• Contractor Payments - 2016-17, 2017-18 and 2018-19 financial years data matching program protocol

    At a glance

    We routinely collect data on payments made to contractors by businesses as part of our employer obligations compliance activities.

    Contractors can be either individuals, partnerships or other types of entities. Contractors earn income by providing services to other businesses and are generally paid upon production of an invoice by the contractor.

    The data collected from businesses is used to identify contractors that may not be meeting their taxation through:

    • not registering correctly with the ATO
    • non-lodgment of returns
    • failing to report payments received
    • not paying amounts of tax due to us.

    The data is also analysed to detect trends and compliance issues enabling us to develop and deliver educational products and tailored services.

    This is an ongoing data matching program and has been conducted for more than five years.

    Program objectives

    The objectives of this data matching program are to:

    • Better tailor educational products and services to address identified areas of concern and give more certainty to taxpayers in managing their obligations
    • Promote voluntary compliance and strengthen community confidence in the integrity of the tax system by detecting and dealing with instances of non-compliance
    • Assess the integrity of the information held on the Australian Business Register to assist the Registrar develop educational and compliance strategies
    • Obtain intelligence to identify risks and trends about contractors that may not be complying with their taxation obligations - this information may form part of the case selection pool, where suitable referrals are forwarded to ATO field teams for audit or follow up checks.
    • Ensure compliance with registration, lodgment, correct reporting and payment of taxation and superannuation obligations.

    How the data will be used

    We are obtaining this data to cross-reference with our own internal data to identify relevant cases for administrative action, including compliance and educational strategies.

    This cross-referencing will include ensuring contractors are:

    • Correctly registered for taxation and superannuation
    • Meeting their lodgment responsibilities
    • Correctly reporting all of their income
    • Satisfying their payment obligations.

    Learn more about what we will do before amending a return.

    Previous programs

    This data matching program has been ongoing since the 2008-09 financial years and the data matching program has:

    • Promoted awareness in the community of the ATO data matching capabilities
    • Informed a variety of ATO compliance activities such as taxpayer audits, voluntary disclosure and lodgment programs. These activities have resulted in improved compliance with obligations and additional income tax, GST and PAYGW liabilities being raised. It is not possible to quantify this as a number of factors are considered when identifying suitable cases for compliance activity.

    Data related matters

    Data matching and user agency

    We are the matching agency and in most cases the sole user of the data obtained in the course of this data matching program. The data matching program will be conducted on our secure systems in accordance with approved policies and procedures.

    In very limited and specific circumstances we may be permitted by law to disclose individual records to other government agencies.

    Learn more about our on-disclosure provisions.

    Data providers

    Data will be obtained from businesses that we visit as part of our employer obligations compliance activities during the relevant financial years.

    Data elements

    We will obtain the following information from the data providers for the 2016-17; 2017-18 and 2018-19 financial years:

    • Australian Business Number (ABN) of the payer business.
    • ABN of the payee business (contractor).
    • Name of the contractor.
    • Address of the contractor.
    • Telephone details of the contractor.
    • Dates of payments to the contractor.
    • Amounts paid to the contractor (including details of whether the payment included GST).

    Number of records

    It is estimated that the total number of records that will be obtained is approximately 25,000 records for each of the years, of which approximately 12,500 will relate to individuals.

    Data will be gathered in small batches from businesses. Experience indicates that each business, on average, will use fewer than 30 contractors during a year and make fewer than 10 payments to each contractor.

    Data quality

    Based on previous contractor payments data matching programs we are confident that the data will be of high quality. The data being sought is extracted from invoices provided by the businesses that is captured and stored by them as part of their existing record keeping requirements and good business practices.

    Data will be transformed into a standardised format and validated to ensure that it contains the required data elements prior to loading to our computer systems.

    Learn more about:

    Data retention

    We are seeking to have the Privacy Commissioner exercise his discretion and allow the ATO to vary from the data destruction requirements contained in the Guidelines.

    The collection of data under this program protocol is expected to occur in the period July 2016 to June 2019.

    We are seeking to retain the data until June 2025 on the basis that its retention is required for the protection of public revenue. Current Guidelines allow for a twelve month retention. The data needs to be retained until the taxpayer has lodged their return and for a further period if subsequent compliance issues are identified within the period of review allowed by the law.

