..
•
OFFICIAL
~~
HSE
@HMRevenue
& Customs
Process Level Memorandum of Understanding
on Information Exchange
between
HM Revenue and Customs
Risk and Intelligence Directorate
Gateway Exchange Team
&
Health and Safety Executive
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Contents
Section
Title
1
2
3
Introduction
legal
Purpose of the agreement
Procedures
4
5
6.
7
Information Handling, Security and assurance
Responsibilities under the Data Protection Act 1998 and Human Rights
Act 1998
Subject Access and Freedom of Information
10
11
Monitoring and review arrangements
Issues disputes and resolution
Costs
Signatories to the Agreement
AnnexA
Annex B
Annex C
Annex 0
Annex E
HSE to HMRC Request form template
HMRC to HSE request form template
Document Control
Contacts
Glossary of Terms and Abbreviations
8
9
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1.
Introduction
HMRC - HM Revenue & Customs: Home Page was established in April 2005 by the
Commissioners for Revenue and Customs Act 2005 (,CRCA 2005'), merging the Inland Revenue
and HM Customs and Excise.
HMRC's functions are set out in sections 5 - 7, 9 and Schedule 1 of the CRCA 2005 and can be
summarised as all powers pertaining and ancillary to the collection and management of the
revenue and duties.
HMRC's purpose is to make sure that the money is available to fund the UK's public services.
HMRC also helps families and individuals with targeted financial support.
1.2
The Health and Safety Executive (HSE) is responsible for enforcing the Health and Safety at
Work etc. Act 1974 (HSWA) throughout Great Britain. Its job is to 'prevent people being killed ,
injured or made ill by work'. HSE: Information about health and safety at work
1.3
This Process Level MoU sits under the HMRC Umbrella MoU reference MoU-U-RR
1.4
A glossary of key terms and abbreviations can be found at Annex E.
2.
Legal
2.1.
Both organisations are legally obliged to handle personal information according to the
recuirements of Ihe Data Protection Act 1998 (DPA) and the Human Righls Act 1998 (HRA) .
2.2
HMRC may disclose information to the HSE using the legal gateway in section 19 of the Anti
Terrorism , Crime and Security Act 2001 (ATCSA). This allows HMRC to disclose information to
another law enforcement agency for the purposes of assisting criminal investigations or
proceedings, including for the purpose of determining whether investigations or proceedings
should be initiated or brought to an end. All disclosures must be proportionate and comply with
HMRC's Anti Terrorism Crime & Security Act 2001 : Code of Practice on the Disclosure of
Information, available from http://bit.lyl1f25Qry.
2.3
HSE may disclose information to HMRC using the legal gateway in section 17 of the Anti
Terrorism Crime and Security Act 2001 (ATCSA). Under that section, an investigating authority
may request information which was obtained by HSE for the purpose of assisting their criminal
investigations or proceedings (whether in the United Kingdom or abroad) , including whether
these investigations or proceedings should be initiated or brought to an end . Section 28(7)
HSWA has been amended by section 17(1) ATCSA to permit such disclosure.
2.4 .
HSE will use information supplied by HMRC for regulatory enforcement purposes, i.e. as part of
prosecution evidence. However, HSE undertakes not to supply information to any third party
unless required , or permitted , by law. Where not permitted/required by law HSE will seek
agreement wilh HMRC
2.5
HMRC will not disclose data supplied by HSE to any third party unless permitted or required by
law and will not make any such disclosure without prior agreement by HSE
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3.
Purpose of the agreement
3.1
This Memorandum of Understanding (MaU) sets out the agreement between HM
Revenue and Customs (HMRC) and the Health and Safety Executive that govems the exchange
of information under the Anti Terrorism Crime and Security Act 2001. It should be noted that
'exchange' covers all transfers of information between the two organisations.
3.2
Information will only be exchanged where it is lawful to do so. The relevant legal bases are
detailed within this agreement.
3.3
This MoU is not a contract nor is it legally binding. It does not in itself create lawful means for the
exchange of information; it simply documents the processes and procedures agreed between the
organisations. The agreement should not be interpreted as removing or reducing existing legal
obligations or responsibilities on each party , for example as data controllers under the Data
Protection Act.
