The Pensions Regulator (TPR) is asking schemes to submit additional information about their data as part of the annual scheme return. For defined benefit schemes, this applies to annual return notices issued from January 2018 and for defined contribution schemes, it applies to annual return notices issued from summer 2018.
TPR will ask two extra questions around the scheme’s last data review and what the scheme's data score is. The data score is the percentage of members for which the scheme has full and accurate common data, now called scheme-specific data. The aim is to encourage good pension administration and so better member outcomes, but it also ties neatly into the new GDPR requirements arising from 25 May 2018 onwards.
Trustees and their scheme administrator must work together to build a list of scheme-specific data, which helps to assess how well the scheme is running. They should also agree why each data area is key. The list might include:
• Employment records like an employer's name, salary records and service history
• Employee and employer contribution history
• Investment decisions
• Any benefit specifics like GMP entitlement, HMRC protections or cash entitlements
Consideration should also be given as to why some data isn't relevant to a scheme so it doesn't need to be collected or measured. For example, benefits may be calculated based on the highest salary earned within the last five years (or the five years prior to leaving), so the scheme doesn't need to keep older pensionable salary information.
Schemes also need to measure common data. This is the list of details about scheme members so they can be identified and includes a member's surname, date of birth, national insurance number, address and what age a member is expected to retire.
TPR are preparing a new Quick Guide to Measuring Data, including how to calculate a data score, which will be available on their website from November 2018, to accompany their existing A Quick Guide to Record Keeping. They will also be including some questions and answers on this on the scheme return checklist, which tells trustees and administrators what's changed on the scheme return.
TPR is not going to act immediately if scores are low but TPR will expect trustees and administrators to take action to improve.
Published:26 October 2017
Pensions Law Update - October 2017
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