    See the submission to the Privacy Commissioner setting out the basis for seeking the variation to the data destruction guidelines and its impacts on individual privacy.

    Public notification of the program

    We will notify the public of our intention to undertake this program by:

    • publishing a notice in the Commonwealth government notices gazette in the week commencing 11 April 2016 - view the content of the gazette notice
    • publishing this data matching program protocol on our website at Data matching protocols
    • advising the data providers they
      • can notify their contractors of their participation in this program and provided written materials to assist with this
      • should update their privacy policies to note that personal information is disclosed to us for data matching purposes.
       

    Gazette notice content

    Commissioner of Taxation - Notice of a data matching program

    The Australian Taxation Office (ATO) will acquire data from businesses that we visit as part of our employer obligations compliance program during the 2016-17; 2017-18 and 2018-19 financial years.

    The following information will be obtained from the data providers:

    • Australian Business Number (ABN) of the payer business.
    • ABN of the payee business (contractor).
    • Name of the contractor.
    • Address of the contractor.
    • Telephone details of the contractor.
    • Dates of payments to the contractor.
    • Amounts paid to the contractor (including details of whether the payment included GST).

    It is estimated that records for 25,000 of entities will be obtained, including the records of 12,500 individuals.

    These records will be electronically matched with ATO data holdings to identify non-compliance with registration, lodgment, reporting and payment obligations under taxation laws.

    The objectives of this data matching program are to:

    • Better tailor educational products and services to address identified areas of concern and give more certainty to taxpayers in managing their obligations
    • Promote voluntary compliance and strengthen community confidence in the integrity of the tax system by detecting and dealing with instances of non-compliance
    • Assess the integrity of the information held on the Australian Business Register to assist the Registrar develop educational and compliance strategies
    • Obtain intelligence to identify risks and trends about contractors that may not be complying with their taxation obligations
    • Ensure compliance with registration, lodgment, correct reporting and payment of taxation and superannuation obligations.

    A document describing this program has been prepared in consultation with the Office of the Australian Information Commissioner. A copy of this document is available at Data matching protocols

    The ATO complies with the Office of the Australian Information Commissioner’s Guidelines on data matching in Australian government administration (2014) which includes standards for data matching to protect the privacy of individuals. A full copy of the ATO’s privacy policy can be accessed at www.ato.gov.au/privacy

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    Legal matters

    Learn more about:

    Submission to the Privacy Commissioner

    Varying from the data destruction requirements

    The Australian Taxation Office (ATO) is seeking approval for the contractor payments 2016-17; 2017-18 and 2018-19 data matching program to vary from one or more of the conditions detailed in Guideline 10 of the Office of the Australian Information Commissioner’s Guidelines on data matching in Australian government administration (2014) (the Guidelines).

    We are seeking to retain data for five years from receipt of all verified data files from the data providers. We consider that a variation from the usual retention periods for this data matching program is in the public interest as:

    • There will be a delay between receiving the data and the taxpayer lodging relevant returns
    • Subsequent compliance issues may be identified within the period of review allowed by the law
    • Destruction of the data would inhibit the ATO’s ability to identify taxpayers who may be subject to administrative action and therefore result in loss of public revenue

    We have determined that this variation will not affect the privacy of an individual.

    This program will be subject to an evaluation within five years which is consistent with the requirements of Guideline 9.

    Additional information justifying this variation is included in the tables below:

    • Table 1 – matters considered in accordance with Guideline 10.2 in seeking this variation
    • Table 2 – consistency with requirements of the other guidelines issued by the Office of the Australian Information Commissioner

    We do not require that this request be kept confidential (Guideline 10.6) and have no concerns if the Office of the Australian Information Commissioner place this information on its website.

    Table 1: Matters considered in seeking this variation to the Guidelines

    Matter considered

    Consideration

    10.2.1

    The effect of not abiding by the specified requirements of the Guidelines would have on individual privacy

    • Retaining data for a period of five years will not increase the risks to an individual’s privacy. We have in place very secure processes for handling and storing data. Once acquired, all data will be stored on our secure computer systems where access is strictly controlled and full audit logs maintained.
    • Our staff operate under stringent confidentiality and privacy legislation that prohibits the improper access to or disclosure of protected information. These obligations are supported by significant penalties, including imprisonment. This substantially mitigates the risks of breaches of privacy.
     

