Scheme member data quality

Overview

A core accountability of trustees and scheme managers (governing bodies) is to make sure data quality is well managed. This enables you to make informed decisions, ensure your scheme is well-run, deliver good outcomes for members, and meet legal obligations, including those set out in data protection legislation.

This updated guidance (previously named as Record-keeping) sets out the practical steps and good practice that trustees and scheme managers can take to meet the expectations that are set out in the data monitoring and improvement module of our code of practice.

Roles and responsibilities

Governing bodies

You are accountable for the quality of the member data you hold. You have a legal duty to ensure that schemes have governance and internal controls in place to monitor and improve data, even if you delegate some of these duties to your administrators or sub-committees. You should challenge your administrators or sub-committees where your expectations are not being satisfactorily met. You must be able to demonstrate that you are maintaining and monitoring scheme member data in line with legislative requirements and TPR’s expectations.

Member data is a strategic data asset, vital for achieving your long-term goals and a good member experience. You should think of your member data strategically and holistically, and not just as an operational afterthought. Having good quality member data means that:

• scheme members can receive the right information and the right benefit at the right time
• you can minimise errors and mistakes, which can have serious negative impacts on members and be costly for you to resolve
• defined benefit schemes have accurate funding plans in place
• defined contribution schemes can process core financial transactions promptly and accurately
• all schemes can meet regulatory data requirements, including those introduced by pensions dashboards
• schemes can deploy advancements in technology and member communications to drive efficiencies and improve members’ accessibility and inclusivity
• members can engage with their pensions easily and effectively
• schemes can achieve their desired strategic ambitions such as buy-out or scheme consolidation

You should take an active role in the management of your member data. This means you should:

• ensure your administrators have adequate controls and processes in place to maintain good quality data
• obtain regular data reports from your administrator/s and tell us your latest data scores in your scheme return
• consider data quality regularly at board meetings
• reflect data quality on your risk register as appropriate
• make relevant decisions required by your administrator promptly and effectively
• ensure that sufficient resource and budget is allocated appropriately to resolve any data issues as they arise
• ensure that data is processed in accordance with data protection legislation and Information Commissioner’s Office guidance, a guide to the data protection principles.

Your governing body, as a team, should have sufficient understanding and experience in administration and data management, and keep up to date with relevant developments and best practice. This will assist you in having effective discussions with your administrators to ensure your scheme data is of good quality, secure, and compliant with regulatory requirements. For larger schemes, you may consider putting in place a dedicated data quality team or sub-committee to assist you in meeting your duties.

Administrators

Administrators play a key role in maintaining data quality, as they process and manage scheme member data on a daily basis, along with other parties such as employers, actuaries and software providers.

Administrators are responsible for implementing the agreed data control policies and processes, which include, but are not limited to:

• conducting regular data reconciliation exercises
• conducting regular data tracing and mortality screening exercises
• measuring the quality of member data on a regular basis
• embedding quality assurance processes
• participating in benefit audits
• working with employers to improve the data they provide
• identifying and investigating any data gaps and errors
• developing and implementing robust data improvement plans to address any identified data gaps or errors

Administrators should provide regular reports on data quality. These should promptly escalate any data issues and risks to relevant governing bodies highlighting any common member queries, errors or complaints that provide evidence of data quality issues.

These reports should include an assessment of the impact of any identified issues on the scheme and its members. This will support the governing body in deciding whether any actions are needed to improve member data quality. 

The Pensions Administration Standards Association’s (PASA) standards include a specific standard on member data quality and provide further detail about the role of the administrator in ensuring the quality of scheme member data.