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Purple book anonymised longitudinal dataset of pension schemes

FOI ref - FOI-5209
Date - 17 September 2020


Please could you provide the anonymised longitudinal dataset of pension schemes which make up the Purple Book universe (showing type of fund, membership by type, assets, liabilities and date of closing/ closing accruals if applicable).


I can confirm that we hold information falling within scope of your request. However, we are unable to supply the information requested for the reasons set out below.

Information we are not able to supply

Section 44 of the Freedom of Information Act (FoIA) - as we have been given strong powers to demand documents and other information from trustees, employers and others, those powers are also balanced by restrictions on how we disclose the information provided to us.

The information held on our register is information we receive in the exercise of our statutory functions and is considered ‘restricted information’.

Restricted information is defined at section 82(4) of the Pensions Act 2004 (PA04) as:

‘information obtained by the Regulator in the exercise of its functions which relates to the business or other affairs of any person’.

Under section 82(5) of the PA04 it is a criminal offence to disclose such information except as permitted under that Act.

More specifically, provision of the requested dataset in the form requested, even on an anonymised basis, does not meet either of the exemptions under which “Restricted” information might be provided – it is our view that such provision would potentially enable information relating to a particular person (in this case corporate) to be ascertained from.

Whilst the FoIA is based on the presumption of releasing information, section 44(1)(a) of the FoIA provides an absolute exemption to the requirement to disclose any information if its disclosure is prohibited by or under any enactment.

In this case, section 82 of the PA04 prohibits disclosure and we are unable to disclose the register, extracts from the register or confirm whether a specific pension scheme is listed on the register. This exemption is absolute and does not require a public interest assessment be undertaken.

Duty to provide advice and assistance

However, we can provide the information in the format of statistical summaries (sums, averages, etc) of segments of the universe (eg by scheme size), then exemption (b) would be met, and we would be able to meet such a request.

Please confirm if you want us to proceed with the above recommendation.