Department makes second update to privacy notice in a short period of time, with the latest version advising citizens that their information may be used to test new departmental platforms

HM Revenue and Customs has made the second update to its privacy notice in a matter of days to clarify that individuals’ personal data may be used in helping the department to test new IT systems before they launch.

Under the heading ‘Situations in which we’ll use your personal information’, the tax agency lists various instances in which HMRC will use sensitive data in delivering its own services, as well as those provided by arm’s-length body the Valuation Office Agency, which assesses properties for their Council Tax-banding.

A third category lists a number of other situations in which the department is liable to process personal data, including anti-fraud activities, conducting research, and producing statistics.

As of a new version of the HMRC privacy notice published on Friday, another use case has been added to this list.

The updated document says: “We may also process your personal data… to test whether an IT system or process is functioning correctly in an effective manner before it goes live.”

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This small addition marks the second tech-centric amendment made in little more than two weeks. At the end of August, PublicTechnology exclusively reported that HMRC revamped the privacy notice to include added allowances for the use of automated decision-making tools to help “determine benefits, credits… penalties and charges” issued by the department.

That update also introduced an entirely new section headed ‘Artificial Intelligence, analytics and machine learning’.

This segment reads: “HMRC will only use AI, including analytics and machine learning where the law allows us for the purposes of the assessment or collection of a tax or duty, or the prevention or detection of crime. AI helps us learn more about large amounts of data, improve our customer services and prevent and respond to non-compliance amongst our customers. When buying or developing and deploying systems that involve AI and processing personal data, HMRC complies with our data protection, security, and ethical professional standards. HMRCs use of AI does not replace human judgement when collecting taxes or determining benefits, and our customer services processes always involve human agents.”

The privacy notice is intended to provide information for citizens and “describes how we collect and use personal information about you in accordance with data protection law”, according to the document’s introduction.

The recent update to include reference to the potential use of automated decision-making tools follows similar changes made by government agencies including the Department for Work and Pensions and the Department of Health and Social Care.