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MTD handover of digital records

Previous accountant refusing to hand over digital records and now claims to have deleted them.

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In my professional clearance letter I asked for a back up of my client's Sage data.

The previous accountant just sent pdf files of the audit trail etc. for the current year only.  Opening balances came with working papers/schedules.

I check some of the old customer balances with my client and it turns out some had been paid via bank transfer in the previous year for which accounts have been produced.

So go I back to the previous accountant with a list but also suggesting that he could still send me the back up so I can investigate myself.  "Assuming the bank was properly reconciled, there are a number of receipts here that must have been recorded somewhere."  

He refuses to send me a back up of Sage "as it contains our passwords and is our own property, as opposed to the information in the ledgers which we consider the client’s property and we sent you." (he only send current year).  So I ask him for the audit trail for the previous 2 years.

This morning I get another email including the line "When I sent you the information and printouts a few weeks back, I deleted the XXXX Sage records from our computer systems as it was using up one of our licences, and I needed to make way for other clients of our practice."

So now where does my client stand with his company's obligation to keep digital records?

Replies (37)

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By Sandnickel
07th Nov 2021 11:06

Sounds like he's fudged the books and he knows it. There should be a backup of SAGE - he can easily change the password but I'm guessing you already know that.

I would say that it's up to the client if he wants to pursue the issue or not. Presumably you have the source documents should the records need to be reproduced? I would inform the client and tell them that should they be investigated the lack of digital records may cause them an issue and leave it with them.

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Replying to Sandnickel:
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By menantoll
07th Nov 2021 11:45

Thanks for the reply.

Yes I am aware he could change the password then send me a data only back up. Thanks anyway as I might not have been aware.

At first I thought he didn't want to make it easy for me. 9 months into the current year I had to rebuild most of it manually into Xero rather than have it imported but now I wonder what else is in there other than a few ledger balances being wrong.

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Replying to Sandnickel:
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By Paul Crowley
07th Nov 2021 12:41

I agree
If the accountant is also the bookkeeper then the "books" belong to the client would be my expectation.
But the software belongs to the agent in this case

This type of issue can only get worse once MTD ITSA comes in

Historically the accountants working papers belonged to the accountant. I have never asked an accountant for working papers, nor been asked for them

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By JD
07th Nov 2021 16:08

Presumably what belongs to accountant or client will be defined in letter of engagement. Respectfully why do you feel the need or that you have a right to have the previous advisors working papers just because they are digital.

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Replying to JD:
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By menantoll
07th Nov 2021 16:23

Respectfully, I'm not asking for the working papers.

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Replying to menantoll:
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By Paul Crowley
07th Nov 2021 21:21

If I write records up on a spreadsheet, then I consider them to be working papers
If I write them up on my software, same applies

If client writes them up on his software and I ammend them, the software is held by client and I have no control, those records are clearly his.

Not sure what point you are making

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Replying to Paul Crowley:
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By Hugo Fair
07th Nov 2021 21:45

Although it doesn't appear to be relevant to scenario set out in OP, you hint at an interesting dilemma arising with Cloud systems. Especially where:
* Licence is is name of Agent (as part of block subscription); but
* That licence is 'allocated' (by Agent) to individual Client; who
* Is responsible for book-keeping (aka data collection); but
* Those records are corrected by Agent during prep of accounts.

As far as I can see ... this means the container (the software) is licensed to the Agent (albeit owned by the developer) - whilst the digital records (the data) is owned by the taxpayer (subject to your point about 'working papers') - but you can't hold the data in a truly effectively readable (analysable) format outside of the software.

AND, in addition to the question of ownership (and cost of maintaining it in a readable medium), there's also the question of compliance with the necessity of 'retaining records' for a minimum defined period (even after a change in Agent).

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Replying to Hugo Fair:
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By Paul Crowley
07th Nov 2021 22:35

Agree
Patterns were set when records were in a handwritten cashbook
Cloud disappears if subsciption not paid

Not a problem for me as I insist that client buys the software, even if I can get it cheaper
I sell skills, do not want to make a buck on software

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Replying to Hugo Fair:
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By Paul Crowley
07th Nov 2021 22:36

Agree
Patterns were set when records were in a handwritten cashbook
Cloud disappears if subsciption not paid

Not a problem for me as I insist that client buys the software, even if I can get it cheaper
I sell skills, do not want to make a buck on software

Looks like a double click

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Replying to Paul Crowley:
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By Hugo Fair
07th Nov 2021 23:18

Yours seems a sensible solution to me ... albeit that's not the way that suppliers of Cloud apps promote their wares, of course.

