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HMRC internal manual

Compliance Operational Guidance

Supporting Guidance: business records checks: BRC officer’s notebook: reducing data security risks of notebooks

Note: For the purpose of this guidance, a page is both sides of a sheet of paper.

In order to reduce the risks associated with data security and optimise their evidential value, managers should make sure:

  • they record the issue, retention and destruction date of assurance notebooks used by their team to record details of Business Records Checks (BRCs)
  • they put in place comprehensive management checks to make sure that the process for the issue of the notebooks, recording of the information and retention of the notebooks when complete is followed by all caseworkers
  • Visiting Officers (VOs) use a standard notebook containing no more than 100 pages or individual sheets of paper so that the number of customers covered in any single notebook is reduced when they record details of a number of checks in one notebook
  • notebooks are kept for the required period of 6 years from the date of the last entry and the destroyed unless the records are likely to be required for disclosure purposes or as evidence at a tribunal(This content has been withheld because of exemptions in the Freedom of Information Act 2000)  Notebooks retention schedule.
  • the destruction date is marked clearly on the front of the notebook
  • notebooks are stored securely in a way that makes it easy for VOs to retrieve the notebooks where they are required for disclosure purposes or as evidence at a tribunal.

In addition to the above, VOs must withdraw notebooks from use one year after the date of the first entry, except in the following circumstances:

  • the notebook contains entries relating to an ongoing compliance check. You must continue to use the same notebook until your check has been completed.

Any new compliance checks must be recorded in a new notebook.