    10.2.2

    The seriousness of the administrative or enforcement action that may flow from the data matching program

    • An extension of the retention period will not affect the seriousness of the administrative action that may flow from the match, but will assist in detecting non-compliance or taxation fraud.
    • Where we propose to take administrative action where a taxpayer may have reported incorrectly, the ATO will differentiate between those that try to do the right thing and those that set out to deliberately avoid their obligations. Documented procedures, including the Taxpayers’ Charter and compliance model will be followed to ensure fairness and consistency.
     

    10.2.3

    The effect that not abiding by the specified requirements of the Guidelines would have on the fairness of the program – including its effect on people’s ability to find out the basis for decisions that affect them and their ability to dispute those decisions

    • There will be no effect on the fairness of the program or the ability of taxpayers to find out the basis of decisions that impact them or their ability to dispute those decisions.
    • Before any administrative action is undertaken, taxpayers will be given at least 28 days to verify the accuracy of the information that has been derived from this data matching program.
    • Where administrative action is to be undertaken, we will adhere to the principles established in the Taxpayers’ Charter and compliance model to ensure an equitable and consistent approach is taken.
    • If a taxpayer does not agree with an assessment, they maintain the right to dispute the decision. They also have the legal right to appeal against those decisions through the courts and tribunals.
     

    10.2.4

    The effect that not abiding by the specified requirements of the Guidelines would have on the transparency and accountability of government operations

    • There will be no adverse effects on the transparency and accountability of government operations.
    • A program protocol is submitted to the Office of the Australian Information Commissioner and we will strictly adhere to the commitments in that document.
    • We will publish a notice with general information about the program in the Commonwealth government notices gazette before administrative action commences. We will also make a copy of the program protocol available on our website.
     

    10.2.5

    The effect that not abiding by the specified requirements of the Guidelines would have on compliance of the proposed program with the Australian Privacy Principles in the Privacy Act 1988

    • There will be no effect on compliance with the Australian Privacy Principles contained in Schedule 1 to the Privacy Act 1988 due to longer retention of the data. The data is collected is solely for the stated objectives established in the data matching program protocol.
     

    10.2.6

    The effect that abiding by all of the requirements of the Guidelines would have on the effectiveness of the proposed program

    • The effectiveness of the program would be reduced if the data retention period is not extended.
    • There would be a significant reduction in the our ability to detect incorrect reporting and taxation fraud without understanding and monitoring trends in the data collected.
    • The destruction of the data in accordance with the current guidelines would impact the integrity of the taxation system by:
      • limiting our ability to identify taxpayers who may be subject to administrative action
      • resulting in the loss of revenue.
       
     

    10.2.7

    Whether complying fully with the Guidelines could jeopardise or endanger the life or physical safety of information providers or could compromise the source of information provided in confidence

    • Not abiding by all the requirements of the Guidelines would not influence or affect the personal safety of any individual identified as part of the program or compromise the source of the information provided in confidence.
     

    10.2.8

    The effect that abiding by all the requirements of the Guidelines would have on public revenue – including tax revenue, personal benefit payments, debts to the Commonwealth and fraud against the Commonwealth

    • Not allowing the variation to the data retention period of the current program would cause us to miss potential breaches of taxation laws and subsequent non-payment of tax. This would result in the Commonwealth foregoing taxation revenue.
    • There are risks to the integrity of taxation system when people fail to comply with their obligations. Abiding by all of the requirements of the guidelines will reduce the effectiveness of proposed compliance activity. We would miss the opportunity to educate those taxpayers trying to do the right thing, and deterring those that are non-compliant from repeating the behaviour.
    • The effect of abiding by all of the requirements in the guidelines could negatively impact on both public revenue and public and government confidence in us. People not complying with their taxation obligations, including those operating outside the system, set a bad example to compliant taxpayers and may encourage their non-compliance. Maintaining community and government confidence in the taxation system is critical to our ongoing role.
     

    10.2.9

    Whether abiding by all of the requirements of the Guidelines would involve the release of a document that would be an exempt document under the Freedom of Information Act 1982

    • Only information relating to the taxpayer’s own affairs will be released upon receipt of a freedom of information request.
     

