Suppressions policy

Guidance

This is important to read if you use Overseas Trade in Goods Statistics (OTS). It is the statement of the Suppressions Policy of the Trade Statistics area of HM Revenue and Customs (HMRC).

Introduction

A suppression is the concealing of potentially disclosive information from the public. OTS data published by HMRC can fall into that category.

Disclosive data is any data that can either:

• reveal the commercial activities of a business
• be against the national interest if published

It may therefore be necessary to withhold the publication of such statistics. This disclosive data is then aggregated to a higher level of detail. This is so that such inferences are not made.

Aim of this policy

The aim of this policy is to meet both of these needs:

• allow for publication of as much detailed trade data as possible
• protecting sensitive business and national interests by preventing disclosure where there is a clear need to do so

This statement is to inform data users or sharers about both:

• suppressions made to published trade data
• the basis for their application

HMRC aims to ensure that users or sharers of published trade in goods statistics data are aware of the following:

• what suppressions are
• the reasons for suppressing data
• the differences between the types of suppression
• the differences between the three levels of suppression applied by HMRC
• how applications for suppressions can be made
• how applications for suppression are evaluated
• how suppressions are applied and publicised
• how reviews of suppressions get reviewed (including any correspondence between HMRC and businesses)

Policy details

Confidentiality systems

There are two main types of Confidentiality System used in Official Statistics.

An 'Active' confidentiality system

This involves evaluating all data. Data that can reveal the commercial activities of an individual business will be automatically suppressed. This is the standard for Official Statistics.

A 'Passive' confidentiality system

Under this, data is only suppressed if a request for suppression is granted. With this system it is acceptable to publish disclosive data. If no suppression of any data gets requested, it will be published. This is regardless of whether such data reveals commercial activities or not.

When publishing the OTS, HMRC follows a passive confidentiality system. Requests for suppressions from a business or government department get reviewed.

If required, they will be applied at a certain level, using the Combined Nomenclature (CN) system. This classifies goods up to an 8-digit number.

Due to this rule OTS are exempt from active confidentiality. This is normally applied under the UK Statistics Authority’s Code of Practice for Official Statistics.

Our commitments

HMRC is committed to the following within the suppression rules:

• protecting the interests of the individual business
• publishing the trade statistics to the fullest extent possible 
• ensuring a trader's right to confidentiality gets maintained

Our aim is to publish the most detailed information, whilst maintaining confidentiality for the individual business. We review which of the three levels of suppression should be applied to achieve this. 

Suppressions get applied at commodity code level for specific flows. The four flows are non-EU imports, non-EU exports, EU imports and EU exports.

Types of suppression

Commercial suppression

This gets applied at the request of the reporting businesses themselves. They make the request if they believe publication will reveal trade details they want to keep confidential. This is because they may not want competitors or customers to know certain information. This could include details about:

• supply
• trade levels
• unit costs

Businesses can either:

• be specific about the level of suppression they want
• give details of the published statistics they do not want disclosed (meaning they specify a level indirectly). 

Strategic suppression

This gets requested by other government departments and agencies. This is if they believe that publication of detailed information would be against the national interest.

Levels of suppression for a specific commodity code

There are three levels of suppression that can be applied.

Level 3: Countries, Ports and Quantity for Total Trade

Value gets published for total trade in the commodity code. However, there is no value breakdown for partner country and port. There is complete suppression of quantity. That means that no quantity data gets published at partner country and port level or for total trade.

Level 2: Countries and Ports

Value and quantity are only published for total trade in the commodity code. Both of these, with all concerned partner countries and ports, get suppressed:

• value of trade
• quantity of trade

Level 1: Complete Suppression

No statistics get published for the specific commodity code.

Note for all levels: Quantity data refers to net mass and supplementary unit data. This is where these units are required for that particular commodity code under that specific flow.

Application for commercial suppression

Businesses requesting a suppression on reported trade in the UK must supply HMRC with the relevant details on uktradeinfo@hmrc.gov.uk.

Those details are:

• full business name and VAT number
• contact details
• details of their perceived trading position

For example, they must declare that they believe they are any of the following:

• a ‘sole exporter or importer for a commodity’
• a ‘sole exporter or importer to or from a specific partner country or countries’
• a ‘sole exporter or importer of a specific port’

Suppressions can be applied on commodity codes in these scenarios:

• those in which businesses currently trade
• those in which they expect to start trading in

Email the customer services team on uktradeinfo@hmrc.gov.uk for more information.

Suppression application evaluation

Commercial suppressions get accepted or rejected based on the ‘value’ and ‘quantity’ of a requesters's trade. This is both in terms of:

• the overall market
• the market within individual partner countries and UK ports

This information gets used to allocate a level of suppression in each case. To be clear, the details of a requester’s trade are checked against specified criteria for each level of suppression for eligibility.

