The data paradox: refusing to share data while it sits in fourteen spreadsheets

Systems discussions often reach the same objection. Tenant data must not go outside the company.

It is a responsible instinct. It is also, in most firms, based on a picture of the business that is not accurate.

Ask where the tenant data is today, and the room usually goes quiet.

Count the copies

Take one tenant in an illustrative firm. For example, follow their passport copy and their Emirates ID from the day they apply.

• The original arrives by WhatsApp on a leasing agent’s own phone.
• It is forwarded to a colleague, so it is on a second phone.
• It is emailed to the admin inbox, which four people can read.
• It is saved to a shared drive, in a folder called “New tenants”.
• A copy sits in the Downloads folder of the laptop that saved it.
• The details are typed into the rent roll, which has been emailed to the accountant.
• A scan goes to the owner, by email.

Where one passport copy ends up

1. Leasing agent's phonePersonal WhatsApp.
2. Colleague's phoneForwarded chat.
3. Admin inboxFour people can read it.
4. Shared driveA folder called "New tenants".
5. Laptop downloadsNever deleted.
6. Rent rollDetails emailed to the accountant.
7. Owner's inboxOutside your control.

That is seven copies of one person’s identity documents, before anyone has done anything careless. Add the older versions of the rent roll, and an old laptop in a cupboard. Fourteen copies is not an exaggeration. It is a normal Tuesday.

None of these copies has an owner. None has an expiry date. Nobody can list them.

Why the fear points the wrong way

The worry about a system is understandable, because a system is visible. It has a name, a contract and a login page. The risk feels like something you are choosing to take.

The scattered copies feel like nothing at all. Nobody decided to create them. They simply build up, one convenient message at a time.

So firms compare a visible risk with an invisible one, and treat the invisible one as zero. That is the data paradox. They refuse to share data with a partner under contract, while it already moves freely with no controls.

This is the same pattern that makes a spreadsheet feel safe. The familiar option gets a free pass. A banker would ask a harder question, as this article on credit checks shows: what can you prove?

What control actually means

Data control is not about where the server sits. It comes down to four questions you can answer on any day.

1. Where is it? Can you name every place a tenant’s documents are held?
2. Who can see it? Is that list based on job role, or on who happened to be copied in?
3. Who has seen or changed it? Is there a record, as covered in the case for audit trails?
4. Can you take it back? When someone leaves, can you remove their access the same day?

The question	Scattered files	One controlled system
Where is it?	Nobody can list every copy	One known location
Who can see it?	Whoever was copied in	Set by job role
Who has seen or changed it?	No record	Logged
Can you take it back?	Only partly	Same day

A firm running on scattered files cannot answer any of these. A firm running one controlled system can answer all four. That difference matters far more than whether the data sits on a machine in your office.

When an employee leaves

This is where the paradox stops being theoretical. An employee resigns. They have a phone full of tenant documents, a laptop with the rent roll, and years of chat groups.

What can you switch off? Their email, perhaps. The rest stays with them, on devices you do not control, in conversations you cannot see.

Staff turnover is normal in this industry. So the question is not whether this happens, but how often, and what leaves each time.

The UAE context

The UAE has a federal data protection law, Federal Decree-Law No. 45 of 2021. It covers the processing of personal data through electronic systems. It gives individuals rights. These include asking for inaccurate data to be corrected, and for processing to be restricted or stopped. Financial free zones such as DIFC have their own law.

The detail of how and when these rules apply is a matter for your legal adviser. Check the current position, including the status of the executive regulations.

The operational impact is easier to state. If a tenant asks you to correct their details, you need to find them first. That is hard to do across fourteen copies. The same is true of deleting records you no longer need. It also applies if a laptop goes missing and you must work out what was exposed.

You cannot apply a rule to data you cannot find.

What to ask a systems partner

Being careful about a partner is still right. Moving data into one system does not remove risk, it changes where you manage it. So ask direct questions:

• Who owns the data, and can we export all of it at any time?
• Who at your firm can see it, and is that recorded?
• Where is it hosted, and how is it backed up?
• What happens to our data if we stop working together?

A good partner will answer these without hesitation. These questions are worth asking. They are also worth asking of your own WhatsApp groups.

Check this on Monday

Pick one tenant at random. Ask your team to list every place that tenant’s identity documents are held, including phones and old files.

Then ask who could see each copy, and how you would remove it.

If you had to delete that tenant’s documents today, how sure would you be that you found them all?