    10.210

    The legal authority for conducting the proposed program in a way inconsistent with the specified requirements of the Guidelines

    • There is no specific legislative power authorising the conduct of this program inconsistent with the Guidelines.
    • The Commissioner of Taxation, or his authorised representative, has formed the opinion that this data is required to enable us to effectively and efficiently carry out its legislated functions under the general powers of administration contained in:
      • Section 3A of the Taxation Administration Act 1953
      • Section 8 of the Income Tax Assessment Act 1936
      • Section 1-7 of the Income Tax Assessment Act 1997
      • Section 356-5 in Schedule 1 of the Taxation Administration Act 1953
       
    • The reasons for proposing to operate outside requirements of the Guidelines are detailed above.
     

    Table 2: Matters considered in seeking this variation to the Guidelines

    This section outlines where we are being consistent with the requirements of the Office of the Australian Information Commissioner’s Guidelines on data matching in Australian government administration (2014).

    Paragraph/Guideline

    Action taken/To be taken

    Paragraph 6

    Status of the Guidelines

    We are committed to complying with the Office of the Australian Information Commissioner’s Guidelines on data matching in Australian government administration (2014) by way of a chief executive instruction.

    Guideline 1

    Application of the Guide

    We apply the guidelines for all data matching programs where it is anticipated the program will include records of 5,000 or more individuals.

    We recognise that programs where there are multiple data sources but with common objectives and algorithms are treated as a single data matching program.

    Guideline 2

    Considerations before conducting a data matching program

    We conduct a cost-benefit analysis and consider alternate methods prior to proposing to conduct a data matching program.

    Further, we have rigorous governance arrangements, processes and system controls in place to protect the privacy of individuals.

    Guideline 3

    Prepare a program protocol

    Prior to conducting a data matching program, we prepare a data matching program protocol, submit this to the Office of the Australian Information Commissioner and make a copy publicly available on the ATO website

    When elements of a data matching program change, the protocol is amended and a copy of the amended protocol provided to the OAIC and updated our website.

    Guideline 4

    Technical standards report

    Documentation is prepared and maintained so as to satisfy the requirements of a technical standards report.

    Guideline 5

    Notify the public

    We publish notification of our intention to undertake data matching program in the Commonwealth government gazette notices prior to the commencement of the program.

    This notice will include the following information as required by the Guidelines:

    • a brief description of the objectives of the data matching program
    • the matching agency and source entities involved in the data matching program
    • a description of the data contained in the data set involved in the data matching program
    • the categories of individuals about whom personal information is to be matched
    • the approximate number of individuals affected
    • reference to our privacy policy.

    Notification of the program is also published on our website and data providers are advised they can advertise their participation in the data matching program.

    Guideline 6

    Notify individuals of proposed administrative action

    Prior to taking any administrative as a result of the data matching programs individuals and other entities are given at least 28 days to verify the accuracy of the information provided to us by third parties.

    Guideline 7

    Destroy information that is no longer required

    We are seeking to vary from this requirement.

    Guideline 8

    Do not create new registers, datasets or databases

    We do not create new registers or databases using data obtained in the course of a data matching program.

    Guideline 9

    Data matching program evaluations

    Programs are regularly evaluated within 3 years of the commencement of the data matching program. These evaluations are provided to the Office of the Australian Information Commissioner.

    Guideline 10

    Variations to guideline requirements

    When we intend to vary from the requirements of the Guidelines we seek the approval of the Office of the Australian Information Commissioner and provides documentation to support the variance.

    Guideline 11

    Data matching with entities other than agencies

    We undertake our own data matching programs. This function is not outsourced.

    Where data is obtained from an entity other than an individual, we usually do so using our formal information gathering powers. In these instances the entities are advised they are able to notify their clients of their participation in the data matching program.

    Guideline 12

    Data matching with exempt agencies

    We do not usually undertake data matching with agencies that are exempt from the operations of the Privacy Act 1988 under section 7 of that Act and that are subject to the operation of the Guidelines (i.e. any data matching undertaken with an exempt agency would usually be for fewer than 5,000 individuals).

    In the event a data matching activity would otherwise be subject to these Guidelines except for the exemption status, we still adhere to the principles of the Guidelines and prepare a program protocol, seeking to vary from the Guidelines by not publicly notifying of the program and publishing the protocol. We would still lodge a copy of the protocol with the Office of the Australian Information Commissioner.