3.4
HMRC and HSE both undertake to comply fully wilh the requirements of the OPA and the HRA
3.5
This MoU is not intended to create any legal rights enforceable by any third party or by either
party against each other.
4.
Procedures
Procedure for HSE to obtain Data from HMRC
4.1
Every request for disclosure of information must be made in writing (pdf via, secure
e-mail). A specimen request form is at Appendix A. Verbal requests will not be accepted.
4.2
Disclosures will be made on a case-by-case basis. Requests must therefore be for a specifically
named individual or company. Bulk requests and lists will not be accepted.
4.3
The request must contain details of the criminal investigation or criminal proceedings to which it
relates and specify the information required - e.g. current address , or details of income for a
stated year.
4 .4
Any HSE Inspector may make a request which must be authorised by the inspectors line
Manager or other senior manager. Authorisation is to be given only jf the authoriSing officer is
satisfied that the request is for the purpose of obtaining information to assist the HSE in a
criminal investigation and! or prosecution. The request must be submitted to HMRC via HSEs
appoinled Single Poinl of Contact (SPOC) officer.
4.5
HSE AuthoriSing Officers must be of at least Band 3 grade.
4.6
The HSE will provide HMRC wilh an up-to-date lisl of its appoinled SPOCs detailing:
Full name
Business address
Rank or grade
Official telephone number
Official e-mail address
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4.7
Requests should bear the appropriate Government Security Classification
https:/Iwww.gov.uklgovernmenUpublications/government-security-classifications
4.8
Requests for information must be sent only by one of the HSE SPoC officers to the Gateway
Exchange Team London. Requests must not be passed to any other officer of HMRC.
4.9
Each SPoC officer will consider if there are other avenues open to obtain the information in a
timely way. Only if this fails will HSE contact HMRC for the infonnation.
4.1 0
HMRC prefers requests to be sent by secure email. E-mail requests should include the
authorisation from the authorising officer in the e-mail chain and sent to:
[email protected]
4.11
E-mail requests using the GSI address should only be up to GSC Official.
4.12
HSE will only engage in postal requests in exceptional circumstances
4.13
Postal requests should be s double enveloped (e.g . the inner envelope should be marked
"Official" and sealed inside another envelope without a security marking on it and show a
return address in the event of non-<lelivery). The protective marking must be shown
prominently on the inner cover. They should be sent to:Gateway Exchange Team (London)
Custom House Annexe, First Floor
20 Lower Thames St
London
EC3R 6EE
Tel: 08707852296
4.14
Providing that the principles of the Code of Practice have been respected and GET is satisfied
that the request is for the purposes of a criminal investigationl prosecution it will normally
disclose the requested information to the full extent that HMRC holds that information. The
disclosure will always be proportionate to the purpose for which it was sought.
4.15
Any disclosure by HMRC will be made in writing or by secure electronic communication to the
Single Point of Contact or Requesting Officer (copied to the SPoC).
- 4.16
4.17
Spontaneous disclosures or proactive disclosures can be made without a request by either HSE
or HMRC were there are potential tax irregularities or health and safety breaches.
Spontaneous disclosures by HMRC to HSE are to be made to HSE at the following email
address: fod [email protected]
Procedure for HMRC to obtain Data from HSE
4.18
A specimen request form is at Annex B
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4 .19
The HSE will consider and, if appropriate, arrange for the disclosure of the requested information
HSE holds
4.20
Spontaneous disclosures from HSE to HMRC should be sent· preferably in 5)(5x5 format - to
[email protected]
If necessary contacting the Intelligence bureau for advice on 03000 521779
4.21
Requests for information may be sent by the HMRC SPoC officers only by post, fax or e-mail to
HSE at:
Health and Safety Executive
Legal and Enforcement Team
1.3 Redgrave Court
Merton Road , Bootie
Merseyside L20 7HS
Fax: 0151 951 3019
E-mail: fod [email protected]
4.22
The HSE SPeC officers in its Legal and Enforcement Team will consider and, if appropriate,
arrange for the disclosure of the requested information HSE holds
S.
