UK compliance: Equality Act, UK GDPR and PECR for AI messaging
If you letting or selling property in England, Wales, Scotland or Northern Ireland, the AI assistant sits inside the same rules your negotiators already work to. This guide sets out what to configure before you switch it on. It is practical guidance, not legal advice.
Equality Act 2010
You cannot treat an applicant differently because of a protected characteristic: age, disability, gender reassignment, marriage or civil partnership, pregnancy or maternity, race, religion or belief, sex, or sexual orientation.
- Never add knowledge base entries such as "professionals only", "no families", or "no DSS/benefits" — blanket benefit bans have been found to be indirectly discriminatory.
- Keep qualification to lawful criteria: budget or affordability, move-in date, chain position, deposit, tenancy length, pets where your landlord permits a decision.
- If an applicant discloses a disability or requests an adjustment, route the conversation to a human rather than letting the assistant decide.
UK GDPR — who is who
You are the controller for applicant, vendor and landlord data. Lytle.ai processes it on your instructions as a processor. Publish a privacy notice that names AI-assisted messaging, your lawful basis, and your retention period.
- Access and portability: export the contact record and transcripts from the contact view.
- Rectification: correct the contact record; the assistant uses the corrected facts from then on.
- Erasure: delete the contact, which removes their messages and derived summaries.
- Respond within one calendar month, as required by UK GDPR.
The GDPR page lists subprocessors and the safeguards used for transfers outside the UK, including the UK International Data Transfer Addendum where relevant.
PECR — texts and marketing
Replying to an enquiry the applicant started is service communication. Ongoing nurture, new-instruction alerts, and re-marketing to old leads are direct marketing and need consent or a valid soft opt-in.
- Capture consent at the point of enquiry and store it against the contact.
- Identify your branch in the first message and give an opt-out route in every marketing message.
- Honour STOP immediately — the assistant suppresses the contact automatically once it is received.
Right to Rent, AML and material information
- Right to Rent and anti-money-laundering checks are staff decisions. The AI may collect documents or answers, but a human must verify and record the outcome.
- Trading Standards material information rules expect tenure, council tax band, price, deposit, and known restrictions to be accurate. Keep those fields correct in the property record, since the assistant answers from them.
- Anything about fees, valuation, or negotiation should escalate to a human. Configure that in your escalation rules.
Tenant Fees Act and deposits
In England, permitted payments are capped — five weeks' rent deposit (six where annual rent is £50,000 or more) and a one week holding deposit. Wales, Scotland and Northern Ireland have their own rules. Put the correct figures in the knowledge base so the assistant never quotes a prohibited payment.
A short pre-launch checklist
- 1Remove any exclusionary wording from listings and knowledge base entries.
- 2Set your escalation rules for fees, valuations, adjustments and complaints.
- 3Add your privacy notice link to the website widget and your SMS footer.
- 4Confirm deposit and holding deposit figures per nation.
- 5Run five test conversations, including one that asks a protected-characteristic question, and check the assistant declines and escalates.
Frequently asked
Can the AI refuse an applicant?
It should not make the decision. It gathers lawful qualifying information and scores the enquiry so your negotiator can decide. Any refusal, adjustment request, or dispute is escalated to a person.
Do I need a DPIA?
If you are profiling applicants at scale or handling special category data, a data protection impact assessment is prudent and may be required. Most single-branch agents document a short assessment covering purpose, lawful basis, retention and escalation.
Is AI-assisted messaging allowed under the Property Ombudsman code?
There is no prohibition on using software to respond, but the code's transparency and accuracy duties still apply to you. Make it clear a human is available, and keep property facts accurate.
This guide is general operational guidance maintained by the Lytle.ai team and is not legal advice. Confirm your process with your broker and qualified counsel for your jurisdiction.