IDG40440 - Sharing information outside of HMRC: disclosure for HMRC’s functions: verifying information
Is verifying information that someone already holds a disclosure?
Yes. Even though someone may already hold information, if they ask HMRC to verify whether that information is correct, HMRC is still making a disclosure of information that is protected by HMRC’s duty of confidentiality. This means you should not verify information unless there is lawful authority for you to do so (see IDG40300).
When can HMRC verify information held?
See IDG40410 and IDG40415 for the steps that need to be followed when deciding whether to disclose identifying information for the purposes of HMRC’s functions.
Two common examples arise in connection with disclosure of information by verification.
(1) Verification of VAT registration numbers
Traders or individuals may contact HMRC to seek verification that a VAT registration number is validly held by a particular trader. They may do this because they want to ensure input VAT they are paying to the trader is being properly paid, or in connection with obligations on them under the VAT reverse charge.
You can confirm that a VAT registration number is valid, and/or that it tallies with a name and address where these details are supplied by the enquirer, provided you are satisfied that:
- there is no intent of fraudulent use of the VAT registration details; and
- the enquirer appears to have a legitimate business need.
Such disclosures are necessary so that traders can correctly operate VAT.
(2) Verification of National Insurance numbers
Employers may contact HMRC seeking verification of National Insurance numbers for employees or prospective employees. They may do this because they want to ensure their end of year returns to HMRC are correct or to help satisfy immigration and nationality checks.
You can confirm that a National Insurance number is correct and/or that it tallies with a name and date of birth where those details are supplied by someone who is registered as an employer or pension provider with HMRC provided you are satisfied that:
- there is no intent of fraudulent use of the National Insurance details; and
- the enquirer appears to have a legitimate business need.
Such disclosures are necessary so that employers can correctly operate Pay As You Earn.
Other situations where HMRC is asked to verify information
Above are the two most commonly occurring verification scenarios. If you are asked to verify customer information held by HMRC in any other situation (or even to confirm or deny that HMRC holds information relating to a identifiable customer) remember that this is a disclosure like any other and so lawful authority is needed.
Further guidance
If you receive a request for verification of information and are unsure how to proceed, please ask for advice from your Security & Information Business Partner (SIBP).