PASA has submitted its response to the Information Commissioner’s Office’s consultation on draft guidance for organisations handling data protection complaints.
Our response highlights the need for practical, joined-up guidance which recognises the complex regulatory environment in which pension schemes operate. Key points include:
🔹 Integrated complaint handling – Encouraging the ICO to consider how data protection complaints interact with pensions legislation and existing statutory processes, to avoid fragmented or duplicated complaints handling
🔹 Clear expectations for schemes – Requesting clarification on whether schemes should maintain separate procedures for data protection complaints, or adapt existing processes to include them
🔹 Post-investigation guidance – Calling for greater clarity on escalation timeframes, record retention, and ongoing responsibilities once a complaint has been resolved
🔹 Handling SARs linked to complaints – Suggesting further practical examples to support consistent handling when Subject Access Requests arise alongside other grievances
A huge thank you to members of PASA’s Industry Policy Committee (IPC) and their employers for their valuable input and expertise in shaping this response.
Check out the response here.
