Access and erasure: answering GDPR requests in condominium management

Sabine Wendt manages eleven owners' associations in Kassel. One Tuesday in March there is an email from Dietmar Roth in the inbox. Mr Roth sold his flat at Lindenstraße 12 two years ago. He would like to know what data the management still holds on him, and asks that all of it be deleted afterwards.

That email contains two requests: access under Art. 15 GDPR and erasure under Art. 17 GDPR. The same deadline applies to both.

The deadline starts on receipt

Under Art. 12(3) GDPR you answer without undue delay and at the latest within one month of receiving the request. If the request is complex, or many requests come in together, you may extend that by two further months. You must tell the requester so within the first month and give your reasons.

If the email sits unread in a shared inbox for a week, that week is missing at the end. So Ms Wendt opens two cases that same morning. Under Privacy requests she clicks New request, finds Mr Roth, picks Access (Art. 15) as the request type and enters the Tuesday as the date received. For the erasure she opens a second case with Erasure (Art. 17). Condomana computes the deadline from the date received and never lets a month overflow: a request received on 31 January is due on 28 February.

You can assign each case to a colleague. The assignee is reminded a week before the deadline, the day before, and once more when it has passed. With nobody assigned, the reminders go to every manager in the organisation. An extension by two months is entered on the case together with its reason.

If you have reasonable doubts that the email really comes from Mr Roth, Art. 12(6) GDPR lets you ask for additional information to confirm his identity. Your letter and his reply go on the case as files.

Access first, then erasure

Whoever erases first can no longer give a complete answer afterwards, because the email address, the postal address and the portal login are gone by then. So Ms Wendt answers the access request first.

On the case she clicks Generate export. Condomana collects everything held on Mr Roth into a ZIP archive: one CSV file per section, a data.json file with the same data in machine-readable form, and a PDF cover sheet. The sections run from the owner record and the ownership history through payments, defect reports, messages, letters, and assemblies with his votes, to surveys and room bookings. The IBAN appears in the archive only masked. The same archive also answers a portability request under Art. 20 GDPR.

Free text is the laborious part: the places where other people wrote about Mr Roth, such as a defect description, a comment or a file name. Condomana searches for his full name, for "Roth, Dietmar", for his email address and, for surnames of four letters or more, for the surname on its own. The hits are listed in the Mentions in free text section. A hit may concern a namesake, so read that section before the archive goes out.

The archive is the copy under Art. 15(3) GDPR. Art. 15(1) also requires information that sits in no table: the purposes of the processing, the recipients, the envisaged storage period, the rights to rectification, erasure, restriction and objection, the right to lodge a complaint with a supervisory authority, and where the data came from. That information belongs in your covering letter. Since it reads the same for most owners, a standard paragraph is worth keeping.

Generating the export marks the access case completed and records that on the timeline.

What remains after an erasure

Art. 17(3)(b) GDPR exempts from erasure data that must be kept to comply with a legal obligation. In an owners' association that mainly means the accounts and the community's records. Mr Roth appears in the annual statements for the years he owned the flat and in the owner lists of that time. Those records must stay legible, which is why his name stays.

On the erasure case Ms Wendt first opens Preview erasure. It shows every kind of data with the decision Erase or Retain under legal obligation, together with the legal basis and the retention period in years.

Erased are the contact details and the data for which no retention duty is recorded:

• email address, phone number, postal address, IBAN, internal notes and any WhatsApp consent
• the portal login with its stored notifications, and any pending invitations
• message threads by email and WhatsApp
• named survey answers and room bookings
• the links to shared documents, while the documents themselves stay
• the address in letters already sent and their PDFs, while the record that the letter was sent stays

Retained are the name, the ownership history, defect reports with their comments, the community's documents and the records of accepted agreements. A tenancy of the person that is still running is ended by the erasure.

How long data is kept

The period in the preview comes from a retention schedule per country. Which country counts depends on the person's units: Condomana takes the country where most of them are, and Germany if there are none. For German properties the schedule holds these periods:

Accounting vouchers such as invoices and bank statements have had an eight-year period since 1 January 2025 (§ 147 (3) sentence 1 AO, § 257 (4) HGB as amended by the Fourth Bureaucracy Relief Act). Books and annual accounts stay at ten years. Condomana holds the name to the longer period, because the same name also appears in the records kept for ten years.

The schedule itself marks the ten years for community records and for agreement records as a working assumption still to be confirmed legally, so agree the figure with your data protection adviser.

When the period has ended

The periods run from the end of the calendar year of the erasure. An erasure in March 2026 under a ten-year period is therefore due on 1 January 2037. On that date Condomana replaces the name with "Anonymised person" and deletes the records of accepted agreements. Where the agreement records have a shorter period than the name, as in France, they go correspondingly earlier. Bookings, ownership history, defect reports and documents stay as the community's records, without the name.

Condomana notifies your organisation's managers 30 days ahead. If you need the name for longer, say for a pending lawsuit, click Postpone on the erasure case and enter a date and the reason. Both then appear on the timeline, as do the notice and the erasure itself.

Automatic erasure is switched on for every organisation. A manager can switch it off under Privacy with Settings. You then delete the data yourself once the periods end, and the response letter tells the owner that you will delete it at that point.

Confirmation, letter, timeline

An erasure cannot be undone. Before Ms Wendt can click Erase contact data, she has to type the surname "Roth" exactly as it appears on the record. The erasure runs as a single step: if any part fails, nothing is erased.

Condomana then produces the Response letter as a PDF. It lists what was erased and what is kept, with the legal basis and period for each, and points to the right to complain under Art. 77 GDPR. Condomana marks the wording as a template that should be reviewed legally before its first use.

The case keeps the name and email address as they were recorded on receipt, so it stays clear whose request it was. Every step is on the Timeline: receipt, assignment, notes, export, erasure, reminders. Entries cannot be edited or removed. If you reopen a closed case, the statutory deadline does not start again.

Refuse request with a reason produces a refusal letter and leaves the data untouched. A rectification under Art. 16 GDPR you carry out on the owner record, then close the case with Mark completed and a note.

When the requester still owns the flat

Mr Roth has sold, so his case is manageable. If a current owner asks for erasure, Condomana erases his postal address just the same, and after that no invitation reaches him by post. In that case, clarify with your data protection adviser beforehand which contact details you still need to run the association.

The essentials

• The one-month deadline runs from receipt. Open the case the same day and assign it.
• The archive holds the data. Purposes, recipients, storage period and rights go in your covering letter.
• An erasure removes the contact details. Name, ownership history and community records stay, each with its legal basis and period.
• Once the periods end, Condomana anonymises the name and deletes the agreement records, after notifying the managers 30 days ahead. Postpone keeps the data for longer.