PASA released Guidance on Data Management Plans back in March 2021. Its launch was accompanied by a webinar where Kristy Cotton, Chair of PASA’s Data Working Group, was joined by Louise Sivyer at the Pensions Regulator to discuss the key purpose and drivers for creating Data Management Plans.
Over a year later (and what a year it has been!), there’s no better time to implement a Data Management Plan than now, if you haven’t already.
So much has continued to develop in the pensions industry – with data, as ever, underpinning every aspect. Automation, funding, investment decisions, risk management, end game planning…. all of these need good quality data. Without it schemes waste time and money, and an increased the risk of errors. See PASA’s publication ’Data is at the heart of every scheme’ here.
The duties for trustees and pension scheme managers to actively manage data are clear and data should be a key recurring item on every trustee board’s agenda. But simply talking about data and checking your administrators are producing common data scores isn’t enough. Pension schemes should understand how important complete and accurate data is in meeting the primary objective of any pension scheme – to pay the right benefits, to the right person, at the right time. Developing, implementing and maintaining a Data Management Plan which meets the need of the pension scheme should be an action for all trustee boards. The information in a scheme’s Data Management Plan should be integrated with the approach trustees are taking in respect of data as part of their wider risk management framework.
PASA is clear in its message. All pension schemes should take an active role in managing their data, this should include:
- Understanding the data held and the data requirements – and where these don’t tie up
- Ensuring data is held securely and is processed effectively
- Setting a data strategy where the objectives and actions for managing pension scheme data align to the wider scheme objectives
- Measuring and actively improving data, which should consider not only gaps but inconsistencies and accuracy
The implementation of a Data Management Plan offers a means of documenting the data held by a pension scheme and a policy for managing it effectively. We know so many pension schemes have acted upon the Data Management Plan Guidance and now actively discuss data quality, security and improvement plans, we also know for some schemes there’s still some way to go. The PASA Data Working Group is regularly releasing Guidance and articles to support trustees and pension scheme managers with data considerations, and the Pensions Regulator has set out clear expectations on data quality and management.
For schemes where the investment into the data held falls short of what’s needed, the implications are growing, with rectification costs of something going wrong far outweighing the costs of data management, as well as regulatory sanctions and reputational costs.
You can find the Data Management Plan Guidance here, and if you wish to discuss this with a member of the PASA Data Working Group please feel free to get in touch.
Kristy Cotton, Chair of the PASA Data Working Group and Actuary at Deloitte, PASA Experts for Data