Strategic suppressions are applied by HMRC at the request of another government department. This will be to protect the national interest.

Fulfilling criteria and obligations for suppression.

HMRC will raise a suppression at the most appropriate level if both: 

• an application for a commercial suppression has been made

• a requester’s trade fulfils the necessary criteria

Businesses can request a suppression at a specific level. However, their trade may not fulfill the criteria needed for that particular level of suppression. In such cases, HMRC will offer and subsequently apply suppression at a more appropriate level if possible.

There may be cases where the trade for an individual business comes close to fulfilling the criteria for suppression at a specific level. 

Such cases will be further reviewed. The Lead Statistician will judge if suppression is required and, if so, at what level.

All strategic suppression requests get discussed with the requesting government department. A mutual agreement will then be reached on the appropriate level of suppression.

Applying suppressions

Suppressions get allocated to data at 8-digit commodity code level. These suppressions are then automatically applied at these more aggregated levels:

• 6-digit and 4-digit Combined Nomenclature (CN)
• 5-digit and 4-digit Standard International Trade Classification (SITC)

No suppressions get applied on data that has been aggregated at a higher level. This is SITC 3-digit and HS 2-digit (Harmonised System).

The commodity code the suppression gets requested for is known as the ‘target’. 

A number of commodity codes can be grouped together under a higher-level SITC heading. 

Preventing trade details of the suppressed commodity code being calculated by a process of deduction usually needs another step. This is to apply a similar suppression to another commodity code within that group. This second suppressed code is known as the ‘mask’. 

Regional Trade in Goods Statistics

Regional Trade in Goods Statistics (RTS) data is only available and published:

• at the aggregated SITC division (2-digit) level for Sections 1 to 8
• at Section level (1-digit) for section 9 of the SITC

No further suppressions get applied to published data. RTS data is only published at this aggregated level. This means none of the commodity code-based suppressions used in OTS get applied to RTS data.

Currency of Invoicing

Currency of Invoicing (COI) data is only available and published at the aggregated SITC Section (1-digit) level for these groups:

• four major currencies
• other

No further suppressions are applied to published data. COI data is only published at this aggregated level. This means none of the commodity code based suppressions used in OTS get applied to COI data.

UK Trade in Goods by Business Characteristics

These statistics are subject to active disclosure controls with these applied:

• a threshold (based on business count)
• a dominance rule (this is to reduce the chance of the trade of a trader who dominates a commodity being identified)

Where the data has been suppressed, extra suppressions ('masks') are used. This is to make it impossible to calculate the suppressed cells.

Data not already in public domain

It can be possible to release trade statistics data that is not already in the public domain. This means that which is not routinely already published or made available as part of the OTS or RTS. 

This is subject to meeting other data security and legal requirements. In such instances, active confidentiality will get applied to all such requests.

Publicity

Whenever a new suppression is granted on a commodity code, the updated list of applied suppressions is published on this site. Find the link to the current list of applied suppressions under ‘Further information’ on this page.

Review of suppressions

Commercial and Strategic suppressions get reviewed every year.

Businesses are contacted and asked to confirm if they want suppressions that remain justified kept in place. They have three weeks from that point to provide that confirmation.

They will then be given a suppression at the most suitable level. This is regardless of whether this increases or decreases the level of disclosivity.

If the suppression is no longer required by the business it will be lifted.

Where the suppression is no longer justified the relevant business is advised by HMRC. The suppression is then lifted.

When a strategic suppression is no longer justified, lifting it may reveal sensitive details of a business’ activity.  

Therefore ahead of a strategic suppression getting lifted, we will contact such businesses. This is to give them the chance to request a commercial suppression before the data gets published.

Changes in Combined Nomenclature

The Combined Nomenclature (CN) is updated on an annual basis. This is to reflect current commodity code usage and requests to change existing descriptions. 

All suppressions that existed on the commodity codes affected by updates to the CN, are applied to:

• any new related commodity codes that are created
• any directly related commodity codes that are created

Where a currently suppressed commodity code merges into one or more new codes, the resulting codes are automatically suppressed.

However, those affected codes get reviewed as soon as possible to establish if the suppression should remain.

Governance

This policy is designed to meet the recommendations for the Passive confidentiality outlined by the UN International Merchandise Trade Statistics (IMTS) Concepts and Definitions.

It also adheres to the UK Statistics Authority’s Code of Practice for Official Statistics concerning passive and active suppression systems.

Further information

Currently applied suppressions

If you need any more details about suppressions please contact our customer services team on:

Telephone: 03000 594 250

Email: uktradeinfo@hmrc.gov.uk.