TC09667 - [2025] UKFTT 01254 (TC)

Len Lothian’s records show an address for Chelsea Kelly at 136 [LA], Glasgow. They also show two mobile phone numbers, one labelled “Kami”. An email address is for “[email protected]”. Their records show that invoices were emailed to this address. Len Lothian also communicated with the customer via text message.

Len Lothian’s system does not contain photographic ID or a date of birth for Ms Kelly. Mr Lothian suggested that photo and other ID had been deleted in accordance with GDPR after the contract ended, which would have been in accordance with Len Lothian’s usual policies. Mr Lees confirmed that no photo ID was held and that he had checked the system at the time of the seizure. We infer that no photo ID was ever taken in this case, despite it being the policy to take photo ID. If photo ID had been taken with a driving licence, we think it likely Chelsea Kelly’s date of birth would have been recorded. We therefore infer that photo ID was never taken.