The Pensions Administration Standards Association (Pasa) has called for schemes to carry out a personal data accuracy investigation in an updated version of its dashboard data matching conventions (DMC) guidance.

In the updated guidance, the association called for these investigations to be conducted well in advance of the scheme’s specific dashboards starting date.

It also called for improvements to personal data accuracy and matching decisions to be made far in advance of the staging date.

The guidance was originally published in December 2021 and advised on the legislative duties of pensions dashboards, schemes and providers to decide how they want to digitally compare and match ‘find requests’ from users of dashboards against all the records they hold.

In the updated guidance, Pasa called for all schemes to now be engaged on the “important topic” of matching.

The updated guidance also called for schemes to work with their administrators and technology providers to seek to understand the level of confidence in the accuracy of the surnames, date of births (DOBs), and national insurance numbers (NINOs) on all deferred and active member records.

Pasa identified several topics that could require additional guidance in the future such as personal identifiers (impact of verified vs self-asserted), options for matching without NINOs, and possible matching.

The topic of personal identifiers was seen as one that could require additional guidance as, initially, the only identifiers that are expected to require verification are surnames, forenames, DOBs, and current addresses with the rest expected to be self-asserted (typed by the user without any verification).

Pasa pointed out that other personal identifiers might require verification in future and further guidance may be necessary in that case.

Furthermore, the updated guidance explained possible matching may require additional guidance, as options for matching should be “striking the right balance” between reconnecting savers to their pensions and avoiding large volumes of calls to administrators if too many ‘false matches’ are returned.

The guidance also explained that, whilst NINOs are one of the few data items available to help uniquely identify an individual, there are still challenges with relying on it in all cases.

Pasa explained that some cases where matching with NINOs only could be disadvantageous include a user who has a UK pension scheme but is not authorised to have a NINO, a scheme which does not hold a NINO for every saver, and a NINO that has been self-asserted and not verified by the digital identity service.

It added that future guidance will recommend options for matching without NINOs.

Pasa chair, Kim Gubler, commented: “All schemes need to focus on this important topic of data matching now.

“Pasa produced this guidance and continues to update it to support the pensions administration community in liaising with schemes and working with them to produce solutions which work for all parties.”

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