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Compliance evidence that holds up: timestamp, location, and the device it belongs to

By Dean Griffiths ·

In short

Compliance evidence that holds up has to be captured at source, inside the app rather than imported from a camera roll. It has to be stamped with time and location, and bound to the property and the device that captured it. When an item does not apply, the record has to say why. A tick in a spreadsheet meets none of these tests.

The difference between a record and evidence

A record says something happened. Evidence shows it.

A tick in a spreadsheet next to "smoke alarms tested" is a record. It proves that someone intended to check, or said they did. It does not prove that the check happened, when it happened, or where.

When everything goes well, nobody looks closely and the difference does not matter. It matters when something goes wrong: an inspection, a dispute with a tenant, a complaint, a claim. At that point, whoever is asking is not interested in what your spreadsheet says. They want to know what you can show.

Most compliance systems are built to produce records. The question this guide answers is what it takes to produce evidence.

Three properties of evidence that survives

Evidence that stands up has three properties. Miss any one and the rest are weakened.

1. Captured at source

The photo, clip or reading is captured inside the app at the moment of the check. It is not taken on a phone camera and imported later. Capture at source closes the gap between the event and the record of it.

2. Stamped with time and location

Each item carries the time it was captured and where. That is what connects the evidence to the rule. A smoke alarm test has to happen on the day the tenancy starts; a timestamp is how you show it did.

3. Bound to the property and the device

The evidence belongs to one property and to the individual device that captured it. It cannot be quietly reused for a different address, and it is clear which device produced it.

Why importing from a camera roll fails

Importing from a camera roll is the most common way a good check turns into weak evidence.

The engineer or inspector takes photos on their phone during the visit. Later, at a desk, they choose the ones that look right and upload them. By then, the link between the photo and the visit is only someone's say-so. Was this taken today, or at last year's visit? At this property, or the identical one next door? The file cannot answer, and the upload date does not help.

Nothing dishonest needs to have happened for this to fail. It fails because the evidence was separated from the event and put back together by hand.

"Not applicable" with and without a reason

Plenty of checks genuinely do not apply. A property with no gas or LPG appliance needs no gas safety check. A room with no fixed combustion appliance needs no CO alarm. A storage-only loft is not a storey with living accommodation, so it needs no smoke alarm.

"Not applicable" is a correct answer only when it carries a reason. A checklist that lets someone tick NA with no reason cannot survive an inspection, because NA without a reason looks exactly like a check that was skipped.

  • Weak: "Gas safety: NA."
  • Strong: "Gas safety: not required. No gas or LPG appliance; all-electric heating and hob."

What actually goes wrong: the four-month-old photo, the untested alarm, the missing device

The four-month-old photo

A photo of a smoke alarm is attached to this month's check. Its date says it was taken four months ago, at the previous visit. The alarm may still be there and may still work, but the evidence for this check is now from a different visit.

The untested alarm

The record shows a photo of the alarm on the ceiling. It does not show the button being pressed or the sounder going off. An alarm being present is not the same as an alarm being tested. The smoke and CO alarm guide covers what a proper test record contains.

The missing device

Evidence was uploaded through a shared login, from an unknown phone. Nobody can say who captured it or on what device. If it is challenged, there is nothing to stand behind it.

A practical evidence standard to adopt

If you adopt one standard across a portfolio, make it this. Every check produces an item that is:

  1. Captured in the app at the time of the check, not imported.
  2. Stamped with the time and location of capture.
  3. Bound to the property and the device that captured it.
  4. Specific to the obligation: per storey for smoke alarms, per room with a fixed combustion appliance for CO alarms.
  5. Recorded with a reason wherever an item does not apply.
  6. Recorded with the result, including failures and what happened next.

Evidence built this way survives export, printing and dispute, because what it shows was fixed at capture rather than added afterwards.

Rolling it out

Start with the checks most likely to be questioned: smoke and CO alarm tests on the day a tenancy starts, because they have to happen on a known day. Then move to inspections, then to anything recorded on a paper sheet today.

Do not try to rebuild old evidence to the new standard. Records from before the change are what they are. The standard applies from the day you adopt it, and the gap closes as each check comes round again.

Where this sits in a portfolio of 150

Take a portfolio of 150 properties with 9 checks each. That is 1,350 obligations a year before renewals, repairs and inspections are added.

At that scale, evidence quality is not a question of how careful each person is. It is a data problem, not a diligence problem. If the system allows camera-roll imports, NA without reasons and shared logins, some share of those 1,350 items will be weak, and nobody will know which until one is challenged.

If the system enforces capture at source, stamping, binding and reasons, every item meets the standard by default. That is the design behind our property compliance work.

Common questions on this topic

A photo can be enough if it was captured at source, stamped with time and location, and bound to the property and the device that took it. A photo pulled from a camera roll days later, with no reliable time or place attached, shows that an object exists. It does not show when or where the check happened.

The rule in England is that smoke and CO alarms are tested on the day a new tenancy starts. It requires a test, not a format. But a test is a sound, and a still photo cannot capture a sounder. A short clip captured in an app, showing the button pressed and the alarm sounding, is the simplest way to show the test actually happened.

Evidence captured inside a home can include people, belongings and location data, so it can be personal data. This guide will not set out a compliance position for you. Check current official guidance from GOV.UK and the Information Commissioner's Office, capture only what the check needs, and keep it secure.

This guide will not invent a retention period. Certificates run on cycles of 1, 5 and 10 years, and an EPC cost cap exemption lasts 10 years, so evidence often needs to outlive the check it records. Check current GOV.UK guidance for the duty in question, and set a retention rule per evidence type.

Evidence supplied by a tenant can be useful context, but it fails the same tests as any other imported file unless it was captured at source, stamped, and bound to the property. Where the duty is yours, treat tenant-supplied material as a prompt to check, not as the check itself.

Exactly like a passed one, with the result recorded honestly: the item, the time, the location, the device, what failed, and what happens next. A failed alarm test followed by a dated replacement and a passed retest is a strong record. A failed check that was never recorded is the weak one.

Still have a question? Book a Discovery Call, direct line to me, Dean.

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