IEIM902340 - How often does Information need to be Collected and Updated?

Where a Reporting Platform Operator (RPO) has collected information in respect of a Seller in a previous Reportable Period, it may be able to rely on this information in a subsequent Reportable Period in certain circumstances. 

Firstly, the RPO must not know, nor have any reason to know, that any of the information collected previously has become unreliable or incorrect. This will depend on the facts. For example, if a Seller got married, changed their name and updated it on the Platform, then the RPO would know that the previously collected information before the marriage was now incorrect. However, if the Seller did not update their name on the Platform, the RPO might not know about the name change. The RPO would not be expected to undertake investigations to find this out, for example by contacting the Seller to ask if they happened to have changed their name.

On the other hand, if the Seller drives a vehicle as part of the work on the Platform, and the RPO routinely checks Sellers’ driving licences to ensure they are valid, then if the name on the Seller’s driving licence has changed, that would mean the Platform had reason to know that the name previously collected had become incorrect. Accordingly, the RPO would now need to collect the new name of the Seller.

This does not necessarily need to be a separate process. If the Seller updates their information on the Platform, and the Platform uses that information provided by the Seller to meet its data collection obligations under these rules, then the steps of finding out that the previously provided information is now wrong and collecting the new, correct information would effectively be undertaken simultaneously.

In addition to the above an RPO can only rely on information about a primary address provided by a Seller in a previous Reportable Period, if it was both collected and verified or confirmed in the previous 36 months. This is because the primary address, compared with the other data points, is more likely to change regularly, and because of the importance of the primary address being correct for the purposes of exchanging the information with other tax authorities as appropriate. For these purposes, the RPO can obtain a Seller’s explicit statement or confirmation that the previously collected address details are still valid. The RPO does not have to collect the primary address again.

More generally, to ensure the information they hold and report is reliable, RPOs may wish to consider what steps they can take to encourage Sellers to update their details, for example, by asking Sellers to confirm information held by the RPO is still correct. Steps such as this could help RPOs to ensure the information they collect and provide is reliable.

If the RPO finds that a Seller’s details are no longer reliable or correct, the RPO must collect that information again, and verify it as required (see 902400).

If a Seller’s personal information, such as their name or primary address, changes during a Reportable Period, then the RPO should report the details that are correct at the end of the Reportable Period.