Information Handling Security and Assurance
Both parties agree to :
•
Only use the information for purposes that are in accordance with the legal basis under
which they received it
•
•
Only hold the data while there is a business need to keep it
•
Store data received securely and in accordance with the prevailing central government
standards, for example in secure premises and on secure IT systems
•
Move, process and destroy data securely i. e. in line with HM Government Security Policy
Framework and in particular Security Policy 2: Security of Information, issued by the
Cabinet Office, when handling, transferring , staring, accessing or destroying information.
•
Comply with reporting requirements (e.g. reporting data losses or wrongful disclosure), in
line with the Cabinet Office Checklist for Managing Potential Loss of Data or Information .
Report any data losses, wrongful disclosures or breaches of security relating to
information originating in HMRC or HSE to the designated in Annex 0 contacts
immediately (within 24 hours of becoming aware). This includes both advising and
consulting with HMRC or HSE on the appropriate steps to take, e.g. notification to the
Information Commissioner's Office or dissemination of any information to the data
subjects.
•
Provide written , signed assurance that they have complied with these undertakings
regularly upon request
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Ensure that only people who have a genuine business need to see the data will have
access to it
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6.
Responsibilities under Data Protection Act (OPA) and Human Rights Act (HRA)
6 .1
HMRC and HSE are public authorities for the purposes of section 6 HRA It would be unlawful for
HMRC and HSE to act in a way that is incompatible with the European Convention on Human
Rights.
6.2
HMRC and HSE undertake to comply with the requirements of the DPA and HRA in carrying out
any of the actions described in this agreement.
6.3
HMRC is the data controller of any information it holds for the purposes of its functions, including
any information it acquires from HSE for the purposes of HMRC's functions under the
procedures set out iii this MOU .
6.4
HSE is the data controller of any information it holds for the purposes of its functions , including
any inform ation it acquires from HMRC for the purposes of those functions under the procedures
set out in this MoU .
7.
Subject Access & Freedom of Information (Fol) and Environmental Information
Regulations Act 2004 (EIR)
7.1
8.
If HMRC or HSE receives a Fol or EIR request involving information which originated from the
other, the receiving party will contact its central Fol team which will then liaise with the central
Fol team for the originator of the information to determine whether the originator wishes to claim
an exemption under the provisions of the DPA or FOI. The receiving party must be mindful of the
timeframe for response. If necessary the initial contact can be via the Contacts for this document.
Monitoring and Review Arrangements
8.1
This agreement will be formally reviewed at least annually.
8.2
The parties may agree to meet more frequently to resolve any matters or concerns arising out of
the operation of the MoU.
9.
Issues, Disputes and Resolution
9.1
Where a problem arises it should be reported, in writing , to the designated contacts (listed in
Annex D). The contacts will endeavour to resolve the problem within 2 working days.
9.2
Where it is not possible to resolve the issue within 2 working days or the issue is of such severity
that customers may be negatively affected, the issue will be escalated to the senior management
team for each partner. They will be notified with an explanation of why the dispute has not been
resolved so that they can take appropriate action for resolution or plan contingency
arrangements.
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9.3
Where the 'business as usual' channels fail to reach agreement, the organisations will attempt to
negotiate a settlement in the spirit of jOint resolution within 20 working days of a formal
notification being received .
9.4
Any issues regarding ongoing delivery aspects of the information supply, such as data integrity
or quality, should be addressed through 'business as usual' channels as detailed in Annex D.
9.5
If it is decided as a result of issues arising that changes to this agreement are required , a formal
change notification should be sent to the 'Data Exchange Coordinator'. External changes
affecting the operational delivery responsibilities of the organisations may also necessitate the
review and potential amendment of this agreement.
10.
Costs
10.1
HMRC will not charge the HSE for information requested under the arrangements in this MoU
unless the number of requests made per year ended April by the HSE exceeds 50. Should the
HSE make more than 50 requests HMRC may decide to charge an administration fee for all
requests made in that year, not just those over the 50. HMRC will ensure that HSE is advised
well in advance of this 50 limit being reached.
