Privacy Policy & Procedures

Reclaims UK North West LTD · Company Registration: 07570259

Money Laundering, Terrorist Financing and Transfer of Funds

Reclaims UK North West LTD operates with reference to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. Our client base is via a government department, the MOD. Prospective clients have been subject to identity checks, residency rules and security checks, and clients will have created an account on the MOD Portal Defence Gateway. Reclaims UK may occasionally create the tax account with agreement from the client.

1. SWOT Analysis

Strengths

• Experienced staff
• Professional behaviour
• Established business since 2011
• Recurring client base

Weaknesses

• Open to scamming
• Weekly basis (online and telephone)

Opportunities

• Being invited to and visiting MOD premises, where identities are checked by MOD personnel
• Face-to-face meetings with clients
• Involvement in MOD-sponsored events

Threats

• Cyber attacks
• Scamming / possible impersonation
• Competitor companies

2. Risk of Fraudulent Characters

We assess the risk as low due to the nature of our client base. Clients have previously undertaken identity checks prior to engagement with the British Armed Forces. We carry out due diligence as far as possible and do not deal with high-value claims or a cash business.

To confirm identity and eligibility, we may collect and check:

• Full name
• Residential address within the last four years
• Date of birth
• National Insurance number
• Car registration number
• Front and back of driving licence
• Government-issued passport
• Recent pay statement / P60
• Proof of vehicle ownership
• Odometer reading to confirm mileage
• MOT checks through the government MOT service

No claim can be processed without the required documents being collected. Suspected false documentation is red-flagged and challenged. If there is doubt about a client's identity, the claim is suspended while additional checks are carried out.

3. Process of a Claim

Eligibility

• Temporary workplace: two years or less
• Courses within the UK lasting three weeks or longer

Stages

• Identity, eligibility and risk checks are completed.
• Calculations are completed.
• We wait for HMRC approval to act on the customer's behalf through a 64-8 authorisation and subsequently a UTR number.
• Secondary checks of eligibility and documents are completed.
• Figures and calculations are checked.
• On completion, a tax return is sent to the client for approval and signature via DocuSign.
• The approved return is submitted through third-party software to HMRC.
• When payment is approved, bank details are securely confirmed and payment is sent to the client, with payment records maintained.

Client information is checked yearly for customers who wish to claim each tax year.

4. Proliferation

Proliferation financing is the provision of funds or services for the development, possession or use of weapons of mass destruction or related materials, technologies and dual-use goods. Reclaims UK considers this risk low for its business model.

We communicate relevant risks to staff through regular meetings and training. Potential red flags include dealings with high-risk jurisdictions or sanctioned entities, customers linked to proliferation-sensitive industries, complex financial structures with vague end users, and inconsistencies in trade documents and financial flows.

Reclaims UK has over 14 years of industry experience and maintains a commitment to safety, security and best practice. If financial criminality is suspected, the matter would be reported to HMRC as appropriate.

5. Enhanced Due Diligence

Based on the company's risk assessment framework, the current client base does not fall into high-risk categories requiring enhanced due diligence. Standard company due diligence is maintained.

6. Politically Exposed Persons (PEPs)

A politically exposed person is an individual entrusted with prominent public functions. Because of their position, PEPs can present a higher risk of corruption or bribery, and associated risks can extend to close business associates and family members.

Examples include heads of state, government ministers, members of parliament or legislative bodies, members of governing bodies of political parties, members of supreme courts and senior officials in state-owned enterprises or central banks. In the context of Reclaims UK, high-ranking military officers may require referral to the company's AML policy/software.

7. Geographic Nationwide Client Base

We operate nationwide through regular or annual visits to army bases in the north and south of the United Kingdom and through Ministry of Defence functions and events. We assess AML risk as low on an equal basis across the UK.

8. Customer Data, Privacy and Cookies Policy

This Privacy and Cookies Policy sets out the basis on which personal data we collect from you, or that you provide to us, will be processed. We use personal data in a way that is fair, relevant and necessary, and retain it only for as long as required for the purpose for which it was collected or as required by law.

For data protection purposes, the data controller is Reclaims UK Northwest Limited.

Types of personal data we may collect

• Identity Data: first name, last name or similar identifier, and government identification details such as National Insurance number.
• Contact Data: address, email address and telephone numbers.
• Transaction Data: information about roles, vehicles, tax-related information and other information explicitly requested to support your claim. This information may be sent to service providers used to process or sign your claim documents.
• Technical Data: IP address, time zone, browser and device information, mobile network information and operating system.
• Usage Data: information about how you use the website and services, including traffic, weblog and communication data.
• Marketing and Communications Data: your preferences for receiving marketing and other communications.

Disclosures of your personal data

We may share personal data where necessary with business partners, professional advisers, HM Revenue & Customs, regulators and other authorities, and service providers used for digital signatures, tax processing and AML checks. Third parties are required to respect the security of personal data and process it only for specified purposes and in accordance with our instructions.

We follow the Data Protection Act 2018 and UK GDPR rules and regulations.

Document destruction

Post and client document waste is sent to USHRED SHREDDING SOLUTIONS LTD, Unit 10 Windal Court, Neston, CH64 3UH.

Contact

Company Registration: 07570259