Scheme member data quality

Data quality improvement plan

You might find data issues through your data review, audit, valuation or other activity. If these require improvement work, you should put an improvement plan in place to address them. Your administrator should be able to help you design an effective improvement plan.

You should keep a clear record of the plan so you can refer to it easily. Typically, the improvement plan is a standalone document. This means you do not have to locate multiple documents or items of correspondence to monitor its progress.

The improvement plan should clearly set out the steps you’re taking to improve your scheme data.

Your plan should be unique to your scheme’s circumstances. The amount of detail should depend on the complexity of the issues you’re trying to address.

Set objectives and scope

The data improvement plan should clearly set out both its scope and the objectives you’re trying to achieve by having better data. If you have more than one objective, you should list them in order of priority.

Objectives can include:

• addressing data issues that impair your ability to run your scheme effectively, paying benefits correctly at the right time, processing core transactions accurately and promptly, ensuring a high standard of service for members, keeping costs manageable or meeting legal obligations
• improving members’ experiences, such as providing them with online access to their records
• improving operational resilience, administration efficiency and scalability, such as implementing automation to reduce service times as information is more readily at hand
• preparing to move to a new administration system or a new administrator
• improving employer confidence in the valuation of liabilities and the appropriateness of their contributions and recovery plans
• improving data ahead of a risk-reduction or a liability-management exercise
• reducing the risk of fraud, such as identifying late notification of death to stop overpayment of benefits

Clearly set out the scope of your improvement work, particularly:

• which data is included
• which membership groups are included
• how far back your improvement work will cover

You may need to take a phased approach or prioritise certain objectives if there is a lot of work required. You should prioritise data that will have the greatest effect on member benefits and the most impact on your core scheme activities. Other factors you could consider for prioritisation include:

• data type: for example, focusing on personal information that will improve your ability to communicate with members
• member type or profile: for example, looking at pensions in payment or members that are closer to retirement first
• data source: for example, looking at the largest employer first
• scheme events: for example, focusing on the data you need for certain scheme events such as issuing benefit statements or valuations
• return on investment: for example, working on issues that have the greatest impact on running costs
• technical solution: for example, starting with data issues that can be resolved using bulk automated solutions
• quick wins: for example, working through known data issues that are relatively easy to fix

Define roles and responsibilities

For the governing body

You need to have appropriate oversight of progress and check the quality of the work being done. You also need to be available to answer any queries the administrator has as the work progresses and make any required decisions.

You should agree roles and responsibilities from the start. Your plan should set out who will make decisions, such as sign-off for the outcome being met, or changes to work on the improvement plan. Clearly document any areas where the administrator has flexibility, and the limits they need to work within.

You should agree and document how and when the administrator will report their progress. This should include reporting to you and other relevant parties, such as for pension boards or employers.

You may need a range of other formal controls in place depending on the complexity of the work. These can include a decisions/action log, a change control log, or cost reporting.

For the administrator

The plan should break down the activities your administrator will perform, and for each activity it should be clear what the administrator will do. It should include:

• the issue to be addressed, including which members (member groups) are covered
• the method to be used, for example, member address tracing or researching company employment records
• who is doing the work and how long it will take
• any assumptions made, for example, the number of records likely to need work
• how you will know the task has been completed

You may also use a specialist service provider to deliver some or all of these planned activities. If so, you will also need to be clear on the respective roles and responsibilities. You will also need to confirm the data sharing and implementation processes between your administrator and the selected specialist service provider.

Identify dependencies with other work

You should identify any other work that might affect or depend on your improvement work, especially where data is being changed or the same resources need to be used.

This will help you identify potential sources of conflict or opportunities to minimise burden and maximise efficiency. For example, reducing how often you ask employers for data, or only contacting members once to request information.

Other work you may need to consider includes:

• valuations
• member communication exercises
• guaranteed minimum pension reconciliation and equalisation
• year-end reconciliation
• negotiating an administration contract or changing an administrative platform
• risk-reduction exercises
• proposed scheme structure changes
• preparing to comply with new legislation

Set a timeline for the plan

You should work with your administrator and agree a timeline for the data improvement plan.

The plan must have a defined end date within a reasonable period. More complex work can take several months, so you could consider breaking it down into phases.

Your timeline should clearly set out key milestones, when reporting and decisions need to happen, and any risks or barriers to meet this timescale. It should also include the dependencies you have identified.

You may need to take a phased approach if there is a lot of work required, or this is a particularly complex project. These should also be reflected in your timeline.

Assign resources

Plans should take account of available staff and financial resources, as well as other pressures such as emerging regulatory changes. The administrator and employer will need to help you, so you should agree resources with them.

You should agree at the start whether the work will be delivered as part of ongoing business as usual administration, or as a separately managed project with additional budget and resources, or a combination of the two. If you’re diverting resources from other work, you should set out how this will affect the scheme.

As well as the administrator’s resources, you should consider which other parties you may need to source data from. Likely sources and examples of data they can supply include:

• employers – providing member information, employment and contribution history
• members – name changes, dates of birth, email addresses
• next of kin – death details, beneficiaries of the estate, spouse or dependent information
• tracing companies – address checks, existence checks, email addresses, phone numbers, likely spousal information, address history
• other parties, such as actuaries or additional voluntary contribution providers

Set measurable outcomes

You should set out the outcomes you are aiming to achieve, based on your objectives. Include how you will measure them and how long they will take to achieve.  

For example, if one of your objectives is to improve member communications by ensuring you can send the right communications to members at the right time, your desired outcomes could be set as follows:

• Desired outcome: you hold accurate contact details (postal, or personal email addresses, or personal phone number) for all members.
• Timeframe: before you issue your next annual benefit statement.
• Measurement: how many members receive their annual benefit statement. You could also consider using a survey to ask members for feedback. This can help you measure your success.

Embedding improved data into your scheme

Improvement work doesn’t end when the data is clean. Make sure the data is fed back into systems. Work with the administrator and employer on follow-up activities such as:

• ensuring that any changes to member records are also made across all administrative systems that hold the same data
• ensuring there are no unintentional overwrites through automated data feeds, this may include employer HR systems and pensioner payroll
• correction work, such as sorting out payment errors
• capturing and documenting changes to data and processes so future administration teams know what has been done
• updating and documenting procedures to reduce the risk of errors recurring and to make sure improvements are maintained