In 2010 the Pensions Regulator ("TPR") set out recommended standards for common data and a target was set for schemes to have 100% of common data in place by 31 December 2012. Common data includes data used to identify scheme members, such as name, address and National Insurance number.
A recent TPR survey of over 500 trust-based occupational schemes (the "recent survey") has revealed little recent improvement in record-keeping and as a result TPR has decided that with effect from 2018 information on scheme data will require to be submitted in the annual scheme return.
It has now been confirmed by TPR that the 2018 scheme return will include two additional questions in relation to data and will require confirmation of the date of the last data review conducted in relation to the scheme and the scheme's data score.
As a reminder of the requirements for common data, new data (this is data either created, or updated in respect of a member since 1 June 2010) requires to be 100% complete and Legacy data (this is data created before 1 June 2010 and not updated since that date) requires to be 95% complete.
The recent survey found that only two-thirds of members were in schemes with a common data score of at least 95%.
In measuring data scores, if only one item of data is missing in respect of an individual member then the whole record of that member fails to meet the standard required and cannot be counted towards the percentage target. So for example if out of a scheme of 100 members, 50 are missing information on their date of birth only, despite all other data being present and accurate, then the data score for that scheme would be 50%.
In addition to the common data, schemes will also have other types of data including conditional data which TPR are now referring to as "scheme specific data" (i.e. Investment choices, pensions sharing and earmarking order details and transfer in details etc.).
There are no set targets for scheme specific data, but TPR has noted that it expects trustees and scheme administrators to work together to build a list of scheme-specific data which will help to assess how well the scheme is running and should agree why they consider each data area to be key.
What should Trustees do now?
Trustees should engage with their scheme administrator and request information regarding the last data review and current data standards and scores for both common and scheme specific data. Action now will allow trustees to identify and take steps to put in place an appropriate action plan if required to ensure the position is as it should be prior to having to provide information in connection with the scheme return.