Customer contact and data security: contact with third parties: outbound calls to third parties
Where possible, before making a call to a third party you must firstly check that you have authorisation to speak to someone other than the customer.
Verbal consent in advance for non authorised third parties
You may get a situation where a customer calls to ask if you will phone a nominated third party to speak about their tax affairs. If you are faced with this situation you should treat this as if they are giving you advanced verbal consent. You should
- verify the customer and record the date the consent was given
- record the name of the person they have asked you to call and their relationship with that person.
- tell them that the need to make sure the third party is aware that they will shortly receive a call
- make it clear that this is only permitted for a one off telephone conversation.
- Ask for the customers telephone number in case of any difficulties.
You can then make the call to the third party as requested.
If, when you call the third party, the third party has no knowledge that the customer has given verbal consent then you should not continue with the call as you may be disclosing information to the wrong person. Instead you should write/call the customer telling them that you have not been able to complete their request.
Authorised third parties
If you are calling an authorised third party you should check the details of the authority prior to making the call to check that there are no limitations on what you can and can’t discuss and that you are speaking to the correct person.
If you are phoning an agent or accountant you must firstly check that there is a 64-8 on record and for all other authorised third parties check that there is a record of the signed written authority on the notes.
Third party answers the phone
If you are making an outbound call and an unauthorised third party answer you should be careful not to disclose anything and you should leave a message for the customer saying you are calling from HMRC and ask them to call back quoting their reference number (quote the appropriate reference number however you must never disclose a NINO).
When calling a company you need to be clear that you are speaking to an authorised person of that company or a nominated third party who represents that company - normally a member of staff like a wages clerk, cheque signatory or payroll officer. For full details on this see DMBM512300.
If you are trying to trace a customer, occasionally you will need to call or speak to a third party in order for you to locate the customer, for example this may be a previous agent/accountant or an ex partner/relative and so on. In these situations you should follow the guidance at DMBM511850.