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PASA updates its guidance on data matching
United Kingdom | Publication | September 2022
On August 23, 2022, the Pensions Administration Standards Association (PASA) published updated guidance on data matching convention (DMC) for dashboards. The original guidance was published in December 2021.
From 2023 onwards, on their staging date (largest schemes staged first), all pension schemes must comply with the new statutory duties. Schemes will need to match “find requests” from dashboard users against their member records and the DMC guidance is aimed at helping schemes decide on their approach to providing the matching function. There is a useful executive summary on page 4 of the PASA guidance.
The updated guidance now includes a chapter on next steps (pp24-28) which sets out topics intended to be subjects for future guidance and why such guidance is needed.
Topics for future guidance include:
- The extent on which to rely on different sort of member identifiers; that is, how to treat verified identifiers (such as a digital passport) and self-asserted personal identifiers (such as name, d.o.b and address).
- Options for matching where there is no NI number provided.
- Potential false positives flagged by data matching.
- Split administration situations (eg multiple sections for a single scheme, such as a DB section with one third-party administrator and DC section with another third-party administrator with savers who have benefits in both sections; AVCs alongside DB benefits; employers with two or more separate schemes).
The PASA guidance also includes a link to the Pensions Regulator’s own dashboards guidance, which itself has a section on matching and includes a checklist for schemes.
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