But it does raise the question that I now realise OP was trying to ask ... which I would re-phrase as "Who is responsible for maintaining digital records, in order to comply with MTD, for the requisite number of years? And therefore did the previous Agent have the right to delete those records (irrespective of who 'owned' them)?"

As mentioned, I'm not even clear whether there's any definition of how accessible or analysable these digital records have to be during the 'retention period' - and therefore what onus is placed on the taxpayer in terms of maintaining it within a readable medium.

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Replying to Hugo Fair:
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By Tax Dragon
08th Nov 2021 08:29

Pre MTD, a taxpayer would have a record of transactions and her accountant a file (possibly in storage) of working papers. The trick with going digital is surely to do what Paul has done and mirror the old ways.

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Replying to Tax Dragon:
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By Hugo Fair
08th Nov 2021 10:32

Wholly agree, from the Agent's perspective - although as I pointed it's not the M.O. that the software companies are promoting (and so may not turn out to be a common solution).

However, as Adam mentions below, that still (correctly) leaves the taxpayer responsible for maintaining the digital records mandated by MTD ... and leaves unanswered two key questions:

* Any definition of how accessible or analysable these digital records have to be during the 'retention period' - and therefore what onus is placed on the taxpayer in terms of maintaining it within a readable medium?
[For instance, what happens when he/she changes 'app' after a couple of years?]

* Whether the necessary interventions/manipulations of these records by the Agent are therefore automatically 'owned' by the taxpayer - as they need to be performed within the book-keeping software in order to retain a single audit trail of the digital records?
[May need to distinguish between corrected data and a'cs prep data in future?]

Personally I'm still not entirely clear as to what rules cover the 'transfer' of these records into the prep of actual accounts (as opposed to tax calcs/returns) ... but that's maybe a story for another day!

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Replying to Paul Crowley:
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By JD
08th Nov 2021 11:09

Precisely, Paul (7 Nov post)

Because of the potential for confusion (not least with MTD as you have noted) we have defined in our engagement letters what belongs to who (particularly important with company clients).

Broadly the client has ownership of what they have paid for (the Accounts, VAT return with VAT transaction report etc) and what they have provided to complete that work. The means of production, digital or excel, is purely a matter for ourselves and remains in our ownership.

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By Paul Crowley
07th Nov 2021 21:25

The issue here coud be that the standard rules were written before digital was common
Indeed before monthly fees were common

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By ireallyshouldknowthisbut
08th Nov 2021 08:39

I would suggest these are not "working papers" as suggested above but the fundamental bookkeeping records of the business. If the former accountant has destroyed them, then I would be suggesting they recreate them, at their cost.

You might therefore find the file magically appear. There will no doubt be a year end backup.

I must admit I don't know why people get so prissy over their working papers. I have no issue sharing mine with incoming accountants. I have nothing to hide.

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By adam.arca
08th Nov 2021 09:16

It’s an interesting point because of the new spin put upon it by MTD.

Fundamentally, however, retention of accounting records is the responsibility of the taxpayer and not their agent even where the agent has undertaken responsibility for the basic as well as advanced bookkeeping. I don’t really see that changing because of MTD.

Pre MTD, I would be with the outgoing accountant on this although I would like to think I would be more generous in terms of audit trail / nominal activity handed over. What I wouldn’t be doing would be handing over the licence if I had absorbed that cost.

Post MTD, this looks like it could be a problem on the assumption that MTD is going to require one, complete audit trail only and we as accountants will have been responsible for the final touches and submission.

Maybe HMG should be thinking in terms of open source requirements for the audit trail to make it completely transferable to other MTD software? In the absence of that, maybe we should all get into the habit of sending our clients a complete annual audit trail as part of the job closedown?

