Policy paper

HMRC Records and Information Collection Policy

Published 19 May 2026

Introduction

This policy forms part of a series of overarching policies, schedules and reports governing records management within HMRC.

The HMRC Records management and retention and disposal policy sets out HMRC’s commitment to the efficient management of our records for the effective delivery of our services, to document our principle activities and to maintain the corporate memory.

This Records and Information Collection Policy aims to guide all employees to the effective selection of records for permanent preservation, continued retention or permanent disposal and should be read in conjunction with the following HMRC policies, schedules and reports:

• Records Management and Retention and Disposal Policy (published internally and externally)
• Business Area Records Retention and Disposal Schedules (internal only)
• Business Area Appraisal Reports (internal only)

Further information is also provided within this policy where reference to regulatory frameworks, such as the Freedom of Information Act 2000, Public Records Act 1958, Data Protection Act 2018, (the UK’s implementation of the General Data Protection Regulation), and the Code of Practice on the Management of Records issued under section 46 of the Freedom of Information Act 2000, is required, to ensure business areas make informed, accurate decisions about the ongoing management of records within HMRC, once they have reached the end of their business use.

This policy is format neutral, and applies to paper, digital, hybrid and any other record formats (see Policy Scope).

What is a Record and Records Management?

Records are defined as information created, received and maintained as evidence and information by an organisation or person, in pursuance of legal obligations or in the transaction of business (ISO 15489-1:2016 Information and documentation — Records management — Part 1: Concepts and principles).

HMRC creates records in the day-to-day management of its services to provide information about what happened, what was decided, and how to do things. These records are a valuable resource because of the information they contain. High-quality information underpins the delivery of high-quality evidence-based management of HMRC’s services and information has most value when it is accurate, up-to-date and accessible when it is needed.

Further detail and the definition of a record for HMRC purposes is available to all staff and as part of HMRC’s internal ‘What is a Record?’ guidance.

Records management is the ‘field of management responsible for the efficient and systemic control of the creation, receipt, maintenance, use and disposition of records’ (ISO 15489-1:2016 Information and documentation — Records management — Part 1: Concepts and principles)

This includes identifying, classifying, storing, securing, retrieving, tracking, and destroying or permanently preserving records. The benefits of effective records management are:

• protecting our business-critical records and improving business resilience
• ensuring our information can be found and retrieved quickly and efficiently
• complying with legal and regulatory requirements
• reducing risk for litigation, audit and other investigations
• minimising storage requirements and reducing costs

The selection of records, once they reach the end of their business use, form part of the effective records management lifecycle.

Regulatory Landscape

This policy has been endorsed by Board Level Management and is aligned with the Lord Chancellor’s Code of Practice on the management of records issued under section 46 of the Freedom of Information Act 2000. The department is obliged to meet the legal requirements for the retention and disposal of records in accordance with relevant legislation, particularly the Public Records Act 1958 (PRA 1958), the Freedom of Information Act 2000 (FOIA 2000) and the Data Protection Act 2018 (DPA 2018) (the UK’s implementation of the General Data Protection Regulation (GDPR).

The Freedom of Information Act 2000 creates a right of access to official information and places a duty on public authorities to publish information in line with publication schemes.

FOIA amends the Public Records Act 1958 and places obligations on public authorities to maintain their records in line with the provisions of a Code of Practice on the Management of Records issued under section 46 of the Freedom of Information Act 2000. The code provides guidance to public authorities ‘in connection with the keeping, management and disposal of their records’ as well as the review and transfer of records to public archives’.

Additionally, the Data Protection Act 2018 (DPA 2018) (the UK’s implementation of the General Data Protection Regulation (GDPR), governs the processing of personal information and data, for example the Act states that personal information should not be kept for longer than it is needed. There are however exemptions to this, so when determining the correct course of action with records, you must assess whether it falls under the DPA or GDPR 2018, for example, it contains personal information. Exemptions allow for personal data to be kept for longer if it is for public interest archiving, scientific or historical research or statistical purposes.

HMRC therefore has an obligation to keep records required for business, regulatory, legal and accountability purposes, all of which must be considered by business areas when making decisions about such records.