10.2
For these purposes each individual or company named on a request counts as a separate
request
10.3
HSE may charge HMRC for information requested under the arrangements in this MoU which
will be on a time and materials basis with charges based on HSEs average salary costs.
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11.
Signatories to this Agreement'
Date'1{6( ,<tKevin Myers
Acting Chief Executive, Health and safety Executive
.. ............
<-~~
-
..... ............. .... .
~/( /'\...(
Date..........
.
Euan Stewart
Risk & Intelligence Service, HM Revenue & Customs
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ANNEX A - HSE to HMRC Request Form
REQUEST FOR INFORMATION FROM HM REVENUE & CUSTOMS UNDER THE ANTITERRORISM CRIME AND SECURITY ACT 2001 ONLY.
(This form should NOT be used for CPIA Requests)
Protective Mar1<lng
Information Report
Witness Statement
Restricted
D
Confidential
D seeretD
Top Secret
D
Format of Reply Required (Tick Only One Box)
0
0
Requests for both go to GET London.
Email: [email protected]
We will aim to meet your key date as shown below. This may not always be achieved. so
please only use this facility in cases of urgency. We do need a date, do not just state urgent.
Please list any KEY dates (court dates or interview datas)
If required urgently please state the [lIi!l!QD
Disclosure Officers
Do not use this form .
Please make a CPIA reQuest.
Address:
Tel no (not
101i:
PNN/GSI
ATCSA Requesting
Officers Name:
Force/Agency:
E-mail address
If you have any speCific Informatton which would be of use to HM Revenue & Customs (tax avoidance,
fraud, MTIC, Smuggling etc) then please email this directly to the
HMRC Intelliaence Bureau ([email protected])
Legal person about whom information is sought:
A SEPARATE request is required for EACH legal entity (e.g. INDIVIDUAL and
COMPANY)
Full name:
Full address:
Date of birth:
National Insurance No:
Other relevant Information:
I.e previous addresses &
linked cases
State details of the criminal investigation or proceedings to which
request relates
These details must show how the INDIVIDUAL or COMPANY are linked
Nature of Enquiry:
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to the Investigation, stating the type of INVESTIGATION (Ie money
laundering/financial etc) and what CRIMINAL OFFENCE the legal person
named above is personally suspected of. tf this infonnation Is not
I Drovided, your request will be REJECTED
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Oporation Name (if relevant) :
Protective Marking
Restrtcted D
Confidential D
secretD Top Secret D
Information requested:
Please note that the exchange of information is not mandatory and only
information that is proportionate to the nature of your enquiry will be provided .
Information required From
to
(All replies will be made in tax years. A tax year begins on 6th April and ends on 5th
April i.e. 6"' April 2009 to 5th April 2010. Most of our databases only hold the last 6
tax year's information.)
If no timescale is provided the request will be rejected .
The list below Is not comprehensive of the Intannatlon held by HMRC. Please use the 'other'
box for infonnation you consider relevant to your Investigation that Is held by HMRC.
Please only tick the boxes that are relevant & proportionate to your enquiry/investigation.
Individuals
o
o
o
o
o
o
n
Latest Address & Current Employment
Private & Businesses addresses held
Declared Income (PAVE, Self - Employment & Other income shown on tax
returns, such as Land & Property & Capital Gains).
Tax Credits
Bank! Building SOCiety accounts and all other identifiable investments,
including Stamp Duty & Land Tax delails (only held for last 5 years)
Child Benefit Payments
VAT Registration delails
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o
VAT Returns/Payments State the Period Required (Only the last 3 years will
be supplied)
o
o
Telephone contact numbers
Agent/Accountants details
Other (please specify)
Companies
o
o
o
Company Tax Returns
VAT Registration detail ..
VAT Returns/Payments (State the Period Required)
Other (please specify}
Please give brief details to show that:
• the requested information cannot be obtained by other means or from other sources
• the requested information will be of substantial value to the investigation or proceedings
• lack of access to the requested information will oreiudice the investigation or proceedings.
