Customer contact and data security: contact with third parties: agents and accountants: checking for the 64-8
Authority in 64-8
When an agent contacts you, you should take the reference number and inform the caller that you will just check the record for their authority. You should firstly check the agent’s details on IDMS (as the parent system), by:
- opening Taxpayer Designatory Data
- select tab ‘Other Addresses’
- select ‘Agent’.
From here you should verify the agent’s details and take them through caller verification checks (see DMBM512800), checking that the information the agent gives you matches with the information on screen.
If you cannot see any agent’s details, then check the head of duty system relevant to the tax the agent is calling in respect of. You do not, however, need to check every head of duty system to establish if a 64-8 authority exists and what it covers. If you still cannot locate the information, then you should ask the agent if they have submitted a 64-8 then refer to the ‘Agent says they have already submitted a 64-8’ section below.
Agent/accountant information matches
If, after checking the details we have on record, the agent successfully passes all the verification questions, you can proceed as normal.
Note: If at any point the agent/accountant says that they no longer work for the company of whom we hold authority, you should advise them that we can no longer continue with the call as they are not authorised to discuss the details. You should advise that another representative of the company should phone instead to discuss the customer’s tax affairs.
Agent /accountant gives different information to what we have on screen
If the agent gives different details to what we have on screen you should firstly check the other HoD to see if you can find any note of the agent authority acting on behalf of the customer, if you are still unable to find anything you should advise the caller that:
- you are unable to find the suitable authority for them
- they should submit a 64-8 either on line or in paper form to the CAAT team (see DMBM511910).
Agent says they have already submitted a 64-8
If an agent states that they act for an existing customer but you cannot find the details on the record, a faxed copy of form 64-8 can be accepted if supported by either:
- copies of previous correspondence between the agent and HMRC about the customers affairs
- notes on the customer’s records (e-notes on IDMS, SA, EF, COTAX etc.) clearly indicating that a 64-8 has already been received.
Once you have received the fax you are permitted to continue with the conversation. You should update IDMS with all the details you have received for future reference.
You should contact the CAAT afterwards who should be able to locate the 64-8 if it was originally sent to them as all forms are scanned and can update all records.
Authority in written form - not 64-8
You should always check the notes or permanent facility in IDMS to see if the authority has been received directly in writing by way of a signed letter. This should show details of the authority given.
Things to note about agent/accountant authority
Even if the notes say we have previously dealt with this agent and discussed the record with them, unless you can find authority or receive proof of that authority, then you should not proceed. Previous notes are not sufficient evidence because it could be that the customer has since withdrawn the authority (unless accompanied by a copy of the 64-8, see above) and therefore each time an agent contacts you they must be verified.
If you learn an agent is no longer acting then you should ask the customer to write in and send the correspondence to the CAAT.
If an agent or other person was acting on behalf of a deceased customer prior to their death, through a power of attorney or consent (such as a form 64-8) for example, you may no longer disclose confidential information to these third parties. If the personal representatives wish these third parties to continue to act they must provide a fresh consent. For guidance on third party deceased cases, see DMBM510450.