Policy Scope

This policy relates to records and information created by HMRC which is held in all formats and media, including but not limited to, the following:

• tax and valuation office data, both digital and paper and all associated activities where tax and valuation office data is created or received
• documents, presentations and spreadsheets stored digitally
• analysis reports
• paper based files
• social media, Viva Engage (formerly Yammer), wikis, Facebook, blogs, LinkedIn posts
• emails where they relate to business cases and transactions, excluding emails containing non-work-related discussions between staff
• diaries
• faxes
• brochures and reports
• HMRC internet and intranet pages
• forms
• evidence supplied by third parties
• information created by third parties on HMRCs behalf
• audio and video recordings
• map and plans
• photographs
• microfiche and microfilm
• any digital platform used to store and manage business related information across the HMRC estate

The principles outlined in this policy have been developed to provide a consistent approach throughout HMRC as to the type of records to select and the decisions required by business areas once the record reaches the end of its business use (as detailed in the HMRC Records management and retention and disposal policy).

Roles and Responsibilities

Business areas are responsible for maintaining and publishing their own records Retention and Disposal Schedules. These schedules will determine the duration the record should be retained and the subsequent action thereafter, such as, permanent preservation, continued retention, or permanent disposal.

Business areas must develop and maintain their own Appraisal Reports to identify groups or series of key departmental records which are required for ongoing administrative, legal or fiscal purposes. The report will act as the basis for appraising records that have short, medium and long-term value and for developing detailed business area Retention and Disposal Schedules. Each business area should have an Appraisal Report, which is to be signed off by the Departmental Records Officer. It is mandatory for each business area to publish a high-level Appraisal Report internally.

Business areas must review the retention periods of their records annually and in line with their Retention and Disposal Schedule and assess the records to determine which have reached the end of their retention period and as such require action.

Once it is known which records have reached the end of their retention period, business areas, in line with this Records and Information Collection Policy, can determine whether such records require permanent preservation, continued retention or permanent disposal.

Website capture is a requirement of all government departments which utilise internet websites for publications and public information. HMRC’s website capture is managed by the HMRC Communications and Guidance team. The web capture process happens automatically through The National Archives (TNA) process, and HMRC does not interact with or influence the process on a regular basis. However, the exception is when HMRC must intervene and ask that specific pages are not captured, mainly in cases where HMRC uses GOV.UK to name individuals or companies — for example, the tax avoidance scheme promoters list — where legislation allows HMRC to publicly name people and stipulates how long individuals’ names can be online before they must be taken down. In these instances, HMRC has a duty not only to remove names from the live GOV.UK site, but also the archives. This is essentially an exemption process, as TNA’s default position is that everything on GOV.UK is archived.

Selecting the types of records for permanent preservation

The following guidelines should be used by each business area to determine the type of record requiring permanent preservation at TNA.

HMRC and its business areas must select records of historical value and enduring public interest and place them under the supervision and guidance of the Keeper of Public Records at TNA, in line with TNA’s Records Collection Policy 2022.

Public records can exist in any format, including paper, digital, audio, film or model format. They may be in any medium, including social media channels and they may have originated in private email accounts, not only in HMRC’s own systems.

The fact that it may not be possible to allow public access to some records for many years does not prevent their selection for permanent preservation.

Criteria for selecting records for permanent preservation

Some of the information HMRC creates and the records it keeps may be of historical interest in the future. HMRC has a legal requirement under the Public Records Act to transfer records of historic interest to TNA, within 20 years from the date the record was closed or last viewed/modified. This ‘20-year rule’ period changed from 30 years, and to manage this change the transfer of records was phased in over ten years from 2013 to 2023. TNA’s Records Collection Policy sets out an overview of this transitional change (section 5.1).

The criteria below and contained within this policy will help each business area identify the type of records which have potential historic value. At a high level, TNA acquire for preservation, records that document:

• the principal policies and actions of the UK central government and English and Welsh government
• the structures and decision-making processes in government
• the state’s interaction with the lives of its citizens
• the state’s interaction with the physical environment
• records that must always be selected

This type of information is normally found in policy records. Casework records will not usually be of any historical interest. It is assumed that casework documentation that has significantly influenced policy has been kept as part of the policy record, as they may be the only evidence of the reason for the change in policy. However, some casework records might relate to ‘notable events’ and need to be considered.