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Replying to adam.arca:
paddle steamer
By DJKL
08th Nov 2021 13:21

If I pay you to write up my books , effectively my primary accounting records, these books are imho very clearly part of my business accounting records and my property, if the agents destroys them prior to passing to the client he better be prepared to recreate them.

To be clear books of prime entry are NOT an accountant's working papers, even a list of journals to a nominal ledger are not, even if the accountant wrote them they are part of the accounting records of the business, so if I pay you to write up a cashbook in excel it is my cashbook, whether you supply it to me in paper form or digitally is your choice.

(An analysis of a nominal, a review say of all R & R, or legal & prof, is a working paper.)

Back in the old days we kept bound ledgers which we posted to, these belonged to the client, they paid us to make the postings- especially with companies there is legal guidance what constitute a company's accounting records (CA 2006 s386)

Accountants really ought to be cooperative , they should imho provide copies of all daybooks, all ledgers, a mere audit transaction report is not imho legally sufficient re a company. (so supplying everything in digital form is actually likely less work)

At the end of the day responding to these sorts of issues is costing the previous accountant money, he/she is wasting time, such disputes can escalate and professional bodies can then become involved- the smart move is transferring the records in a digital format to the client and getting the file closed so that efforts can instead be applied to getting a new replacement client/better serving existing clients.

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By GHarr497688
08th Nov 2021 12:04

Your new client should have made sure he had all he needs before moving across to you. The client is responsible for ensuring records are maintained and kept. This blaming the Accountant for everything from losing a receipt to missing a banking has to stop. Learning the concept of balancing Accounts is not rocket science. Clients are lazy and want to blame others for being idle!!

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Replying to GHarr497688:
paddle steamer
By DJKL
08th Nov 2021 13:23

Unless they are paying someone to do this for them, in which case they have a perfect right to receive copies of what was being paid to be done.

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Replying to DJKL:
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By Hugo Fair
08th Nov 2021 14:47

Exactly.
Although many clients are indeed lazy, that can be one of their main drivers for paying you to do something they could (possibly) have done themselves ... so don't knock it.
The bit that almost no client seems to understand is that they remain liable (in this case for retention of digital records and accounts) ... so, if they think they've 'outsourced' this but are let down by the Agent, then the taxpayer is still liable (even if they have the separate potential option to threaten/sue their Agent).
Hence my interest (and earlier post on this thread) about the impact of changing software or agent during the retention period - and thus the accessibility issue.

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Replying to DJKL:
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By GHarr497688
08th Nov 2021 17:15

I think I should make clear that even if the client pays the Accountant to complete the records then any decent Accountant would provide a copy of the records and make sure that the client understands the records keeping requirements , the limitations of work done and the importance of prime entry. In other words before the client left the old Accountant the new Accountant would be wise to tell them what was needed although the client should know anyway. I always give clients paper records or digital copies if requested and I also make sure they understand what's needed.

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ALISK
By atleastisoundknowledgable...
08th Nov 2021 17:45

I need to update my LoE to say ‘if I pay for Xero it’s mine, unless I recharge you, then it’s yours’. I guess unless it’s mentioned on my services, in which case from this thread it’s probably theirs. Need to think about this a bit more.

When someone leaves, I activate the 1 month cancellation, give them full access to export data or transfer the subscription.

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By Heating_installer
09th Nov 2021 16:50

My thoughts on this are that if the issue is largely down to MTD requireements then HMRC need to make a data exchange file format part of the MTD compliant software specification.

Something like the ****.dxf file that facilitates exchange of CAD data between different author packages i.e. a little more than a ****.csv

It would probably be to their own advantage if the software houses got together and thrashed one out between themselves before HMRC impose something unworkable!

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Replying to Heating_installer:
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By Hugo Fair
09th Nov 2021 19:20

The pigs are now flying in massed formation and will pass overhead shortly!

I don't disagree with the "need" you state, but HMRC will never mandate a common file format unless it is the file that they need to 'import' at their end. Anything else is seen by them as 'market interference', which causes them to run for the hills squealing loudly. Do they truly believe this or are they just scared of the developers?

