On the go: The Pensions Administration and Standards Association has published guidance detailing how schemes must compare ‘find requests’ from pensions dashboard users against member records, with data quality determining the choice of approach taken.
Pension schemes will have to begin complying with dashboards legislation from 2023, but given the extent of the data exercises involved and the importance of clear record keeping, PASA’s guidance encourages schemes and providers to begin to look now at the practical implications.
There are currently several matching options available, ranging from ‘simple matching’ — for schemes that have a high level of confidence in the data they possess — to more complex and sophisticated approaches.
The guidance proposes three core data elements to be used for matching, these being surname, date of birth and national insurance number.
A high level of confidence in all three is key just to pursue the simplest matching option, as failing to comply with this standard would lead to a pension going undiscovered on the dashboards and be deemed a breach of dashboards legislative requirements.
The enhanced version of the first matching option would include the first eight characters of the national insurance number, as well as any surnames previously supplied by users, and would mitigate the risk that data provided to the dashboards by users may not match that member’s data as held by the scheme.
For schemes lacking a high degree of confidence in the data they hold, there are two further matching options that could be used until that level of confidence is reached.
Option two relies on the same core data elements but contains provisions for ‘maybe matches’, which would at least increase the odds of a pension being found and matched, but would require a more complicated approach that would require the help of internet service providers and pension scheme administrators.
Option three expands the list of data elements, which may upgrade some maybe matches to full matches.
“This could improve the individual’s experience by reducing the number of maybe matches, but is a more complicated match regime for ISPs to build and operate. There will still be demand on administrators to resolve maybe matches, but arguably lower than under option two,” the guidance explained.
It also pointed out that schemes will need a high level of confidence in any alternative or additional data elements they use to match pensions for the dashboards.
PASA chair Kim Gubler said: “As the pensions industry’s administration standards body, it makes sense for PASA to lead on helping schemes decide how they wish to match their records to the users of pensions dashboards.
“We’re grateful for the industry-wide support for the PASA DMC Guidance and will continue to work hard to deliver practical support for schemes’ compliance, so that members have a good experience of dashboards.”
Chris Connelly, EQ solutions director and chair of the PASA Pensions Dashboards Working Group, added: “It is easy to sit back and wait for everything to be decided, but in truth the scale of the job at hand means we must make an early start. While it is true we do not yet know everything, we do know plenty to get started.”
Rob Yuille, head of long-term savings at the Association of British Insurers, welcomed the guidance. “Matching people to pensions is the essence of the dashboards idea, so it’s an important first step to create a data-matching regime that gives users of dashboards the best chance of finding their pensions,” he said.
“The responsibility and liability of those involved in the matching process needs to be clear, including through the forthcoming regulations and a view from the Information Commissioner’s Office, before the guidance can be fully implemented.”
Nigel Peaple, director of policy and advocacy at the Pensions and Lifetime Savings Association, argued that schemes “should be discussing this topic with their administrators and other providers now, and reviewing the accuracy of the personal data values held for all of their deferred and active member records”.
“This initial DMC Guidance does not completely resolve the matching challenges — questions of liability and maybe matches remain for 2022 — but it’s an important step in helping schemes prepare for dashboards,” he said.