Identifying records that have potential historic interest

To help identify records deemed appropriate for permanent preservation, The National Archives set guiding principles around selecting and appraising records.

TNA seeks to collect and preserve public records that document and meet the criteria highlighted in this section the policy.

To support this process and in relation to TNA’s Records Collection Policy, a number of Operational Selection Policies (OSPs) should be used by public sector bodies to help identify records of historical importance.

To support its openness and accountability, HMRC has published a High-level Appraisal Methodology, an external document which provides a summary of the roles and responsibilities of HMRC as a government department, in relation to its selection and appraisal of public records.

HMRC has internal guidance pages available to staff, around ‘Selecting your Records’. A list of OSPs has been developed, based on TNA’s OSPs. This enables business areas to identify which HMRC OSP relates to the corresponding TNA OSP.

For HMRC, records that document the following should be considered for permanent preservation:

• Government and People: The interaction of the State with the citizen as documented in electronic case files and datasets (OSP1) (TNA OSP30)
• Board and Committee records (OSP2) (TNA OSP35)
• Publications/Grey literature (OSP3) (TNA OSP36)
• Freedom of Information Act records (covering Data Protection Act and Environmental Information Regulations records) (OSP4) (TNA OSP37)
• Records of Internal Administration – Policy records of government housekeeping functions covering personnel, organisation, financial management, industrial relations, procurement, property management and information technology (OSP5) (TNA OSP38)
• Records of UK government involvement in the development and implementation of European Community secondary legislation (OSP6) (TNA OSP 44)
• Case files (OSP7) (TNA OSP48)
• Records of the central direction and oversight of government policy programmes 1970 – 2000 (OSP8) (TNA OSP12)
• Machinery of Government (MoG) and the management the Civil Services Mart 1974 - 2000 (OSP9) (TNA OSP24)

Generic records selection criteria

A set of generic records selection criteria has been developed to provide general guidance on the types of records that should be permanently preserved and should be used to develop justifications for selection.

The principal policies and action UK government (HMRC)

• records of policy decisions that had a significant impact on UK or international events and conditions where department was the lead (for example, foreign policy, policing, asylum and other legal cases, deployment of troops, setting the budget, intervention on foreign exchanges)
• records that show the development of primary legislation where department is the lead (for example, work on White or Green papers, Bills, Acts, notes on clauses, policy working groups or committees)
• records that show the development of secondary legislation where department was the lead (for example, work on statutory instruments)
• key records that illustrate how legislation was implemented where department was the lead
• records of decisions that affect the way an organisation conducts its core functions (for example, decisions that set a precedent or had an impact on wider political developments)
• records of projects that were particularly innovative, or were significant from the perspective of cost, risk or impact (for example, Millennium Dome project and project to build the new British Library)

The structures and decision-making process in UK government (HMRC)

• high-level governance records (for example, agendas, minutes and papers of Cabinet Committees, management boards, key committees, ministerial committees) — see TNA OSP35 — Board and Committee records
• records that show dissolution, creation, merger of departments, agencies, (for example recent machinery of government changes under the programme to reform public bodies in 2010/11) — see TNA OSP24 - machinery of Government changes and the management of the Civil Service Mart 1974 to 2000
• records that illustrate how a body or function was privatised/nationalised (for example, privatisation of British Rail)
• records (for example, evidence, transcripts, reports) of tribunals, commissions, inquiries or inquests that were of particular public interest or had a significant impact on policy or process
• constitutional relationships (for example, government relationship with devolved administrations)
• records of discussions/actions where there was involvement of secretary of state/minister (unless they are non-public records such as party political and constituency records — see TNA OSP12 on the central direction and oversight of government policy for a specific time period as an example)
• records reflecting the creation/development of key departmental function/structure

The state’s (HMRC’s) interaction with the lives of its citizens

• aggregated data which provides extensive information on individuals or groups (see TNA OSP30) on interaction between the state and the citizen), places or organisations (case files or datasets, for example, Census records)
• records that illustrate a significant event/person/group which lead to a change in policy, set a precedent or caused controversy and add to what is already known - see TNA OSP48 on case files (for example, a legal case that set a precedent around how a particular law was applied in practice)
• websites of UK Government departments – see Roles and Responsibilities para 23 for further detail