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Pile of Stones
By Beach Accountancy
09th Nov 2021 22:16

Why doesn't the client ask for the Sage backup of his (own) records? (and then pass them to you)

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By Rgab1947
10th Nov 2021 12:24

re: Retention, I always transfer the license to the client when he leaves so he (and his new accountant) have the digital record keeping. For desktop I give the data backup (Sage)

Records I keep are my working papers which are digital.

Hopefully that makes me compliant with whatever rules there are.

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By Leywood
10th Nov 2021 13:47

I dont believe they deleted ALL of their backups. Push harder, via the client if needs be.

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All Paul Accountants in Leeds
By paulinleeds
13th Nov 2021 13:57

If you are paid to maintain the accounting records of the business then those records belong to the business. That is what they have bought from you. Just because they are on software or in the cloud does not change the position.

The only time that you would not provide the accounting records is possibly where they are your working papers. However, bear in mind that any journal entries that you do on top of the client’s own accounting records causes those journal entries to become part of the business accounting records.

I would therefore expect to hand over to any new advisor/bookkeeper/client their accounting records so they can continue to maintain/use them.

This may necessitate the provision of journal entries which would link the clients accounting records to the annual Financial Statements. In that case your journal entries, are not simply your working papers, but they become link papers and therefore accounting records of the client.

If you are dealing with a limited company, then under Companies Act 2006, the accounting records that you have been paid to maintain/create become the accounting records of the company. You therefore cannot hold on to them.

The big problem once we talk about digital records and cloud accounting is that whilst the client may own the accounting records they do not necessarily own the software or platform that holds the accounting records.

There are however provisions under GDPR that ensures ‘The right to data portability’.

The right to data portability allows individuals to obtain their personal data for reuse. It allows them to securely move, copy or transfer personal data easily from one IT environment to another commonly used and machine readable form e.g. CSV files. The data must be provided free of charge and without undue delay, at least within one month. Accounting practices may be required to provide client data electronically to the new advisor when they move.

There is absolutely no point in giving a new advisor/company/bookkeeper photocopies of copious accounting records or sending them in PDF format. The data must be provided in a machine readable format.

They should therefore be relatively easy to extract as an audit trail from one piece of software, via say a csv or Excel file, and pass this to a new advisor/company/bookkeeper.

In fact, on a very practical level this is what you would have to do if you were changing accounting packages and where there was not the ability, as is the case generally, to import directly the data from one software package to another.

Even giving a csv or Excel file may not be particularly helpful. Whilst the new advisor/company/bookkeeper could, with some work, reconstruct the accounting records, it fails to address a number of other key issues e.g. which transactions have been reconciled for VAT, on the bank and which sales and purchase invoices are outstanding or have not been matched to payments/invoices?

When I contact a new accountant, I may be happy to accept PDF or posted photocopies of accountants’ working papers to help me set up balances brought forward and for comparatives.

However, if there are lengthy lists of debtors, creditors, and stock etc, and particularly where these have been extracted or created by the accountant in order to ascertain the year end position, they become link papers, and therefore the accounting records of the business. As such, I would always request them in digital format.

My client does not want me to spend hours re-keying a considerable amount of data, when this data is already in digital format with the former accountant, and which most probably will be printed/PDFed before transfer to me. If the client has paid for this information to be produced by the belongs to the client.

Therefore, in summary, whilst the accounting data will most probably belong to the client, the software platform of software programs, that manages the data, may belong to the accountant.

There is probably no real reason why the accountant should not transfer the licence. You don’t actually own the license, you only have the ability to access the data or use the software through the license. Therefore, the transfer of the license should not cause any loss to the accountant. I can’t see any real reason why an accountant would block the transfer of a license.

It is almost akin to saying that a builder has built a house, which our client has paid for, to only then offer the client a pile of brick, timber and concrete. The house includes the constituent materials, just like the accounting software or platform holds the data.

There may become occasions where the client wants the data, but does not have the right to the software platform, or there is no have the ability to transfer the software program or platform. In these cases, the only practical alternative is to transfer the data, and not necessarily just dates and amounts, but also what has being reconciled and matched with what.

We have to start thinking in modern terms. We wouldn’t separate the ink in a set of books from the actual book. We therefore have to consider the accounting data (the business’s accounting records) and the underlying software platform/programmes when transferring accounting records.