    Guideline 13

    Enable review by the Office of the Australian Information Commissioner

    We would not prevent the Office of the Australian Information Commissioner from reviewing its data matching activities and processes. These activities and processes have been reviewed by the Australian National Audit Office and Inspector-General of Taxation.

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    More information

    What we will do before we amend a return

    Where we detect a discrepancy that requires verification we will contact the taxpayer usually by phone, letter or email.

    Before any administrative action is taken, taxpayers will be provided with the opportunity to verify the accuracy of the information obtained by us. Taxpayers will be given at least 28 days to respond before administrative action is taken.

    For example, where discrepancy matching identifies that a taxpayer is not reporting all of their income, but in fact they are reporting the income under another entity, the taxpayer will be given the opportunity to clarify the situation.

    The data may also be used to ensure that taxpayers are complying with their other taxation and superannuation obligations, including registration requirements, lodgment obligations and payment responsibilities.

    In cases where taxpayers fail to comply with these obligations, after being reminded of them, escalation for prosecution action may be instigated in appropriate circumstances.

    Where a taxpayer has correctly met its obligations, the use of the data will reduce the likelihood of contact from us.

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    Our on-disclosure provisions

    Division 355 of Schedule 1 to the Taxation Administration Act 1953 sets out the other government agencies we can disclose taxpayer information to, and the circumstances we are permitted to make those disclosures. These include agencies responsible for:

    • state and territory revenue laws
    • payments of social welfare and health and safety programs for determining eligibility for certain types of benefits and rebates
    • overseeing superannuation funds, corporations and financial market operators to ensure compliance with prudential regulations
    • determining entitlement to rehabilitation and compensation payments
    • law enforcement activities to assist with specific types of investigations.

    Each request for information by other agencies will be assessed on its merits and must be for an admissible purpose allowed for by taxation laws.

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    How we undertake data matching

    We use sophisticated identity matching techniques to ensure we identify the correct taxpayer when we obtain data from third parties. This technique uses multiple details to obtain an identity match. For example, where a name, address and date of birth are available all items are used in the identity matching process. Very high confidence matches will occur where all fields are matched.

    Additional manual processes may be undertaken where high confidence identity matches do not occur, or a decision taken to destroy the data with no further action.

    Where administrative action is proposed, additional checks will take place to ensure the correct taxpayer has been identified. The taxpayers will be provided with the opportunity to verify the accuracy of the information before any administrative action is taken.

    Data analysts use various models and techniques to detect potential discrepancies, such as under-reported income or over-reported deductions. Higher risk discrepancy matches will be loaded to our case management system and allocated to compliance staff for actioning.

    Lower risk discrepancy matches will be further analysed and a decision made to take some form of compliance or educational activity, or to destroy the data. In accordance with Guideline 7, where a decision is made not to take further action, the information that has been collected will be destroyed within 90 days of the decision not to take further action.

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    How we protect your personal information

    Our staff are subject to the strict confidentiality and privacy provisions contained in Division 355 of Schedule 1 to the Taxation Administration Act 1953 and include terms of imprisonment in cases of serious contravention of these provisions.

    All ATO computer systems are strictly controlled, with features including:

    • system access controls and security groupings
    • login identification codes and password protection
    • full audit trails of data files and system accesses.

    We will utilise our secure internet-based data transfer facility to obtain the data from source agencies.

    Where this is not possible, data providers will be requested to provide copies of the data on a CD, DVD or USB device encrypted to a standard that satisfies Australian government requirements. The magnetic media device will be password protected, with the password provided under separate cover to us.

    Where the data is not collected by an authorised ATO officer, an approved courier service will be used to collect the data. In remote locations not serviced by an approved courier service, the Australia Post ‘Express Post Platinum’ will be used (this provides both tracking and signature for delivery features).

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    Our quality assurance framework

    Quality assurance processes are integrated into our processes and computer systems and are applied throughout the data matching cycle.

    These assurance processes include:

    • registering the intention to undertake a data matching program on an internal register
    • obtaining approval from the data matching gatekeeper and relevant Senior Executive Service (SES) officers prior to any activity being undertaken
    • conducting program pilots or obtaining sample data to ensure the data matching program will achieve its objectives prior to full data sets being obtained
    • notifying the Office of the Australian Information Commissioner of our intention to undertake the data matching program and request permission to vary from the data matching guidelines (where applicable)
    • maintaining access management logs recording details of who has access to the data, why access is required and how it will be used
    • processes embedded into compliance activities, such as:
      • review of risk assessments, taxpayer profiles and case plans by senior officers prior to client contact
      • ongoing reviews of cases by subject matter technical experts at key points during the life cycle of a case
      • regular independent panel reviews of samples of case work to provide assurance of the accuracy and consistency of case work.
       