The state’s (HMRC’s) interaction with the physical environment

• records which document the impact of policies/proposals on the natural environment (for example, impact of decision to build a nuclear power station on the surrounding area)
• records of significant events (natural/man-made) which lead to a change in policy, or set a precedent (for example, foot and mouth crisis)
• key records that establish or re-affirm UK Crown responsibilities (property and major assets) (for example, OS maps, Thames Barrier, Channel Tunnel, Olympic venues)

Records that should always be selected

• any record created earlier than 1660 (a requirement of the Public Records Act 1958)
• papers cited in or noted as consulted in the preparation of Cabinet Office official histories

Key or notable events

A key or notable event is one that may be of historical interest in the future. In HMRC these may include high impact policy and legislation changes, trends in major issues that lead to policy/procedural changes, the alteration or creation of a major function or judgements/rulings that have had a major impact on people or groups outside HMRC. It is the responsibility of the business areas to identify and retain all records of all events that may be regarded as notable. Each year the Departmental Records Officer (DRO) will ask business areas to review the TNA Transfer list to ensure that it accurately contains any notable events, all the relevant information has been captured and confirm that you have and can retrieve all the relevant records when requested.

Datasets

Collections of information are often loosely referred to as a dataset as defined by TNA in the Records Collection Policy – section 3.2.

For the purposes of this policy, it refers to digital data that has been organised, usually in tabular form, that can be analysed in a number of ways by the user — for example by sorting, filtering, or combining with data in other tables — and that can be displayed in a variety of ways such as charts, graphs, and maps.

Although this collection policy is format-neutral, there are particular criteria that apply to the collection of government datasets (though datasets may also be collected under all criteria listed in this policy).

Many datasets are the results of HMRC’s endeavours to collect information about the state of the country, in its social, physical and political environments. This information is collected by measuring, mapping, conducting surveys and censuses, and combining the raw data obtained from these processes into structured digital formats such as relational datasets, or geographical information systems. HMRC may also create datasets as part of its own administrative processes, most often in the form of digital case files.

As datasets can be subjected to repeated statistical or scientific analysis, they are particularly capable of enriching the collection outcomes set out in this policy.

Where possible TNA will collect the data in a machine-readable format as close to its raw state as possible, after the data has been validated. So that it can continue to be interpreted and used in the future, TNA will collect contextual information about why and how the data was created and how it could be used alongside the raw data.

The physical condition of records

The National Archives has the right to refuse records which are in an extremely poor state of repair as indicated in TNA’s Records Collection Policy – see section 3.3. Records which are badly damaged present costly challenges for ongoing preservation and presentation. This includes paper records where value is compromised by being, for example, badly torn, smudged, water-damaged or burnt. Usability may also be a factor influencing selection of digital records which are corrupt or cannot be read. TNA may also be unable to accept transfers of some other material including microfiche (unless digitised) or artefacts. These issues will be assessed on a case-by-case basis, it is therefore imperative that business areas assess the physical condition during the appraisal process.

TNA hosts a suite of guidance around ‘Digital Continuity’ – how to ensure records, information, data and documents remain accessible as technology evolves.

Records which will not be collected

Records that do not have enduring historical value (such as internal administration, routine case files or temporary papers) will not be collected by TNA.

Some records may have been collected or duplicated elsewhere such as in parliamentary papers or may have already been captured by TNA in the UK Government Web Archive. Therefore, TNA will not seek to acquire duplicated collections.

Next steps

Once the ‘type’ of record for permanent preservation has been identified, the business areas should next refer to their respective Appraisal Report. This will direct the process of examining, at the appropriate time, the content of each record to further determine whether or not it is worthy of archival preservation, whether they need to be retained for a longer period, or whether they should be destroyed.

Selecting the type of records requiring continued retention

When business areas are undertaking the appraisal and selection of records, it is important to consider how long records should be retained for, particularly for those records that fall outside of HMRC’s generic 6+1 years retention period.

Continued retention of records

The type of records that can be retained beyond the default HMRC retention period is those records where continued retention can be justified for statutory, regulatory, legal or security reasons or for their historic value.