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This form needs signing by an Authorising Officer.
For Police requests this is Inspector level or above.
For other law enforcement agencies this is Senior Officer or above.
If the request is sent eledronically then the Authorising Officer must show their approval of
Ihe request in the email chain sent to HMRC.
A list of Authorised Officers is held by the Single Point of Conted for your Force/Agency.
Name (print) .. ..•.•••. . .. ... .... ••..• ••• .. .....•
E-mail address
... .......... ....... ... ....
~
Ran k ................ .. ............... ... .........
Signature ............ .••........ •....... .. ......••.
Date ............................................. ...
Protective
Marking
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Restrided
0
Confidential
0
Secret
0
Top Secret
0
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ANNEX B HMRC to HSE Request Fonn Template
REQUEST FOR INFORMATION by HMRC From HEALTH AND SAFETY EXECUTIVE UNDER
THE ANTI-TERRORISM CRIME AND SECURITY ACT 2001
Protective Marking
Restricted D
Confidential D
Secret D
Topsecret D
Requests for information should be emailed to:
fod [email protected] .gov.uk
Please list any KEY dates (court dates or interview dates)
If required urgently please state the reason
Requesting
Officers
Name:
Authority
Tel no:
Fax No:
E-mail address
Address
Legal person about whom information is sought: A SEPARATE request is required for EACH
legal entity (e.g. INDIVIDUAL and COMPANY)
Name:
Address:
Other relevant
information as
appropriate
Nature of Enquiry:
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State details ofthe criminol investigation or proceedings to which request relates
These details must show how the individual or company are linked to the
investigation, and state what criminal offence they are suspected of.
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I
Please note that the
Information requested :
excha~ge
of information is not mandatory.
Only information that is proportionate to the nature of your enquiry will be provided .
Please provide full details of the information sought, explain why it is necessary and
whether you have taken any steps already to obtain the required Information.
Please give brief details to show that:
• the requested information cannot be obtained by other means or from other sources
• the requested information will be of substantial value to the investigation or proceedings
• lack of access to the requested information will prejudice the investigation or proceedings.
This form needs authorising by an SEO or above.
Name (print) .................................
Grade ...... ' ................... .... ........ .. . ' ...
Location .......................................
Signature ..........................................
Date ..... .. ....................... ..... ... .. .. ......
Please use this space to provide any Information which would be of use to Health and
Safety Executive. This Information may al80 be sent to HSE
Protective Marking
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Restricted D
Confidential D
secretD
TopsecretD
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An nex C Doc ument Control
Personnel
Key Personnel
Author
Approvers
Review Control
Name
Peter McCafferty
Organisation (Team)
HMRC
Steve Bridge
External Data Exchange Team I
Information Policy and Disclosure
Teaml RIS Data Guardian
FOD Legal and Enforcement Team
Peter McCafferty
HSE
HMRC
Wayne Crumpton
HSE
HSE
HMRC
Version History
Version
Date
Summary of changes
Changes
marked
0.1
2012
Initial draft
Yes
0.2
201 3
Minor amendments
No
0.3
Nov 2013
Incorporated comments from
Meeting
No
0.4
Dec 2014
Comments on charging updated
and minor presentation
No
0.4
Jan 2014
Comments from HSE Lawyers
No
Final version
No
1.0
Review dates
Version
Publication date
Review date
1.0
?
?
