Employee address details

23 October 2014

Some readers of the earlier announcement were unclear about the meaning of the sentence…… “Employers must advise their employee they have sent this change to HMRC”.

HMRC have now clarified this as follows:

HMRC analysis of FPS submissions shows that approximately 25% of submissions that include a National Insurance Number (after the first FPS) include an address for the individual. HMRC does not currently automatically make use of this data. The data is only used once. HMRC is made aware that the address it holds for an individual is no longer valid. For these cases HMRC staff manually check to see if there is a newer address within a recent FPS. The analysis further shows that the individual will often inform their employer that they have changed address but forget to inform HMRC. HMRC would therefore like to make full use of the data that it receives. All of the customer research we have completed in this area has led us to the conclusion that most individuals believe that their employer will notify HMRC of the change of address. Advice from our Data Protection Act experts has confirmed there is no legal barrier for HMRC to use the data it receives, but they did highlight that there may be an impact for the employer.

Employers already provide information about their employees to HMRC; including address data when they employ a new staff member. It is generally accepted that as part of that process the Employer needs to send information to HMRC about the new staff member including their address; thus the employee is aware that their address will be notified to HMRC. Employees may not make the same connection later in the lifecycle of their employment. To protect the Employer and ensure that they are compliant with the Data Protection Act, employees need to be made aware that their employer will be providing address data to HMRC during the lifetime of their employment.Individual notification for each change of address is not required.It is sufficient for the employer to make their workforce aware through general communications.

Providing changes to address during the lifetime of the employment will be voluntary for the employer. Should the employer/ pension provider not wish to provide that information to HMRC they can continue to submit 'blank' address data in subsequent FPS.