
Publication
Regulatory investigations and enforcement: Key developments
The past six months have seen a number of key changes in the regulatory investigations and enforcement space.
United Kingdom | Publication | December 2021
The Pensions Administration Standards Association (PASA) has published guidance to help schemes decide how they are going to match ‘find’ requests from users of dashboards against the records they hold once pension dashboards are up and running (expected to be from 2023). There are different options for matching dashboard users to member records because schemes hold different data, and it will be for schemes to decide which option to choose.
PASA expects that many schemes will decide to match on the basis of surname, date of birth and national insurance number. However, schemes wanting to go down this relatively simple route will need a high degree of confidence in the accuracy of these data items.
The detailed legal requirements for dashboards are expected to be published for consultation in early 2022, but the message from PASA is that this need not hold up the process of improving the accuracy of data items needed for matching.
As the dashboard programme gathers pace, trustees should engage with their administrators (if they haven’t already) to understand what administrators are doing to get ready for dashboards and whether they have any scheme-specific concerns.
Publication
The past six months have seen a number of key changes in the regulatory investigations and enforcement space.
Publication
In a recent determination, the Ombudsman rejected a scheme member’s claim that the trustees should have conducted due diligence on the receiving scheme before making a transfer in in 2014, as there was no duty of care on the trustees at the time of transfer.
Publication
The Court of Appeal has confirmed that proof of disclosure to third parties is not required for data protection law breaches and that individuals’ rights are breached by unlawful “processing” alone.
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