Let me explain.
Someone had made a mistake – one mistake which resulted in one wrong data entry on one pension Scheme,
We asked tPR how to report the mistake. The answer came back
I am writing in response to your recent query regarding the correct way to calculate errors in both common and conditional data.
I can confirm that the correct method to use is that which was published as part of our 2008 Record Keeping Guidance and I have attached an example of this.
An example of the correct method is that if a scheme has 100 members and 1 piece of data is incorrect for 1 member then 1% of the data is incorrect. Similarly if each of the 100 members has at least 1 piece of data incorrect then 100% of the data is incorrect.
I hope this clarifies the matter…
You might feel a little sorry for the administrator. If the administrator get’s one out of ten data items wrong, you might think he or she is 90% right and 10% wrong.
If the administrator makes a common mistake across 100% of the members which results in one out of ten data items being wrong for 100 members, then you might still think that the administrator is 90% right and 10% wrong.
But no! The administrator is 100% wrong (as 100% of the data is incorrect) on the member’s record even though only one out of ten data items is incorrect . Similarly the scheme’s data is 100% wrong when 100 out of 1000 data items is wrong!
Let’s hope the tPR don’t find a case where all 10 items are wrong for in this case the administrator would be 1000% wrong. I’ve heard of footballers “givin 110%” but to be 1000% wrong is going it some!
It’s worth noting that most of such errors are in fact “omissions” where data such as postcodes has not been entered as it was not readily available. This illogical and draconian reporting system is hardly invcentivising administrators to do better!
More worryingly, the approach to reporting advocated by tPR is creating a lot of unwarranted concern for hard-pressed trustees whose time could better be spent on more substantive solvency issues.
I’m no lawyer of data cleanser but three things come out of this for me
- TPR need to look at the 2008 Record Keeping Guidance
- Common sense overrides legal imbecility
- A sense of humour overrides outrage!
Question in ignorance : can you define a set of ” member data” (critical for benefits and contacting) and “supplementary data” (nice to have but not critical).
Reporting on “member data” would be then be accurate in terms of members for whom you have ability to correctly identify and calculate benefits.
(Slight more philosophical part of this is whether “spouse /dependant details” are critical . Probably not … it only matters at point of death and needs to be checked at that point.)
The downside of this calculation is clearly the way in which it will be reported in the mainstream press and media. Depressing level of understanding and quality of reporting of facts is a particular bugbear … see recent comments on those 1000 11/12 yrs on the pill …http://tinyurl.com/2vprkej
To be fair, this is what the Regulator is trying to do – but it can be very scheme specific eg you don’t need c/out earnings history for a c/in scheme. The spouse point is an important one. We can spend a lot of time getting the data absolutely right so that it can cope with whatever happens to the member. But do schemes want to pay for this and does society want to pay for this?