IRD has recently implemented a reasonably consistent policy across some of its service delivery divisions. In this article we provide details and comment on areas still needing improvement.
This is a brief update to our article in November 2011 and should be read in conjunction with that article – see here.
We provided the article to IRD in draft well in advance of publication, and have included IRD’s comments.
IRD accepts that if a taxpayer agrees then IRD is not legally prevented from sending information by email, and where appropriate (eg working collaboratively on a document) by way of an electronic attachments e.g excel spreadsheet.
As at May 2012 the position appears to be as follows:
The largest of IRD’s business groups– the services delivery business group, has various divisions that interact with the public:
Assurance (ie audit)
Collections (debt management)
Assurance (audit) has what I consider to be a reasonably well written policy – click.
Collections (debt management)
The collections debt unit of IRD has only recently implemented its own version of an email and spreadsheet policy, which IRD advises is the same as Assurance (audit). We welcome this development.
We assume that Litigation Management will follow the same procedures as Assurance and Collections.
Application in practice
Where IRD does permit use of email and electronic documents (with taxpayer agreement), IRD imposes various barriers which we consider are artificial:
|Assurance guidelines for sending spreadsheets appear very good
|Staff often substitute numbers for formulas, which means it is difficult to understand the structure of a spreadsheet, and further if some underlying data is corrected the tax calculation does not change. Regrettably spreadsheet design by IRD staff leaves a great deal to be desired
|The subject line of an email should be meaningful eg taxpayer name and subject. In fact Assurance policy states “Subject line of email to start with “In confidence”, followed by the actual subject of the communication”
|Email subject lines are often restricted to saying ‘in confidence’ which makes it challenging to identify a particular email out of what may be hundreds
|A recipient should acknowledge receipt of an email upon request
|IRD explicitly requests confirmation of receipt, but often does not provide that courtesy itself
|The email should be brief, with sensitive material in an attachment which may be protected by a password
|IRD Staff sometimes use overly complex protection methods like including an attachment in a zip file with unlocking passwords. On other occasions staff have protected with a password but naively included the password in the same email
|IRD should copy in other recipients on request – eg the taxpayer, tax advisor, accountant and lawyer
|Frequently IRD staff insist on communicating with one person, when they may not be contactable for some reason
The only comment from IRD on the above was on the last point: “The issue of copying in multiple recipients is one which carries increased risk of breaching authority and confidentiality and accordingly will remain subject to tighter control”.
IRD’s customer services unit refuse to use email at all. IRD states:
Inland Revenue recognises the increasing demand for email as a means of communication with our customers. We are currently working across the organisation to understand how we can improve and achieve consistency in this area. Of utmost importance however is the security of our customer information so this is a key driver.
The nature of Customer Services work is such that our staff do not usually have on-going contact with one customer (i.e. it is NOT a case managed environment). As such the use of email containing customer information poses a somewhat higher risk to the organisation than in some other Service Delivery areas. As our systems change we do anticipate having more capability in this area which will afford us more flexibility in terms of how we communicate electronically with customers. In the immediate future however we have no plans to make emailing customer information (as an attachment or in the body of the email) part of our normal business practice.
- we receive a letter signed by a specific person (John Smith), and
- sometimes from a person who appears to have no first name (J Smith),
- they don’t provide an email address or a telephone number (other than the 0800 number alleging a tax position)
- we have no way to challenge the assertion other than writing back to J Smith, and hope it gets to the right person
- we have no way to follow up to get an indicative time frame.
IRD did not address these points.
While it has taken a lot of badgering, we are pleased that at last IRD has instituted policies governing use of electronic spreadsheets and email.
We trust that this is now communicated across all relevant IRD staff, IRD will appreciate the efficiencies that will result, and that IRD will now put some resources into improving its standards in these areas.