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HMRC internal manual

International Exchange of Information Manual

Reportable Information: Paper and Electronic Records

Reportable Information: Paper and Electronic Records

The records of a Financial Institution include both paper and electronic records that the Financial Institution maintains for the purpose of keeping Account Holder information available for use in the business. This includes information such as the customer master file necessary to maintain contact with the Account Holder and information for satisfying AML/KYC procedures.

Information is not regarded as maintained by the Financial Institution if it has been archived and is not used by the business, for example there may be regulatory requirements that documents are kept for a minimum period before they can be destroyed but are otherwise not used by the business. Only when such information is retrieved by the Financial Institution from the archive so that it can be used by it will the information be regarded as maintained.

Electronic records are available for use by the Financial Institution to the extent that they are electronically searchable. This means information maintained by the Financial Institution that is stored in the form of an electronic database against which standard queries in programming languages, such as Structured Query Language, may be used. Information, data or files are not electronically searchable merely because they are stored in an image retrieval system such as portable document format (pdf.) or as scanned documents.

Financial Institutions should rely on the IT systems they have in place at the time the electronic searches are carried out, they are not expected to build systems to carry out electronic searches solely for the purpose of reporting under their automatic exchange of information obligations.