In my own firm’s engagement letter, I do say that the client must request copies or backups themselves within a reasonable/agreed time frame from when I have performed the work. Furthermore, we should not be seen as an unpaid data back-up service.

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Replying to paulinleeds:
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By Hugo Fair
13th Nov 2021 16:21

An excellent forensic examination of the issues raised by OP - i.e. changing Agent or Accountant (where for obvious reasons the main focus is on PYA & associated data).

I'm still interested in the (parallel) point that I raised earlier in this thread, with regard to the taxpayer's responsibilities for maintaining her/his records as both accessible & readable/reportable for the whole of the 7+ years' retention period.

My question was/is:
* Is there any definition of how accessible or analysable these digital records have to be during the 'retention period' - and therefore what onus is placed on the taxpayer in terms of maintaining them within a readable medium?

For instance, what happens when he/she changes 'app' after a couple of years?
Do copies of all the original apps have to be retained (along with any upgrades and subscription fees to keep the data accessible)?
Or is the taxpayer expected to convert/transfer the historical records with every change in software?

None of this is likely to happen with the average unrepresented taxpayer - so where do Agents stop in terms of advising their clients about their responsibilities (or options for meeting their obligations)?

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Replying to Hugo Fair:
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By Paul Crowley
13th Nov 2021 16:24

I may have to report you
Aweb is sponsored by the software people that just do not want to address their inherent responsibilities for record retention
Idiot accountants tend to do it for free

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Replying to Paul Crowley:
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By Hugo Fair
13th Nov 2021 17:23

Ta, I have these occasional bursts of optimism (or is that naïveté) when I believe that:
politely raising pertinent questions that Sift might like to pose to the software developers, or even to HMRC, is (pompous pause) my public duty. <:-|

I've spent half a lifetime using my one true skill (unbiased logic) to identify and then draw attention to potential but unperceived problems in the operation of new regs (particularly those affecting employment, payroll, pensions et al).
My success rate is high in pre-identifying problems, although less so in getting the powers that be to do anything about overcoming them (with just enough successes to keep me going)!

And this interaction, between the existing 'minimum retention of records' and the forthcoming mandation of these records needing to be 'digital', seems to me to be worthy of digging-up for a good look ... irrespective of MTD itself and its impact on all sorts of Agents.

Maybe I'll never learn when to shut up (as I was warned by a teacher when I was 8 years old and had only been speaking English for a couple of years)!

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Replying to Hugo Fair:
All Paul Accountants in Leeds
By paulinleeds
13th Nov 2021 17:19

I do not think, generally, there is any requirement to keep digital records, only to keep the defined records.

There is no requirement to keep all past records online i.e. immediately available. They can be archived. You need both software programs / platforms to restore archived data records.

With changes in Apps and platforms this can prove problematic, though they can be archived e.g. to an audit trail or PDFed etc.

Overall, most documents a business will create are covered by Section 5 of the Limitations Act 1980 and should be kept for six years after they expire. This ensures that the documents are available if a civil case is brought against the company.

Accounting records

The main UK legislation regulating statutory retention periods is summarised below.

Statutory retention period: 3 years for private companies, 6 years for public limited companies.
Statutory authority: Section 221 of the Companies Act 1985 as modified by the Companies Acts 1989 and 2006.

Income tax and NI returns, income tax records and correspondence with HMRC

Statutory retention period: Not less than 3 years after the end of the financial year to which they relate. Statutory authority: The Income Tax (Employments) Regulations 1993 (SI 1993/744) as amended, for example by The Income Tax (Employments) (Amendment No. 6) Regulations 1996 (SI 1996/2631).

Payroll wage/salary records (also overtime, bonuses, expenses)

Statutory retention period: 6 years from the end of the tax year to which they relate. Statutory authority: Taxes Management Act 1970.

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Replying to paulinleeds:
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By Hugo Fair
13th Nov 2021 17:53

Thanks for all the references ... which I lazily tend to simplify as a single "7+ years" (thereby 'covering' 6 complete years + current, as well as all the sub-sets that don't require more than 3 years).
FWIW there are also other non-statutory retention durations that are actually rather important in practice - and often needed for a much greater duration - such as pension contributions (ER & EE). ACAS and others recommend that, under GDPR, these are kept for the lifetime of the employee/member!

