role at a public body, mostly already published, and only MatchKey staff can see them. Councils, building owners and Homes England never see them. We have recorded a legitimate interests assessment, following the Information Commissioner's Office guidance on legitimate interests and on business-to-business marketing, and you can ask us for a copy.

When we tell you. In the first email we send you, and in any case within one month of recording your details (UK GDPR Article 14). Every marketing email from us says who we are and how to stop them (Privacy and Electronic Communications Regulations 2003, regulation 23).

Your right to object. You can object at any time and we will stop (UK GDPR Article 21). Reply to any of our emails or write to privacy@goldenledger.co.uk. We then mark you as "do not contact", delete your job title, phone number and the page we found you on, and keep only your name, work email address and the date you objected, so that we never add you again. We will still answer you if you write to us. You can also ask us to delete your details and our emails with you (Article 17).

Who can see your information

  • Your council sees the buildings in its own area, the answers you submit and the documents you upload. A council never sees another council's buildings.
  • Your company and its managing agent, where you have one, see the buildings linked to your company.
  • MatchKey staff who run the service can see information where they need to, to support you and keep the service working. Access is limited by role and recorded.
  • Homes England would see anonymised counts only, once that reporting exists.
  • Suppliers who run parts of the service for us, listed below. They act only on our instructions under contracts that meet UK GDPR Article 28, except where the table below says otherwise.
  • Others where the law requires it, for example a court order or a request from a regulator or the police that we are legally obliged to meet.

Suppliers we use

Suppliers, what they do, where the data is held and the transfer safeguard
SupplierWhat they doWhere the data is heldSafeguard for any transfer outside the UK
Microsoft (Azure Blob Storage, Defender for Storage, Azure AI Document Intelligence, Azure OpenAI)Stores and virus scans uploaded documents; reads them if your company choosesUK South (London)Stored and processed in the UK. Microsoft Products and Services Data Protection Addendum
Vercel Inc.Runs the website and application, and stores documents uploaded before 12 October 2026 and council import files (Vercel Blob) until they are moved to MicrosoftApplication servers and Vercel Blob: London, United KingdomICO International Data Transfer Addendum with the EU standard contractual clauses, in Vercel's Data Processing Addendum
Neon (Databricks, Inc.)Hosts the database that holds accounts, answers and recordsLondon (AWS eu-west-2)Stored in the UK. Any access from outside the UK: EU standard contractual clauses with the ICO's UK Addendum, in the Databricks Data Processing Addendum
WorkOS, Inc.Account sign-in and password managementUnited StatesEU standard contractual clauses with the ICO's UK Addendum, in WorkOS's Data Processing Addendum
ResendSends service emailsUnited StatesUK Extension to the EU-US Data Privacy Framework, and EU standard contractual clauses with the ICO's UK Addendum, in Resend's Data Processing Addendum
Google Cloud (BigQuery)Holds MatchKey's building and ownership data, which names companies, not private individualsEuropean Union (EU multi-region)The UK treats EEA countries as adequate (Data Protection Act 2018, Schedule 21). Google Cloud Data Processing Addendum
Google Analytics (Google LLC), only if you allow analytics cookiesMeasures how Golden Ledger is used and, if you allow advertising cookies, our adverts. Google acts for us under the Google Analytics data processing terms, and as a separate controller when it uses the information for its own advertising servicesUnited States and other countries where Google has data centresGoogle LLC is certified under the UK Extension to the EU-US Data Privacy Framework (UK adequacy regulations for the United States, SI 2023/1028)
Companies HouseWe look up company details. We send company names and numbers onlyUKNone needed

This list was checked against our systems on 26 October 2026. Owners never pay for Golden Ledger, so no payment provider receives your information.

Information sent outside the UK

Uploaded documents are stored and read in the UK, and our application servers run in London. Some suppliers above are based in the United States, including the one that runs sign-in. For each transfer we rely on a safeguard under UK GDPR Chapter V (Articles 44 to 49), shown in the table: UK adequacy regulations (for the European Economic Area, or for US companies certified under the UK Extension to the EU-US Data Privacy Framework), or the EU standard contractual clauses with the ICO's International Data Transfer Addendum. You can ask us for a copy of the safeguard at privacy@goldenledger.co.uk.

