Record keeping

General code in force: 28 March 2024

This module forms part of our expectations for trustees of those schemes required to operate an effective system of governance, see Systems of governance.

1. Governing bodies are required to maintain complete and accurate records^1,2. This is to ensure that governing bodies can pay the right member (or beneficiary) the right benefit at the right time.
2. Under section 249A of the Pensions Act 2004³, governing bodies of certain schemes must establish and operate an effective system of governance (see Systems of governance) including internal controls (see Internal controls). However, there are certain exemptions⁴. The system of governance must be proportionate to the size, nature, scale, and complexity of the activities of the scheme.
3. The Public Service Pensions (Record Keeping and Miscellaneous Amendments) Regulations 2014⁵ set out the records that must be maintained by governing bodies of public service pension schemes. Under section 249B of the Pensions Act 2004⁶, scheme managers of public service pension schemes⁷ are required to establish and operate internal controls which are adequate for the purpose of securing that the scheme is administered and managed in accordance with the scheme rules⁸, and with the requirements of the law.
4. Governing bodies must in any event keep records of information relating to transactions^9,10 and meetings of the governing body and decisions^11,12.
5. Governing bodies should have a series of measures in place to maintain scheme records. See also Data monitoring and improvement.

Record-keeping

6. Governing bodies should:
   1. be able to demonstrate to us, where required, that they operate processes to maintain accurate and up-to-date records, enough to run their pension scheme
   2. keep records of meetings, member data, and transactions made to and from the scheme
   3. retain records for as long as the information is relevant, and in line with data protection legislation
   4. ensure that the data they or their administrator holds, enables financial transactions to be processed accurately. See Financial transactions.
   5. rectify any errors identified in scheme records as soon as possible
   6. review and amend processes as necessary to prevent further errors
   7. comply with the data protection requirements, including the need to store data securely and for a legitimate purpose under administrative systems
7. Governing bodies may consider as good practice:
   1. Holding member and benefit records electronically on a dedicated administration system.
   2. Keeping records of scheme governing documentation, including details of any amendments and how they apply to members.
   3. Making sure the administrator has basic member information known as common data.
   4. Working with the administrator to identify, record, validate, and where necessary, correct the items of scheme specific data.
   5. Taking into account developments in technology that may be available to the scheme to improve administration and record-keeping.

Administrative systems

8. Governing bodies should:
   1. ensure that processes exist to record member benefits, identifiers, contributions, investments, member decisions, payments, and transfers
   2. record accurate investments and disinvestments
   3. accurately perform benefit calculations
   4. provide members with accurate information regarding their pension benefits (both accrued and projected entitlements) as required and on a timely basis¹³
   5. carry out reconciliations of data, transactions, and investments held
   6. identify members approaching retirement and other scheme specific events
9. Governing bodies may consider as good practice:
   1. Processing financial transactions, including core transactions automatically (where feasible) and securely. See Financial transactions.
   2. Generating appropriate reporting on historic contributions, membership movements, and core and scheme specific data. See our record-keeping guidance.

Data from other parties

10. Governing bodies should:
    1. have processes in place enabling participating employers to provide timely and accurate data
    2. ensure that appropriate procedures are in place to reconcile employer data and scheme data
    3. have processes in place for situations where an employer fails to meet their legal duties to the scheme (see Decision to report for more information)
11. Governing bodies may consider as good practice:
    1. Educating employers to understand the main events where member information must and should be shared by the employer to the scheme and/or another employer.

Glossary

Common data

This data is needed so that a member can be uniquely identified. See our guidance on what records to keep.

Identifiers

Personal information that could be used to identify a member, such as their national insurance number.

Internal controls

• Arrangements and procedures to be followed in the administration and management of the scheme,
• Systems and arrangements for monitoring that administration and management, and
• Arrangements and procedures to be followed for the safe custody and security of the assets of the scheme.

Scheme-specific data

Other data specific to a scheme relating to its members and their participation in the scheme. See our guidance on what records to keep.

Legal references

¹ Regulation 4 of The Public Service Pensions (Record Keeping and Miscellaneous Amendments) Regulations 2014 [Regulation 4 of The Public Service Pensions (Record Keeping and Miscellaneous Amendments) Regulations (Northern Ireland) 2014]

² Regulation 12 of The Occupational Pension Schemes (Scheme Administration) Regulations 1996 [Regulation 12 of The Occupational Pension Schemes (Scheme Administration) Regulations (Northern Ireland) 1997]

³ Article 226A of The Pensions (Northern Ireland) Order 2005

⁴ Section 249A(3) of the Pensions Act 2004 [Article 226A (3) of The Pensions (Northern Ireland) Order 2005]

⁵ Public Service Pensions (Record Keeping and Miscellaneous Amendments) Regulations (Northern Ireland) 2014

⁶ Articles 226B of The Pensions (Northern Ireland) Order 2005

⁷ As defined in section 318(1) of the Pensions Act 2004 (Article 2(2) of The Pensions (Northern Ireland) Order 2005)

⁸ As defined in Section 318(2) of the Pensions Act 2004 (Article 2(3) of The Pensions (Northern Ireland) Order 2005)

⁹ Regulation 5 of The Public Service Pensions (Record Keeping and Miscellaneous Amendments) Regulations 2014 [Regulation 5 of The Public Service Pensions (Record Keeping and Miscellaneous Amendments) Regulations (Northern Ireland) 2014]

¹⁰ Regulation 12 of The Occupational Pension Schemes (Scheme Administration) Regulations 1996 [Regulation 12 of The Occupational Pension Schemes (Scheme Administration) Regulations (Northern Ireland) 1997]

¹¹ Regulation 6 of The Public Service Pensions (Record Keeping and Miscellaneous Amendments) Regulations 2014 [Regulation 6 of The Public Service Pensions (Record Keeping and Miscellaneous Amendments) Regulations (Northern Ireland) 2014]

¹² Regulation 13 of The Occupational Pension Schemes (Scheme Administration) Regulations 1996 [Regulation 12 of The Occupational Pension Schemes (Scheme Administration) Regulations (Northern Ireland) 1997]

¹³ Section 14 of the Public Service Pensions Act 2013 [Section 14 of the Public Service Pensions Act (Northern Ireland) 2014], and the Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013 [The Occupational and Personal Pension Schemes (Disclosure of Information) Regulations (Northern Ireland) 2014]

Related content

• Record-keeping: guidance