Privacy Policy

1. Who We Are

We provide an online HMRC Self Assessment filing service for UK self-employed individuals.

Contact: privacy@clearyear.co.uk

2. What Data We Collect

We collect the minimum data necessary to file your return and to keep the audit trail HMRC requires:

• Email address — for payment receipt, submission confirmation, and service communications
• NINO & UTR — used during your session to submit to HMRC. We do not store these in plaintext; a one-way SHA256 hash is retained against your submission record, so we can recognise repeat or amended filings without holding the identifier itself
• Income, expenses, and calculated tax figures (e.g. turnover, expense totals, tax due or refund amount, CIS deductions, State Pension amount declared) — retained against your submission record. These are not linked to your plaintext NINO/UTR (only the hash), but HMRC requires we be able to produce evidence of what was actually filed, so these figures are not deleted after your session ends
• Occupation category — retained against your submission record
• IP address — stored in our step-by-step audit log as required for HMRC traceability
• Payment reference — Stripe session/payment intent IDs stored for dispute resolution and accounting (no card data — see §8)
• HMRC OAuth access token (Making Tax Digital filings only) — held temporarily on our server for the duration of your submission attempt, then wiped immediately afterward (see §3)

3. What We Do NOT Store

Note: unlike NINO/UTR, the income, expense, and tax figures you enter are retained against your submission record (see §2) — they're needed to satisfy HMRC's record-keeping requirement (§5) and to help you or our support team verify what was actually submitted if a question arises later.

4. Legal Basis for Processing

We process your data under Article 6(1)(b) GDPR — processing necessary for the performance of a contract (filing your tax return).

Submission records and audit logs are retained under Article 6(1)(c) — legal obligation (HMRC requires we can evidence what was filed and when).

5. Data Retention

• Browser session cookie (your name, email, NINO/UTR, tax year for the filing in progress) — cleared when you start a new filing attempt; not proactively wiped mid-session otherwise, so closing your browser without clearing cookies does not immediately erase it from your device
• Submission records (hashed NINO/UTR, income/expense/tax figures, status) — retained for 6 years (HMRC statutory requirement)
• Audit logs (step-by-step record of what was submitted, IP address) — retained for 6 years
• Payment records — retained for 6 years (financial record-keeping)

Automatic deletion once the 6-year period expires is not yet a scheduled/automated process — it is currently handled by manual review. We're working towards automating this.

6. Third Parties

• HMRC — your tax return data is submitted to HMRC as the primary purpose of this service
• Stripe — payment processing. Stripe's privacy policy applies to card data
• Brevo — sends your submission confirmation email and PDF receipt on our behalf. Brevo processes your email address and the emailed PDF content for this purpose only

We do not sell, rent, or share your data with any other third parties.

7. Your Rights (GDPR)

• Right of access — request a copy of your data
• Right to erasure — you can clear your current browser session at any time via the in-app option, which removes your name/email/NINO/UTR from that session immediately. For submission records, audit logs, and payment records, we're legally required to retain these for 6 years (§5) and cannot delete them before then; you can still request erasure of anything not covered by that obligation by emailing us
• Right to rectification — correct inaccurate data
• Right to portability — receive your data in machine-readable format
• Right to object — object to processing in certain circumstances

To exercise any of these rights, email: privacy@clearyear.co.uk — we currently handle access/rectification/portability/objection requests manually and will respond within one month, as required by GDPR.

8. Security

All data is transmitted over HTTPS. NINO and UTR are hashed using SHA256 before storage — the plaintext values are never written to our database. HMRC OAuth access tokens are held server-side only for the duration of a submission attempt and are wiped immediately once it completes, whether it succeeds or fails. We never store your HMRC Government Gateway password or your card details — those are used transiently (password) or handled entirely by HMRC/Stripe respectively.

9. Complaints

If you have concerns about our data practices, you may contact the Information Commissioner's Office (ICO) at ico.org.uk.