How long we keep it

How long each kind of information is kept
InformationHow long
Documents you uploadWhile your company has the building on Golden Ledger, then as your council instructs
Questionnaire answers you confirmed, your company's reading choice and the record of who did what with a submissionAs your council instructs
Values read from documents but not confirmedUntil you confirm them, or until your company chooses an option that reads less, when they are deleted
A document's copy inside Document Intelligence24 hours after reading, then deleted by Microsoft
Title registers a council ordersAs your council instructs
Our ownership dataWhile it is current and the building is in the area of a council that uses Golden Ledger. HM Land Registry updates its company datasets every month, and we replace our copy when it does
Your accountWhile your account is open. If you ask us to close it, we delete it within one month, except your name where it appears in records your council keeps
Security and sign-in records6 years, the period in which a legal claim can be brought (Limitation Act 1980, section 5)
Your IP address used to limit access code guessingDeleted within 2 days
Records of how the questionnaire is used (which pages were opened and when)13 months, then deleted automatically
Copies of emails held by our email supplier30 days
Usage analytics in Google AnalyticsUp to 14 months, then deleted by Google. The _ga cookies on your device last up to 2 years unless you withdraw consent or clear them
Website enquiries2 years after our last reply
Council officers' business contact detailsWhile your council is a customer or we are talking to it and you are in post. Deleted 24 months after our last contact with a council that has not gone ahead, or when you leave and we hear of it. If you object, we keep only your name, work email address and the date, so we never contact you again

Cookies and similar technology

Some cookies and storage are strictly necessary for the service, so we do not ask for consent for them (Privacy and Electronic Communications (EC Directive) Regulations 2003, regulation 6 and Schedule A1, paragraph 4). Analytics and advertising cookies are not, so we use them only if you allow them in the cookie banner (regulation 6, as amended by the Data (Use and Access) Act 2025). Nothing from Google Analytics loads until you do. You can change or withdraw your choice at any time with Cookie settings, at the foot of every page of Golden Ledger or on our cookies page. Withdrawing does not affect what was collected before, and the service works the same whatever you choose.

Cookies and browser storage Golden Ledger uses
NameTypePurposeHow long
wos-sessionCookie (encrypted)Keeps you signed inUp to 400 days, or until you sign out
wos-auth-verifierCookieProtects the sign-in step against forgery10 minutes, set only when you start signing in or open a page that needs you to be signed in; deleted when sign-in finishes
gl_auth_restartCookieRestarts sign-in once if it fails part way2 minutes
gl_agent_companyCookieRemembers which company you are working for, if you can act for more than one1 year
gl_admin_councilCookieRemembers which council a MatchKey staff member is viewing (staff only)1 year
gl_consentCookieRemembers your answer to the cookie banner6 months
_ga and _ga_<id>Cookie, only with analytics consentGoogle Analytics: counts you as one visitor and remembers your current visit2 years
_gcl_auCookie, only with advertising consentMay be set by Google to tell whether one of our adverts led to a visit3 months
gl-displayBrowser storage on your deviceRemembers your display settings (text size, spacing, contrast, motion)Until you clear it
Questionnaire draftsBrowser storage on your deviceKeeps a reply you are typing to a council question if the page reloadsUntil sent or cleared

Keeping it secure

Uploaded documents are stored in private storage, scanned for viruses before Golden Ledger reads them, and opened only through Golden Ledger, which checks who is asking first. Access codes are checked against a scrambled (hashed) copy, and the plain code is kept so your council can see it. Access to the service is limited by role and recorded. If you find a security problem, email security@goldenledger.co.uk.

Your rights

You have the right to:

  • be told how your information is used (this notice; UK GDPR Articles 13 and 14)
  • get a copy of your information (Article 15)
  • have it corrected (Article 16)
  • have it deleted in some cases (Article 17)
  • limit how it is used in some cases (Article 18)
  • receive it in a portable form in some cases (Article 20)
  • object to its use where we rely on legitimate interests or public task (Article 21)
  • withdraw your consent at any time, where we rely on it (Article 7(3)), using Cookie settings; withdrawing does not affect what was collected before
  • not be subject to a significant decision based solely on automated processing without safeguards, including the right to have a person review it (Articles 22A to 22D)

Giving us information is not something we require: MatchKey does not make you supply anything to read this notice or visit the site. Any duty to respond to your council comes from the council, not from us, and your council tells you what follows if you do not give it information it asks for. Without an account we cannot link a building to your company, but nothing else is affected.

To use any right, email privacy@goldenledger.co.uk. For what you submitted about a building, your council is the controller: we will pass your request to them and help them answer. We reply within one month, which can be extended by two further months for complex requests (Article 12(3)). It is normally free.

How to complain

Please tell us first at privacy@goldenledger.co.uk and we will try to put it right. We acknowledge every complaint within 30 days and tell you the outcome without undue delay (Data Protection Act 2018, section 164A).

You can also complain to the Information Commissioner's Office: ico.org.uk/make-a-complaint, telephone 0303 123 1113, or write to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Changes to this notice

We will update this notice when the service or the law changes, and show the date at the top. If a change affects you significantly, we will tell you by email or when you next sign in.