The 2018 Scheme Return for both defined benefit and defined contribution pension schemes will include new questions about the scheme’s data. Schemes will be asked to report on when they last reviewed their ‘common’ and ‘scheme-specific’ data and how much of this data is complete and accurate.
‘Common’ data are basic data items that are common to all schemes and are used to identify scheme members. It includes a member’s National Insurance number, surname, date of birth and address. ‘Scheme-specific’ data (also called ‘conditional’ data) are other types of member data that the trustees need to hold in order to enable them to administer their particular scheme. Scheme-specific data will vary from scheme to scheme and will depend on a number of factors, including scheme type and structure.
The Pensions Regulator (TPR) is asking for this information so that it can measure the quality of record-keeping in the pensions industry and track the progress of individual schemes. It is also aiming to use the information as part of a drive to improve the quality of record-keeping in pension schemes.
The requirement to measure common and scheme-specific data is not new. However, with the changes to the 2018 Scheme Return and trustees also needing to review their data and record keeping for the purposes of preparing for the new General Data Protection Regulation, it is important that schemes are taking action now to ensure that their data is in good order.
Trustees should engage with their scheme administrator to understand the controls they have in place to ensure the quality of data, have confidence that these controls are sufficient for the needs of the scheme and should receive regular reports on the data.
Whilst TPR has confirmed that it will not take enforcement action on the basis of a scheme’s data measurements alone, if it has concerns about standards not being met, it may engage with individual schemes, which may result in action being taken where the trustees fail to demonstrate that they are taking ‘appropriate steps’ to improve their records.
To assist trustees, TPR has published a checklist, as well as a new guide (‘A quick guide to measuring your data’), to accompany their existing guide, ‘A quick guide to record-keeping.