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What records to keep

As a pension trustee or someone running a public service scheme you need to keep certain records and data. This enables the administrator to accurately identify scheme members and value their benefits.

You need to keep records relating to:

  • your meetings and decisions
  • scheme documents including trust deed and rules, and any deeds of amendment or rule changes – this is particularly important for defined benefit schemes so that trustees and administrators can track which rules apply to each category of member
  • member and beneficiary information, including the date each member joined the scheme
  • details of all contributions received
  • all other payments to and from the scheme, including benefit payments and payments to advisers or the employer
  • details of transfers of members’ benefits and related assets to and from the scheme

You should hold two types of member data: common and scheme-specific. Both types of data are equally important.

Common data

Common data consists of:

  • National Insurance number
  • surname and either forename or initials
  • gender
  • date of birth
  • date pensionable service started, membership/policy start date or first contribution date
  • expected retirement/maturity date (target retirement age)
  • membership status
  • last status event – the date at which the membership status last changed, eg from active to deferred – where appropriate, you should also capture the reason for the change in status (eg retired or opted out)
  • address including postcode

This data is needed so that a member can be uniquely identified. All schemes should hold this data for all members. If any is missing it may be impossible to identify or trace the member, or their benefits.

Scheme-specific data

You also need to hold other data relating to members and their participation in the scheme. This will depend on factors such as:

  • the scheme type, structure and design
  • a member’s status – for example, the data you need for deferred members may differ to the data for active members
  • events that have taken place during membership

You should work with your scheme administrator to assess your scheme and decide what scheme-specific data to keep.

You should pay attention to areas such as salary records, member options exercised and payment of benefits.

For more information on scheme-specific data, see data guidance from the Pensions Administration Standards Association (PASA).

Example: How to define scheme-specific data

The trustees of a defined benefit scheme want to assess the quality of their data. They understand what common data is but invite the scheme administrator to their next trustee board meeting to discuss scheme-specific data.

The administrator provides a list of what they consider to be relevant data items for this scheme and why these are key to how the scheme runs. The administrator also explains why some data is not considered key. For example, in this scheme, benefits are calculated based on the highest salary earned within the last five years (or the five years before leaving) so salary information before this period is not essential for running the scheme. It does not need to form part of the scheme-specific data measurement.

The trustees discuss the list with the administrator and commission them to measure the data. They also ask the administrator to break down which data items have gaps and assess the impact of the gaps so they can prioritise any improvements.

How long to keep records

It’s likely that your scheme will need to hold data for long periods of time.

You must keep records for at least six years.

You will need to keep some records, including both common and scheme-specific data, for a much longer period. This means for as long as they remain relevant and are needed for the scheme to operate.

Public service schemes

For public service schemes the records to keep are set out in legislation.

The scheme manager must keep records relating to:

  • member and beneficiary information
  • transactions
  • pension board meetings and decisions

Member and beneficiary information

Type of data Information to include 
Member and beneficiary data
  • name
  • date of birth
  • gender
  • last known postal address
  • member’s scheme identification number
  • member’s National Insurance number (if they have one)
  • dates that active, deferred and pensioner members join and leave the scheme
  • details of active, deferred and pensioner members’ employment with any employer participating in the scheme including the period of pensionable service and the amount of pensionable earnings each year
Benefits that aren’t money purchase benefits, injury benefits or compensation benefits under the scheme
  • any formula used to calculate a member’s or beneficiary’s pension or benefit
  • the percentage to be applied for revaluation each year to a member’s accrued rights to benefits under the scheme
  • any increase to be applied to a pensioner member’s or beneficiary’s pension or benefit in payment in each year
Money purchase benefits under the scheme
  • any investment decisions taken by or relating to a member
  • any investments held on behalf of a member
  • any anticipated date of retirement notified by a member
Pension credit (under the Welfare Reform and Pensions Act 1999)
  • any information relevant to calculating each member’s rights under the scheme which are directly or indirectly attributable to a pension credit
Pension debit (under the Welfare Reform and Pensions Act 1999)
  • any information relevant to calculating any reduction in each member’s rights under the scheme which are attributable to a pension debit

Transactions

Transaction
Information to include

Employer or member contributions paid in relation to each active member

 
Pension and benefits payments
  • date of the payment
Payments made by or on behalf of the scheme manager to any person – except pension and benefits payments, and payments made to members who leave the scheme (other than on a transfer)
  • name and address of the person that the payment was made to
  • reason for the payment
Any movement or transfer of assets from the scheme to any person
  • name and address of the person that the assets were moved or transferred to
  • reason for the transaction
Receipt or payment of money or assets relating to the transfer of members into or out of the scheme
  • member’s name
  • transfer terms
  • name of the scheme into or out of which the member has been transferred
  • transfer date
  • date of receipt or payment of money or assets
Payments made to any member who leaves the scheme, other than on a transfer
  • member’s name
  • leaving date
  • member’s entitlement at that date
  • method used for calculating any entitlement under the scheme
  • how that entitlement was discharged
Payments made to any employer participating in the scheme
 
Any amount due to the scheme that has been written off in the scheme’s accounts
 
Any other payment to the scheme
  • name and address of the person from whom it is received
  • where a payment is made in respect of a member, the name of the member

Pension board meetings and decisions

Type of meeting or decision Information to include
Records relating to any pension board meeting
  • date, time and place of the meeting
  • names of all pension board members invited to the meeting
  • name of any person who attended the meeting and in what capacity
  • any decisions made at the meeting
Records relating to any other decision made by pension board members while carrying out their role as pension board members
  • date, time and place of the decision
  • names of pension board members who participated in making the decision
Records relating to any decision made by a committee or sub-committee of the pension board not ratified by the pension board
  • date, time and place of the decision
  • names of pension board members who participated in making the decision
1. Overview
3. Review your scheme data