Thursday, 11 October 2012

HMRC and Skyscape

The following open letter has been sent by email* to Lin Homer in her capacity as Chief Executive, Permanent Secretary and Commissioner of HMRC:


Open letter [1]


Lin Homer CB

Chief Executive, Permanent Secretary and Commissioner
Her Majesty’s Revenue and Customs (HMRC) 11 October 2012
Dear Ms Homer

HMRC and Skyscape Cloud Services Ltd

On 26 September 2012 HMRC announced in a press release [2] that the Department had contracted with Skyscape Cloud Services Ltd to store its data in the cloud [3] with a view to increasing “efficiency” and “reliability” while providing “cheaper”, “more secure and greener” services to the public.
Enquiries at Companies House reveal that Skyscape was incorporated as company no. 07619797 on 3 May 2011 and hasn’t yet submitted any accounts. It is impossible for the public therefore to assess the company’s track record and its financial strength.
Skyscape may not have submitted any accounts but it has submitted an annual return as at 3 May 2012 according to which:
· It has no company secretary and just one director, Mr Jeremy Robin Sanders
· Skyscape has just £1,000 of paid-up share capital
· There is only one shareholder, the same Mr Sanders
· The company’s registered office is at Hartham Park, Hartham, Corsham, Wilts SN13 0RP
Questions must arise in the public’s mind whether Skyscape – being so new and so small – is a suitable company to host web access to all our HMRC records.
One share in Skyscape was held by Mr Jeffery (sic) Paul Thomas until 29 April 2012 when it was transferred to Mr Sanders. Skyscape mention on their website [4] a company called ARK Continuity Ltd. Enquiries at Companies House reveal that ARK Continuity has three directors, one of them being Mr Jeffrey (sic) Paul Thomas.
The other two directors are bankers appointed to protect the interests of Revcap Properties 25 Ltd, a property fund. ARK Continuity has filed accounts as at 30 April 2011 according to which its ultimate parent company is Real Estate Venture Capital Partners LLP.
According to its 16 December 2011 annual return:
· ARK Continuity has £16 of issued share capital, not all paid up
· Mr Thomas’s interest in the company is a nominal £3.20
· The company’s registered office is at Hartham Park, Hartham, Corsham, Wilts SN13 0RP
The business relationship between Skyscape and ARK Continuity is unclear. It is described as an “alliance” on the Skyscape website but what is an alliance in this case? It doesn’t look like a joint venture or a partnership. The question must arise in the public’s mind just what the business relationship is and what HMRC are relying on for the storage of our data entrusted to the Department’s care.
ARK Continuity’s principal activity is “the design, construction and operation of data centres”. They’re a property company and naturally enough they proudly describe their major product, the Spring Park data centre, on their website [5] including a map how to get there and the address – Hartham Park, Corsham, Wiltshire SN13 0RP.
Skyscape, ARK Continuity and Spring Park all have the same address. It is possible that the location of the data centre at which the public’s HMRC data is being stored has been advertised for everyone to see on ARK Continuity’s website – everyone including terrorists and hackers. That looks like a potential breach of security.
By this stage, Ms Homer, you will agree that every claim made in HMRC’s 26 September 2012 press release is questionable. The decision to contract with Skyscape and the conduct of the business relationship so far appear dangerous, imprudent, ill-advised, unprofessional, wrong-headed, unbusinesslike, undignified and irresponsible. Could I ask you please to comment on these matters of public interest.
Yours sincerely
David Moss
cc      Chartered Institute of Taxation
Institute of Chartered Accountants in England and Wales




[1] HMRC and Skyscape, http://www.dmossesq.com/2012/10/hmrc-and-skyscape.html
[2] HMRC first for new IT contract, http://press.hmrc.gov.uk/Press-Releases/HMRC-first-for-new-IT-contract-680b1.aspx
[3] HMG's cloud computing strategy – there isn't one, http://www.dmossesq.com/2012/06/hmgs-cloud-computing-strategy-there.html
[4] Skyscape Cloud Alliance, http://www.skyscapecloud.com/about/the-skyscape-cloud-alliance
[5] Spring Park, http://www.arkcontinuity.co.uk/contact-spring-park.html 
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* and by post, the hard copy letter should have arrived with the HMRC Correspondence Team at Somerset House by 16 October 2012. Acknowledgement dated 17 October 2012 received 22 October 2012 promising response "within the next 15 working days".

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