Welcome to your weekly update from the A&O Shearman pensions team, covering all the latest legal and regulatory developments in the world of workplace pensions.
ICO guidance on using employment records
The Information Commissioner’s Office (ICO) has published guidance on how to treat employment records in line with data protection requirements. The guidance covers a range of scenarios and includes a section on pension schemes, which sets out reminders of basic data protection principles on sharing information with third parties, including:
If you are sharing health information with a scheme provider, you must identify both a special category condition (for example, that it is necessary to comply with the law) and a lawful basis (such as consent).
You must only use the personal information you collect for the purpose for which it is collected (e.g. for the scheme provider to administer benefits under a scheme) and you should ensure that the only people in your organisation who have access to the information are those who need it. You should make them aware of their data protection responsibilities and ensure they do not use it for other purposes.
Read the ICO’s guidance.
Pensions Data Project: reporting on data matching
The Pensions Data Project (an initiative aimed at addressing the lack of a central research base for retirement savings in the UK) has published a report setting out lessons learned from a data matching exercise, using data from five master trusts. The report applies the findings to the issues of small pots and pensions dashboards.
On small pots, it concludes that there is a difficult balance between having strict matching criteria to ensure pots are not merged incorrectly, and having broad enough criteria that pots are not left unmatched. In relation to dashboards, the report suggests ‘there will be many good matches, signifying that pensions dashboards will be able to confidently display a good number of pensions for an individual. However, the number of partial matches found in the project could also indicate significant traffic to providers, off the back of dashboards. If further verification was undertaken before a member follows up with providers, this would reduce the amount of unnecessary contact’.
Read the Pensions Data Project report.
[View source.]
