As a third party administration and payroll provider for pension schemes, clients sometimes change providers. By nature we regularly submit FPS adjustments and EYU's because of retuned payments, suspended records where existence is being re-established and late notifications of death of pensioners.
If the PAYE tax reference transfers, the historic payslip and P60 data (including pay and tax details) is migrated to the new provider but not the original RTI file as this usually contains member records in addition to those being migrated. As the RTI files are the source of what was submitted to HMRC outside the data HMRC hold, how long should we retain the file and record of successful receipt?
If the PAYE tax reference closes, the historic payslip and P60 data (including pay and tax details) is migrated. The new administrator may or may not load all the historic data to their database. As our RTI file is the only source of what was submitted to HMRC outside the data HMRC hold, how long should we retain the file and record of successful receipt? How long should we retain the payroll and RTI history on our database / in our archive to process queries?
Some pensioner adjustments can go back a number of years as finalising an estate can be an exceptionally length process. HMRC can demand tax they believe is owed going back more than the 4 year recovery period employers can claim. What data items should we retain as a minimum in case we receive a query and at what point can we safely delete it?
In the event of a split migration: Scenario PAYE transfers to payroll A along with half the pensioners, Payroll B take the other half and members join a different PAYE, how does HMRC view the responsibility in light of GDPR? Should Payroll A take all the PAYE information eg RTI files?
Apologies for the lengthy submission, any assistance is appreciated. Thank you