Atkin trustees, actuaries, consultants & administrators

Data Audit

The Regulator issued guidance for trustees in June 2010 to promote better record-keeping in pension schemes. The guidance aims to reduce errors in member benefit calculations, and will serve to reduce the amount of data verification work needed for schemes which may be bought out or enter the PPF at some point in the future. In addition, these minimum requirements should reduce the risk of reputational damage to trustees and sponsors where poor quality of membership data has been an issue in the past. The Regulator has set a deadline of December 2012 for trustees to meet these requirements.

Although these requirements may not be too onerous for most schemes, the Regulator has suggested that trustees should take the opportunity to review their membership records and the processes underlying the updating of these records to assess whether there are any issues with the data currently held and whether any potential future issues can be identified and addressed.

There will be a number of schemes with legacy data issues which may not be easy to resolve and may involve engagement from affected members. The Regulator suggests that a first stage for these schemes is to identify where there are problems, their extent and then put together an action plan for resolving them.

We have developed data verification tools which we can use to examine your scheme data and check for compliance with the Regulator’s requirements and any additional tests that the trustees feel are appropriate. As administrator to many pension schemes, we are experienced in investigating inaccurate or incomplete data from legacy issues. Our experience in helping schemes into the PPF or to buy-out has meant we have had to adhere to extremely thorough data cleanse processes. We will produce a report which will highlight our findings and discuss the options available to trustees to rectify any issues that are identified. This report will serve to demonstrate to the Regulator that the guidance has been noted and addressed appropriately.

Our approach to resolving data problems is to consider the value added versus cost and look for practical ways these issues can be resolved with minimum cost, delay and fuss. For instance, sometimes issues can arise from poorly drafted legal documents and we will therefore work with the company to ensure that the benefits reflect as much as possible what was actually intended.

The Regulator’s guidance acts as a prompt for trustees to consider a data cleanse exercise to address some of their legacy problems which is likely to be more cost-effective than updating records on a member by member basis as they reach retirement, transfer from the scheme etc. The requirements may also suggest an opportune time for trustees to consider whether there are any concerns over the benefits payable from the scheme e.g. has age equalisation been addressed adequately? We can provide training to trustees to help them better understand their scheme rules and ask the right questions of their administrators to ensure that benefits are calculated in line with the rules and consistently between members minimising the risk of any future issues.

The service is simply leagues ahead of anything I have previously experienced with Blue-Chip players.

Lee, Administration and Actuarial client