PASA have released their latest Data Accuracy Guidance about the importance of accurate data for pension schemes and provides guidance on how trustees can improve data accuracy. The guidance was created as a collaboration between various organisations including our own. Dr Tim Drye, MM’s Chief Data Officer.


The guidance lays out that accurate data is essential for pension schemes to navigate through an ever-changing landscape and meet new obligations. 

The Pensions Regulator (TPR) has increased its focus on good record keeping, making accurate data a requirement rather than a nice to have. Complete and accurate data is necessary for various aspects of scheme management, such as dashboards and member access to records. Inaccurate data can lead to increased costs, higher levels of queries, data breaches, and poor decision making. 

Trustees can improve data accuracy by conducting a data quality audit to identify issues and areas of weakness. They should cross-reference data fields, test for validation criteria, and analyse the consistency of data from different sources. Trustees should also consider digitizing paper files and microfiche and storing all data on a single electronic administration platform. The results of the data accuracy review should be summarized in a trustee report, which includes an overall assessment, results for individual data, categories of concern, impact on the scheme, recommendations, and prioritization of actions. 

Trustees should establish repeatable data validation tests, refine tests periodically, maintain a Data Management Plan (DMP), maintain an improvement log, and keep a clear audit trail of data updates and decisions made. Data quality management should be seen as a continuous process rather than a one-off exercise. 

1.        Increased queries and costs: Schemes with inadequate data accuracy will experience higher levels of queries from their administrators, leading to increased costs in resolving these queries. 

2.        Low levels of engagement: Inadequate data accuracy can result in low levels of member engagement, as members may not trust the information provided by the scheme. 

3.        Data breaches: Poor data accuracy increases the risk of data breaches, which can have serious consequences for both trustees and members. 

4.        Inaccurate reporting and decision making: Accurate data is essential for generating accurate reports and making informed decisions. Inadequate data accuracy can lead to incorrect reporting and poor decision making, which can have negative impacts on the scheme’s long-term strategies. 

5.        Delayed risk transfer exercises and wind-ups: Inaccurate data can slow down risk transfer exercises and wind-ups, leading to delays and potentially higher premiums. 

6.        Increased administration costs: Poor data accuracy requires more ad hoc data checking during member events, resulting in increased ongoing administration costs. 

7.        Poor service and increased complaints: Inaccurate data can lead to poor service delivery and more complaints from members about data errors. 

8.        Limited potential for self-service tools and digital engagement: Inaccurate data hinders the implementation of self-service tools and digital engagement options for members. 

9.        Incorrect pension payments: Poor data accuracy increases the risk of incorrect pension payments, which may require expensive future remediation. 

10.   Reputational damage: Inaccurate data can damage the reputation of trustees and employers, leading to a loss of trust from members and the wider public. 

11.   Impaired scheme valuation and funding strategies: Inaccurate data can negatively impact scheme valuation and funding strategies, making it difficult to accurately assess the financial health of the scheme.

12.   Higher ongoing PPF fees or transfer costs: Inadequate data accuracy can result in higher fees paid to the Pension Protection Fund (PPF) or increased costs for transferring data to other schemes. 

Multiple Authors (2024). PASA Data Working Group Produced in partnership with: PASA Experts for Data. Data Presence vs Accuracy. [online] Available at: https://www.pasa-uk.com/wp-content/uploads/2024/06/PASA-DWG-Data-Accuracy-vs-Data-Presence-FINAL.pdf