The Pensions Regulator has confirmed that 2018 DB Scheme Returns will, for the first time, include specific questions about scheme data and record-keeping. The DB Scheme Return Checklist, published alongside A Quick Guide to Measuring Your Data, outlines the new questions. When completing their 2018 return, Trustees will have to confirm when they last measured their scheme's 'common' and 'conditional' data, and the accuracy 'score' of that data.
'Common' data is basic information used to identify scheme members – such as national insurance number, address or date of birth – while 'conditional' data is the information an individual scheme requires to meet its obligations to members. This will vary by scheme but typically will include members' service history and contributions, and any specific benefit entitlements such as guaranteed minimum pensions. The accuracy 'score' of this data is the percentage of scheme members for whom complete data is held.
Trustees have been encouraged since 2010 to keep this kind of information, when the Regulator issued its record-keeping guidance. As such, the Checklist confirms that a scheme's administrator reports are likely to already include this information, although this is the first time the information must specifically be reported to the Regulator. Trustees who are undertaking GDPR-compliance efforts may also find that the results of any data-mapping exercise will help confirm exactly what member data is held, and where.
The Regulator has said it will not take action solely based on a low 'score', but it may prompt further investigation leading to regulatory steps being taken.
The Quick Guide, published alongside the Checklist, explains that while in practice trustees will typically delegate record-keeping responsibilities to their administrator, the trustees remain liable for ensuring that data is accurate and complete. As such, trustees must be satisfied the administrator has put sufficient processes and controls in place to ensure the quality of data.
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