But my central point was the bit where you say:
"There is no requirement to keep all past records online i.e. immediately available. They can be archived. You need both software programs / platforms to restore archived data records. With changes in Apps and platforms this can prove problematic, though they can be archived e.g. to an audit trail or PDFed etc."

I agree. However my question was whether anyone in charge (HMRC or PBs or whomever) has identified the problem that Retention periods were defined in the days of paper records, but the move to 'everything digital' will mean no such paper records remaining - in many cases - in the near future.

Hence my interest in what you've labelled the archiving process - where, as you say, "You need both software programs / platforms to restore archived data records."
Is the assumption that taxpayers will, every year, perform an 'archive' process (whether by exporting data in one of many different formats, or 'printing' dumps of the data to PDF, or some such)?
If so, in the absence of a defined common format, will that archive be intelligibly readable in the future 'as is'? Or will the taxpayer have to maintain subscriptions to various Apps in order to ensure the data is truly accessible for a few years?

Of course this 'issue' (which it is in my mind as no-one seems to be addressing it) is bad enough where the taxpayer never changes Apps - as that leaves open the question of reliance on developers who promise 'backwards compatibility' AND means having to maintain a subscription after you cease using the App?

But it's much worse where the taxpayer changes App - or even changes Agent (which may also necessitate changing Apps). As now we're into the realms of compromising any attempted retrospective analysis (whether for an HMRC enquiry or in support of M&A or Loan activities).

I'm not intending to whinge ... just seriously interested in whether there's any evidence that Govt or PBs (or indeed software suppliers) have said anything about recognising - or even addressing/solving - this issue?

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Replying to johnhemming:
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By Hugo Fair
13th Nov 2021 19:55

Thanks, John, that's certainly interesting.

At first I wondered why you suggested the T&Cs for developers using the govt's APIs - which in themselves are points of short-term access, unrelated to the long-term storage/accessibility of a taxpayer's historical digital records.

And then the penny dropped ... the APIs are only accessible via the HMRC Developer Hub, and someone has had the foresight to include in the T&Cs (for the Hub) obligations going beyond the scope of merely using/incorporating actual APIs.

Kudos to that person ... but I do wonder how seriously most developers take this aspect (if they've taken the implications on board at all):

"What we expect from you ...
Accessing data:
* You must give your users access to their data. We may also ask to access their data if we open an investigation.
* If you withdraw a piece of software or a user stops using it, you must let them retrieve and export all their data so they can meet their obligations to us."

It's a start (albeit it sounds more like an unquantified aspiration than a defined rule) ... but without any mention of additional costs (or not) for the taxpayer, or the question of who is the App client (the Agent licence holder or the taxpayer who's records are held), or of any 'standard' regarding retrieval/export of data.

This unfortunately takes us full circle back to where this (and other) threads have asked about who has to do what (and at whose cost) to maintain these records in a format & medium that will remain both accessible & usefully readable for several years?

FWIW, I presume that the Hub T&Cs are only 'covering' the MTD submission data - so presumably not all the digital records that HMRC is so keen to be able to prove are/aren't being maintained free of human contamination?

Sorry for yet more cynicism, but most people's experiences since the arrival of cloud Apps has not been good (irrespective of MTD) when they, or their Agent, decides to change software.
At best they find themselves on the hook for one-off fees to download their own data (which turns out sometimes to not be quite as 'transferable' into another App as they'd been lead to believe) ... and at worst they're expected to continue the subscription for the old App, alongside one for the new App, and may even have to perform actions (to maintain their account) for the old data.

These taxpayers are an obvious milch-cow for developers - and yes I know you're not all the same - so I think a little more than the Hub T&Cs is still needed!

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Replying to Hugo Fair:
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By johnhemming
13th Nov 2021 21:35

It is a start. I this situation a letter from the taxpayers MP to the FST may help.to clarify the position. HMRC could suggest to the developer holding the digital records that the taxpayer has a right to the legally required information.

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Replying to Hugo Fair:
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By johnhemming
13th Nov 2021 21:35

Duplicate

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