Information held for longer than is necessary carries additional risk and cost. Records and information should only be retained when there is a business need to do so. Under DPA 2018 (UK GDPR), personal data processed by HMRC must not be retained for longer than is necessary for its lawful purpose.

The default standard retention period for HMRC records is 6 years plus current, otherwise known as 6 years + 1. This is defined as 6 years after the last entry in a record followed by first review or destruction to be carried out in the additional current (+ 1) accounting year. This is reflected in HMRC’s Records management and retention and disposal policy.

The maximum retention period for HMRC records identified as having historic value is defined as 20 years after the last entry in the record, with an additional one calendar year for final review and transfer or disposal.

For further information about storage limitation refer to the Information Commissioner’s Office guidelines on storage limitation.

Records involved in investigations, inquiries, litigation and legal holds

A legal hold, also known as a litigation hold, document hold, hold order or preservation order is an instruction directing employees to preserve (and refrain from destroying or modifying) certain records and information (both paper and electronic) that may be relevant to the subject matter of a pending or anticipated lawsuit, investigation or inquiry.

HMRC (and therefore business areas) have a duty to preserve relevant information when a lawsuit, investigation or inquiry is reasonably anticipated.  Employees must immediately notify the assigned Departmental Records Officer (DRO) if they have been notified of a litigation, investigation or inquiry or have reasonable foresight of a future litigation, investigation or inquiry as this could result in records being held beyond their identified retention period.

The legal hold decision will be determined by Senior Management. When a legal hold is terminated, records previously covered by the legal hold should be retained in accordance with the applicable retention period under HMRC’s Records management and retention and disposal policy without regard to the legal hold and retained non-records or records not previously subject to retention may be destroyed.

Processes for continued record retention

Information held for longer than is necessary carries additional risk and cost. Records and information should only be retained when there is a business need to do so and furthermore, under DPA 2018 (UK GDPR), personal data processed by HMRC must not be retained for longer than is necessary for its lawful purpose. This is reflected in the Code of Practice on the management of records issued under section 46 of FOI 2000.

The default standard retention period for HMRC records is 6 years plus current, otherwise known as 6 years + 1. This is defined as 6 years after the last entry in a record followed by first review or destruction to be carried out in the additional current (+ 1) accounting year.

Records must only be retained beyond the default HMRC retention period if their retention can be justified for statutory, regulatory, legal or security reasons or for their historic value. The disposal periods for records retained for extended duration must be included within business areas records Retention and Disposal Schedule.

As described earlier in this policy, the maximum retention period for HMRC records identified as having historic value is defined as 20 years after the last entry in the record, with an additional one calendar year for final review and transfer or destruction. Please refer to the Records management and retention and disposal policy for further detail. However, depending on the function of a business area and types of records created, longer retention may be required. HMRC’s business areas refer to bespoke retention and disposal schedules which apply to the information and records created by the business area in carrying out its functions.

Guidelines determining types of records which require permanent destruction or deletion

To determine which records, require destruction at the end of their retention period, reference should be made to the HMRC Records management and retention and disposal policy and the individual business area’s records retention and disposal schedule.

In most cases, it will be appropriate to destroy records immediately once their retention period has been reached, unless they have been selected for transfer under the Public Records Act 1958 or are subject to pending audit, litigation or investigation. As such, only those records which have not been selected for permanent preservation nor continued retention should be selected for permanent disposal.

As referenced in the business area records retention and disposal schedule, it is important to keep accurate records of disposal and appraisal decisions. Disposal implies a permanent action.

For digital records, ‘disposal’ may be reversed and may not meet the standard as the information can/may be able to be recovered or reversed. Records must be securely disposed of in accordance with the departmental security policies and measures must be in place to ensure that all backups and copies are included in the disposal of records, or that data is put beyond further use. TNA provide guidance around the disposal of records.

Where records have been downloaded as a copy from a system, it is the user’s responsibility to delete and dispose the downloaded copy version as soon as its business use has ended (the reason why the record had to be downloaded). It is also the user’s responsibility to ensure the download has been deleted from all folders, for example OneDrive folders. This helps avoid duplicate versions of the same record existing and reduces risks around HMRC holding onto records (in the form of a copy) beyond its remit to do so.

To help track disposals and destructions, a destruction log template is available for business areas to utilise.