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Data monitoring

Important

Early draft of the code of practice

This code is not in force yet. It is an early version for the new code of practice consultation.

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Published: 17 March 2021

There are requirements for governing bodies to maintain complete and accurate records.DA1, DA2

The Occupational Pension Schemes (Scheme Administration) Regulations 1996DA3 set out the records that must be maintained by governing bodies of trust-based pension schemes. Under section 249A of the Pensions Act 2004,DA4 governing bodies of certain schemes must establish and operate an effective system of governance (see Scheme governance) including internal controls (see Managing risk using internal controls). However, there are certain exemptions.DA5

The Public Service Pensions (Record Keeping and Miscellaneous Amendments) Regulations 2014DA7 set out the records that must be maintained by governing bodies of Public service pension schemes. Under section 249B of the Pensions Act 2004,DA8 scheme managers of public service pension schemes 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 rules,DA9 and with the requirements of the law.

Governing bodies should have the following processes for monitoring scheme data.

Universal requirements

  • Monitor data on an ongoing basis to ensure it is accurate and complete in relation to all pension scheme members.
  • Ensure they receive information about material errors and gaps in their scheme data, once identified.
  • Ensure any service providers follow their own procedures for reporting errors to the governing body.
  • Ensure data improvement is prioritised for members decumulating.
  • Ensure any plan for improving data can be monitored and has an achievable deadline.
  • Where applicable, ensure member records are reconciled with information held by the employer(s).
  • Ensure regular reconciliation of scheme membership, especially those reaching retirement.

Data reviews

  • Assess the need for a data review exercise at least annually.
  • Decide the frequency and nature of any additional data review where errors, gaps are identified or in response to significant scheme events, for example winding up the scheme or changing the administrator.
  • Ensure data reviews include an assessment of the accuracy and completeness of common and scheme specific data.
  • Keep a record of data reviews undertaken and their findings.
  • Where errors and gaps are identified, put a data improvement plan in place to address the issues.
  • Ensure the plan includes the actions necessary by the governing body or administrator, to correct member data.

Data protection

  • Ensure processes to manage scheme member data meet the requirements of the data protection legislationDA10 and the data protection principles.
  • Ensure processes address any breaches of the data protection legislation or principles.
  • Understand their obligations under data protection law.

Glossary and legal references

Decumulating

Accumulation is where your pension grows (by contributions or investment return, for example). Decumulation is where you take money out of your pension to fund your retirement, for example, as a lump sum or by buying an annuity.

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 (Section 249A of the Pensions Act 2004).

DA1Regulation 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]

DA2Regulation 12 of The Occupational Pension Schemes (Scheme Administration) Regulations 1996
[Regulation 12 of The Occupational Pension Schemes (Scheme Administration) Regulations (Northern Ireland) 1997]

DA3Occupational Pensions Schemes (Scheme Administration) Regulations (Northern Ireland) 1997

DA4Articles 226A of The Pensions (Northern Ireland) Order 2005

DA5Section 249A(3) of the Pensions Act 2004
[Article 226A (3) of The Pensions (Northern Ireland) Order 2005]

DA6Public Service Pensions (Record Keeping and Miscellaneous Amendments) Regulations (Northern Ireland) 2014

DA7Articles 226B of The Pensions (Northern Ireland) Order 2005

DA8As defined in section 318(1) of the Pensions Act 2004
[Article 2(2) of The Pensions (Northern Ireland) Order 2005]

DA9As defined in Section 318(2) of the Pensions Act 2004
[Article 2(3) of The Pensions (Northern Ireland) Order 2005]

DA10The law includes the Data Protection Act 2018 and the Retained Regulation (EU) 2016/679) (UK General Data Protection Regulation).