Regulator adds new data reporting requirements to Scheme Returns from 2018
The Pensions Regulator (TPR) has announced that it will be asking some new record-keeping questions as part of the annual Scheme Returns for defined benefit (DB) and defined contribution (DC) pension schemes.
The most notable of these questions concern member data and relate to both ‘common’ and ‘conditional’ data.
Common data are basic data items used to identify scheme members which all schemes should hold for members: that includes factors such as national insurance number, surname and address.
Conditional data, or ‘scheme specific’ data, are data specific to each scheme and which have been determined by the trustees to be necessary in the running of their scheme. That data can include employment records, contribution history, and the value of member benefits.
Scheme trustees and managers are being asked to report on:
- when they last measured both common and conditional data; and
- what percentage of their records is complete and accurate.
Measuring the completeness and accuracy of member data is not a new requirement: regulatory guidance has been in place since 2010. However, this is the first time that TPR has required reporting on data records in all Scheme Returns.
TPR has confirmed that it will not be taking immediate enforcement action on the basis of scores alone, but it will use these as a means of entering dialogue with a view to improving record keeping management.
The new requirements are timely, given the onerous provisions of the General Data Protection Regulations that will come into force in May 2018 and which will affect all pension schemes.
Trustees should work with their administrators to ensure that their common and conditional data are in a measurable form, in line with the Regulator’s guidance, in time for the issue of the Scheme Returns: defined benefit schemes will see their returns issued in January 2018, and defined contribution returns will be available in the summer.