    These processes ensure data is collected and used in accordance with our data management policies and principles, and complies with the Information Commissioner's data matching guidelines.

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    Why we undertake data matching

    We have considered a range of alternatives to this data matching program to ensure entities are complying with their taxation and superannuation obligations. Relying only on data already held by the ATO is of limited value for the following reasons:

    • we only receive data from taxpayers that are correctly registered and meeting their lodgment obligations
    • we have no other data to cross-reference to ensure taxpayers are reporting their obligations correctly other than by directly contacting every taxpayer.

    This data matching program will allow us to identify taxpayers who are not fully complying with their obligations, as well as those that may be operating outside the taxation and superannuation systems. It will also reduce the likelihood of the ATO unnecessarily contacting taxpayers who appear to be complying with their taxation obligations.

    Data matching is an effective method of examining records of thousands of taxpayers to ensure compliance with lodgment and reporting obligations that would otherwise be a resource intensive exercise.

    Data matching also assists us in effectively promoting voluntary compliance by notifying the public of areas and activities under scrutiny.

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    Costs and benefits of data matching

    Costs

    There are some incidental costs to us in the conduct of this data matching program, but these will be more than offset by the total revenue protected. These costs include:

    • data analyst resources to identify potential instances of non-compliance
    • compliance resources to manage casework and educational activities
    • governance resources to ensure that the Guidelines and Privacy Act are complied with, and quality assurance work to ensure the rigour of the work undertaken by analysts and compliance staff
    • storage of the data.

    Benefits

    Benefits from conducting this data matching programs include:

    • maintaining community confidence in both the taxation and superannuation systems by creating a level playing field, as well as maintaining community confidence in the ATO’s capacity to fairly administer those systems
    • integrity of the taxation and superannuation systems – there are inherent risks in taxpayers not complying with their obligations, including those that deliberately abuse these systems – this program will assist the ATO in detecting, dealing with and deterring those that are not meeting their obligations
    • enabling enforcement activity and recovery of taxation revenue – without undertaking this data matching program and subsequent compliance activity there are no assurances that a wider risk to revenue does not exist.

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    Making a privacy complaint

    If a taxpayer is not satisfied with how we have collected, held, used or disclosed its personal information, they can make a formal complaint by:

    • using the online complaints form at Complaints
    • phoning our complaints line on 1800 199 010
    • phoning the National Relay Service on 13 36 77 (if you have a hearing, speech or communication impairment)
    • sending us a free fax on 1800 060 063
    • writing to us at:

    ATO Complaints

    PO Box 1271

    ALBURY NSW 2640.

    If a taxpayer is not satisfied with the outcome of the privacy complaint, they can contact the Office of the Australian Information Commissioner. More details on the process can be found on the OAIC website at How doI make a privacy complaint?External Link

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    Our lawful role

    The Commissioner of Taxation has responsibility for ensuring taxpayers meet their taxation and superannuation obligations. Compliance with these obligations is a matter we take seriously and failure to address non-compliant behaviour has the potential to undermine community confidence in the integrity of the taxation and superannuation systems and our capacity to administer those systems.

    Our data matching program is one of the strategies used to identity and deal with non-compliant behaviour. Data matching programs also provide a degree of assurance that taxpayers are meeting their obligations.

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    Our legal authority to undertake a data matching program

    ATO legislation

    The data will be obtained under our formal information gathering powers contained in section 353-10 of Schedule 1 to the Taxation Administration Act 1953.

    This is a coercive power that obligate the data providers to furnish the information requested. We will use the information for taxation and superannuation compliance purposes.

    Privacy Act

    Data will only be used within the limits prescribed by Australian Privacy Principle 6 (APP6) contained in Schedule 1 of the Privacy Act 1988 and in particular:

    • APP6.2(b) – the use of the information is required or authorised by an Australian law
    • APP6.2(e) – the ATO reasonably believes that the use of the information is reasonably necessary for our enforcement related activities.

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      Last modified: 13 Apr 2016QC 48688