Date posted: 01/04/2009
Audience: HR managers, payroll managers and staff responsible for notifying their APAC when a member leaves employment.
- Contact your APAC to discuss possible timescales for work and when you are likely to receive your list
- Check the list of member records your APAC sends you against your own HR/personnel/Pay records to identify employee status
- Reply to your APAC with the employee status, setting out the reason why the person is no longer employed and when the departure occurred
Timing: Immediate - The data cleansing exercise must be completed by the end of 2009
- Extracts of Civil Service pension scheme data for the last scheme valuation in 2007 showed a significant number of discrepancies which must be investigated. There are a large number of member records on PenServer which show an end date for pensionable service but no associated award. This is very disappointing, given the massive efforts that employers and APACs put in to getting their pensions data cleansed for the “Choices” exercise back in 2002.
- We need to take urgent action to resolve these discrepancies so that the scheme data is correct in time for the next valuation in 2010. It is possible that employers are not consistently telling their APAC when scheme members leave their employment. This can lead to:
a) Contribution Equivalent Premiums (CEP) not being paid to buy back the members into the State Second Pension (S2P)
b) members entitled to deferred pension awards not receiving notification of their entitlement
c) member records not transferring where the person moves to another CSP employer
d) inaccurate benefit statements; and
e) the possibility of death benefits not being paid
- Data accuracy is essential for Scheme governance. Not only do employers need to be mindful of their responsibilities under the Data Protection Act, but members also need to trust the quality of the data held by the administrator,
- With the introduction, in 2010, of cost-sharing and cost-capping the Scheme valuation will potentially have a greater significance than before, it is therefore essential that the data on which it is based is as accurate as possible. The discrepancies must be resolved before the next valuation extract is taken (March 2010) which means data cleansing needs to be completed by the end of 2009.
- As the employer you are responsible for notifying your APAC of a change of member status, this can include; members who leave employment, transfer to another CSP employer, go on a career break or take unpaid maternity/paternity leave. Please see Section 6 of the Employers’ Pension Guide for detailed guidance on what action you should take in these circumstances and EPN 218 for information on dealing with a transfer of a member to another CSP employer. You are required to check your records so that the APAC can take the appropriate action.
- CSP, as scheme managers, has the responsibility for ensuring the data cleansing work is completed and will be monitoring progress rigorously.
- While you must notify your APAC when someone leaves, your APAC has a duty of care for the maintenance of the personal data. Your APAC has been issued with special software to identify and extract the member records with discrepancies. Your APAC will send you a list of member records with a deadline for completion and return. You will need to check the individual records against your HR/Personnel/Pay records and reply to your APAC setting out the reason why the person is no longer employed and when the departure occurred.
- You will need to schedule the work and allocate resources to it. Depending on the quality of your records it is possible that the work could be resource-intensive. You will need to agree a timetable with your APAC. This timetable will also include a commitment from your APAC on timescales.
- You may also need to consider what changes to make to your processes so that this situation does not arise again. Staff working in this area should be reminded of the importance of promptly notifying the APAC of any changes to a member’s status, so that the administrator can maintain accurate data records for the future.
- On receiving your replies, your APAC will take the appropriate action. It will pay a CEP; make a preserved award; transfer member records to a new APAC and update the PenServer database as necessary.
- This is important and necessary work and must be completed. Deadlines for each stage of the work must be set and agreed with your APAC. If you feel that you cannot meet them you will need to discuss this with your APAC who will consult CSP as necessary. Your APAC will monitor its employers for responses. CSP will follow-up if the arrangements between employers and APACs either cannot be agreed, or fail to deliver cleansed records within the deadline.
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