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Key points

  • Work with trustees of defined benefit (DB) schemes to identify what types of member data need to be kept.
  • Advise clients they need adequate internal controls to maintain accurate and up-to-date member data.
  • Work with trustees to carry out a data review exercise regularly and create a data improvement plan.
  • Work with employers to ensure that they understand when they need to pass information to the scheme administrator.

Types of member data to keep

Trustees are legally required to keep certain types of information. If you’re responsible for managing your clients’ member data or advising trustees on the records they need to keep, ensure you maintain (or, as appropriate, advise the trustees to maintain) records relating to:

  • the date each member joined the scheme
  • details of all contributions received
  • all other payments to and from the scheme including, for example, benefit payments and payments to advisers or the employer
  • details of transfers of members’ benefits and related assets to and from the scheme.

Schemes also need to hold certain types of data that is common to all schemes as well as other types of data that is conditional on a number of factors. For more information about common data and conditional data, see the data to be measured in our record-keeping regulatory guidance.

Schemes need to keep records for a minimum of six years. However, some records, including both common and conditional data, will need to be kept for a much longer period.

Internal controls

If you’re responsible for managing your clients’ scheme data, you need to have adequate internal controls that enable you to keep the data accurate and up-to-date. Ensure that your processes meet the requirements of the Data Protection Act 1998.

Maintaining data

You should work with trustees to carry out a data review exercise at appropriate intervals, eg annually. You or the trustees should also carry out a review when significant events occur, such as merging or winding up the scheme.

You should make sure there’s a data improvement plan to address poor quality data.

Working with employers

If you advise the trustees you should assist them to take reasonable steps to ensure that member records are reconciled with information held by employers.

Whether you advise the trustees or the employer, ensure that they understand when the employer needs to pass information to the scheme administrator. This includes key events such as when an employee:

  • joins or leaves the scheme
  • changes their rate of contribution
  • changes their name, address or salary
  • retires from work or dies.

If an employer fails to provide the required information, you should liaise with the trustees or employer (depending on who you advise), as needed to resolve the issue. You should also consider whether you need to report the breach to us. See code of practice 1: reporting breaches of the law.

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