Scottish Fiscal Commission must ensure adequate safeguarding of sensitive personal data say tax professionals

The body representing Scotland’s tax professionals has reiterated its support for plans to place the Scottish Fiscal Commission on a statutory footing from next year, but restated the importance of ensuring that the privacy of data relating to individual members of the public is maintained.

The CIOT was responding to the Scottish Government’s call for evidence on the Draft Scottish Fiscal Commission (Modification of Functions) Regulations 2017.

In its response, the Institute calls for appropriate safeguards to be put in place to ensure that individual taxpayers’ information is protected.  The CIOT has also called on the Scottish Government to ensure that the Commission is properly resourced to be able to execute its enhanced functions when it becomes a statutory body from 1 April next year.

Commenting on the submission, Moira Kelly, Chair of the CIOT’s Scottish Technical Committee said:

“Independent scrutiny is an essential component of a robust fiscal framework which can in turn help to create a better, more efficient tax system.  The move to place the Scottish Fiscal Commission on a statutory footing from April of next year is a welcome step forward in achieving these aims.

“Effective and appropriate public scrutiny must be combined with protecting sensitive and personal information related to individual taxpayers.  We are encouraged that the Scottish Government believes that there will be no impact on privacy as a result of the use of anonymised, aggregate data.

“However, as we have warned in the past, there is a need – particularly in areas of relatively low population such as the Highlands and Islands – to make sure that even anonymous and aggregated data cannot allow for fairly easy identification of those affected.

“We trust that the appropriate steps will be taken to maintain the anonymity of this data, with Part 3 of the Revenue Scotland and Tax Powers Act 2014 a useful example of how this can be achieved, but we will nevertheless be maintaining a close eye on developments.”


1.       CIOT’s submission to the Scottish Government can be read here

2.       Part 3 of the Revenue Scotland and Tax Powers Act 2014 makes provisions about the use and protection of taxpayer and other information

3.       The Chartered Institute of Taxation (CIOT)

The CIOT is the leading professional body in the United Kingdom concerned solely with taxation. The CIOT is an educational charity, promoting education and study of the administration and practice of taxation. One of our key aims is to work for a better, more efficient, tax system for all affected by it – taxpayers, their advisers and the authorities. The CIOT’s work covers all aspects of taxation, including direct and indirect taxes and duties. Through our Low Incomes Tax Reform Group (LITRG), the CIOT has a particular focus on improving the tax system, including tax credits and benefits, for the unrepresented taxpayer.

The CIOT draws on our members’ experience in private practice, commerce and industry, government and academia to improve tax administration and propose and explain how tax policy objectives can most effectively be achieved. We also link to, and draw on, similar leading professional tax bodies in other countries. The CIOT’s comments and recommendations on tax issues are made in line with our charitable objectives: we are politically neutral in our work.

The CIOT’s 18,000 members have the practising title of ‘Chartered Tax Adviser’ and the designatory letters ‘CTA’, to represent the leading tax qualification.

Contact: Chris Young, External Relations Officer, 07900 241 584