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HMRC internal manual

Compliance Handbook

How to do a compliance check: establishing the facts: covert surveillance: levels of covert activity

There are three levels of covert activity:

  • basic fact check: no authorisation needed
  • covert surveillance to observe business activity: authorised officer agreement needed 
  • directed surveillance likely to result in obtaining private information about a person: authorised officer agreement and Directed Surveillance Authority (DSA) needed.

Basic fact check - not surveillance

A single walk or drive by of a business premises to make simple observations. Perhaps to establish the size of a unit, to see if the business is trading, see the external condition of a shop, or obtain details from shop signage. During this you must not engage with people or third parties.

Covert surveillance to observe business activity

  • Repeated walk by, drive by or visit to a business to monitor, for example, opening times
  • Test purchases
  • Test eats
  • Observing cash handling procedures
  • Counting staff and customers
  • Observing how customers pay.  

Directed surveillance

  • Taking descriptions
  • Recording conversations
  • Monitoring a person’s movements and activities.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)