Contractors’ Questions: Should I hand a Spanish client my address, NI number and passport?

Contractor’s Question: I`m an independent worker based in the UK. I took on some freelance, contract work with a Spanish company in March. However they have just asked me to provide them with my address, NI number and passport number, ahead of potential renewal in July.

When I asked them what the information is for, they stated: “It is a legal requirement that has recently come in to effect here for us to collate all the personal information and submit it to a data protection company so that this sensitive information will not be passed on to a third party and will be protected and secure.”

They also told me: “Once we have the requested information, we will send you a legal document to sign in due course to confirm that you wish to have your information protected under the Data Protection Act.”

It sounds to me like they are actually trying to protect my information, but if they don`t have it in the first place, surely they don`t need to protect it?! Is their request normal? I only ask, because none of my clients have ever asked for any of my personal information before.  

I work from home managing and administering online platforms, products, and portals for this particular client, but I don`t think I have access to any confidential business information. Any help appreciated as to what this Spanish firm wants with my passport and other identifiers.

Expert’s Answer: You are right in saying that the Spanish company do not need to protect your data if they do not have it in the first place!

However, there might be reasons why they asked for it. They more than likely need this data as part of their ‘KYC’ (Know Your Client) procedure.

KYC is a regulatory requirement which, if not carried out, can lead to accusations of taking insufficient care to root out money-laundering and fraud which are, of course, criminal matters.


If the company carries out this procedure, it means that they can always ascertain that they are working with and paying for a real person, whose identity can be verified by the authorities, if needed. In this regard, it is legitimate for them to ask you for it, and you may provide the information, as long as they can guarantee the protection of your data.

According to the international GDPR (General Data Protection Regulation) legislation, you have certain internationally-guaranteed rights when sharing your data with any client, as outlined by the Information Commissioner's Office (ICO). You can visit the commissioner’s website here.

As you can read about on the ICO’s site, you have a right to see what data the data protection company they mention is holding on you, and you have a right to be able to correct it if it is not accurate. So it is your legal right to know who is holding your data. If you are so minded, you can even ask to see their registration with the appropriate data protection body which, in the UK, would be the ICO.

We ask for these identifiers too

For your background information, you might wish to note that, as an overseas contracting advisory and payroll provider, we always insist on seeing a client’s passport as evidence of their identity. This is part of the standard anti-money laundering procedure that companies such as ours need to follow. Ideally, this would be with you in front of me, but in the current climate of covid-19 and social distancing, at least on Zoom. I have seen several cases of late of solicitors accepting remote certification. Ordinarily, it is widespread to be asked to have your passport certified by a professionally qualified person who is not related to you.

As to the request for your address, there is not much point in ‘Knowing Your Client’ if you are not able to contact them. Proof of address is also supporting evidence that you are who you say you are.

Lastly, you say the client wants your National Insurance Number. Probably, this is for the above two reasons but it would also constitute evidence that you are known to the authorities and, presumably, paying your taxes and social contributions.

Odd, but not alarming

Standing back from the detail, I think your client has put this request to you in a slightly strange way. But I do not think it is ominous, more a barrera del idioma (language barrier). I do not feel you need to worry about furnishing the data they need to satisfy their regulatory authorities. It is good that they are regulated.

The expert was Kevin Austin, managing director of overseas contracting advisory Access Financial.

Wednesday 8th Jul 2020
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Written by Kevin Austin

Kevin is a Fellow of the Institute of Chartered Accountants in England and Wales, a Fellow of the Association of Chartered Certified Accountants, a Fellow of the Association of International Accountants and a Fellow of the Chartered Management Institute.

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