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Sch 23 bulk data-gathering powers: policing the gig economy

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The growth in the ‘gig’ and ‘sharing’ economies poses challenges for HMRC to identify and check workers and small businesses are paying the right tax, and large businesses are a useful source of data. The bulk data gathering powers in FA 2011 Sch 23 provide HMRC with a potentially effective tool for policing this increasingly important sector of the economy. Data holder notices are not always well drafted, however. Recipients must be mindful of their data protection obligations and should carefully consider the scope and validity of any notice they receive before handing over customers’ personal data.

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