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Annex 0 - Contacts
Business As Usual
Contact details
Each party has nominated a Single Point of Contact (SPOC) •
The SP~C for HMRC is Paul Wright Gateway Exchange Team (Tel: 08707852220)
[email protected]
•
The SP~C for HSE is Steve Bridge, FOD Legal and Enforcement (Tel: 01519514971)
Email - [email protected]
Escalation
(i)
Escalation within HMRC
Initially - Peter McCafferty 03000564679
Email: _pete [email protected]
Central HMRC contacts are:
Contact
Dan Leonard ,
Security &
Information
Directorate
Central Policy
Information Pollcy &
Disclosure team
Inbox
External Data
Exchange team
Inbox
E-mail
Leonard , Dan (S&ID)
[email protected]
Responsibility
Security Incidents
ccp, disclosure (RP CCP London)
Legal issues
Data Exchange, Coordinator (IMS
Live Services)
[email protected]
EDE process and central
FOI team Inbox
Request, FOI (CenPollnformation
Policy and Disclosure)
fai .ren uestta>hmrc.n 5 i. nov .uk
Freedom of Infonnation
Requests
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cCl~ · disciosure@hmrc . gsi . gov . uk
database of MoUs
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(iil Escalation within HSE
Inilially - Wayne Crumpton
Email: wayne,[email protected],uk
Contact
Jonathon Sibley
E-mail
Responsibility
[email protected]
019() IT Security Officer
0190445 5790
Jayne Thorniley
[email protected]
HSE Data Protection Officer
and FOI requests
[email protected]
Legal and Enforcement issues
01519513355
Legal and
Enforcement Team
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Annex E Glossary of Terms and Abbreviations
Abbreviation
Description
CRCA
MoU
FolA
EIR
Fol
HMRC
PSB
5PF
ATCSA
CoP
The Commissioners for Revenue and Customs Act
Memorandum of Understanding
Freedom of Information Act
Environmental Information Regulations Act 2004
Freedom of Information
Her Majesty's Revenue and Customs
Public Sector Body
Security Policy Framework
Anti Terrorism Crime & Security Act 2001
Anti Terrorism Crime & Security Act 2001 : Gode of Practice on the
Oisclosure of InformationCommissioners for Revenue & Customs Act 2005
Data Protection Act 1998
Gatewav Exchan!le Team
H M Revenue & Customs
Human Rights Act 1998
Memorandum of Understanding
Health and Safety Executive
Single Point of Contact
CRCA
DPA
GET
HMRC
HRA
MoU
HSE
SPoC
Definition
Interpretation
" Data Controller"
has the meaning set out in section 1 of the Data Protection
Act 1998, i. e. 'a [natural or legal] person who (either alone or
jointly or in common with other persons) determines the
purposes for which and the manner in which any personal
data are, or are to be, processed '.
" Data Processor"
has the meaning set out in section 1 of the Data Protection
Act 1998, i.e. 'in relation to personal data, any [natural or
legal] person who processes the data on behalf of the data
controller' .
"Data Protection
Legislation"
means the Data Protection Act 1998, the EU Data Protection
Directive 95/461EC, the Regulation of Investigatory Powers
Act 2000, the Telecommunications (Lawful Business
Practice) (Interception of Communications) Regulations
2000 (51 2000/2699), the Electronic Communications Data
Protection Directive 2002lS8IEC, the Privacy and Electronic
Communications (EC Directive) Regulations 2003 and all
applicable laws and regulations relating to processing of
personal data and privacy, including where applicable the
guidance and codes of practice issued by the Information
Commissioner
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lIFolA"
means the Freedom of Information Act 2000 and any
subordinate legislation made under this Act together with
any guidance and/or codes of practice issued by the
Information Commissioner or relevant Government
Department in relation to such legislation
"Law"
means any applicable law, statute, bye ~ law, regulation ,
order, regulatory policy, guidance or industry code , rule of
court or directives or requirements of any Regulatory Body,
delegated or subordinate legislation or notice of any
Regulatory Body
"Ad Hoc Transfer"
Is defined as being bulk data with a protective marking of
restricted or above and the transfer is part of a pilot or
project with a definitive end date.
" Regulatory Bodies"
means those government departments and regulatory
statutory and other entities , committees and bodies which,
whether under statute, rules, regulations, codes of practice
or otherwise , are entitled to regulate, investigate, or
influence matters dealt with in this Agreement and
"Regulatory 80dy~ shall be construed accordingly
Mpublic sector bodY-
Th is will generally be another government department
(OGD) but could be another public sector body (e.g. Local
Authority) . Information sharing with a private sector body
needs to be covered by a commercial contract, not an MoU.
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