The report of the Director, West Yorkshire Pension Fund (WYPF),

Document “A”,  informs members that The Pension Regulator’s (TPR) Code of Practice 14 and The Public Service Pensions (Record Keeping & Miscellaneous Amendments) Regulations 2014 sets out the requirements for public sector pension funds to maintain comprehensive and accurate data on their members and their members’ pension contributions.

Recommended –

That the report be noted.

(Caroline Blackburn – 01274 434523)

The report of the Director, West Yorkshire Pension Fund (WYPF),

Document “A”, informed members that the Pension Regulator’s (tPR) Code of Practice 14 and The Public Service Pensions (Record Keeping & Miscellaneous Amendments) Regulations 2014 set out the requirements for public sector pension funds to maintain comprehensive and accurate data on their members and their members’ pension contributions.

The report revealed that from 2018, and for the first time, Local Government Pension Funds were required to report on the quality of common and scheme-specific data in their Pension Regulator scheme returns.

Guidance issued by the Pensions Regulator (tPR) at that time was outlined in Document “A”.  The guidance included that a continuous review of data was required; a data review be carried out annually and where a review of data identified poor or missing data an improvement plan should be put in place to address those issues.  Members were advised that that there were two types of data which should be measured and that was Common Data and Scheme Specific Data.   As a definition of Scheme Specific Data was not completed until July 2109 Pension Funds were advised to assess what they thought was scheme specific and to use that for their 2018 tPR return.

The WYPF Data Improvement Plan 2018/19 was appended to Document “A”.  It was explained that the scheme specific data in that plan was under the definition of WYPF and that it would change following a definition of scheme specific data which had now been provided from the Local Government Association. 

During discussions about actions to improve the data it was acknowledged that the fund had over 100,000 active members and 291,000 deferred members and that there was only a small percentage of incomplete or incorrect data.  The majority of incomplete data was due to deferred members moving address and not informing the fund of their contact details.  Members were advised that systems were in place to trace those members and that annual deferred member statements were issued and reminded members to update their personal information. 

In response to questions about the start up system used for new members it was confirmed that employers provided monthly returns for their employees and any missing information would be requested from the employer at that time.

It was queried how data was disposed of and it was clarified that all records were kept to provided a full audit trail and historic information for each member.

In response to questions about measures to ensure that data from employers was accurate it was confirmed that employers provided a detailed record on payments to HMRC each month.  The amounts paid were checked against member records and queries were picked up from the payroll or Human Resources sections and corrected within one month.  It was confirmed that pensionable pay and employer contributions were checked.  Measures were undertaken to educate and train employers in the production of accurate data and it was confirmed that there were no issues with the largest employers.  It was believed that the provision of Member Benefit Statements containing salary details would also allow members to alert the fund to any discrepancies.

Inconsistency in start date information was discussed.  It was explained that this could be due to employees changing working hours/patterns and new starter forms being produced in error by employers.  It was agreed to check the rationale for that data further.

Members questioned if there was a central or Government tracing system which could be used and it was confirmed that there was not one definitive service available.  The Department for Works and Pensions were contacted as part of the fund’s tracing activities.

Resolved –

That the report be noted.

ACTION: Director, West Yorkshire Pension Fund