Agenda item

COMPLIANCE CHECKLIST

To receive a verbal update.

Minutes:

The following sections were discussed and points noted:

 

Section F – Administration and Scheme Record Keeping

 

F1 – Do member records hold the information required as defined in the Record Keeping Regulations and is it accurate?  Members agreed that the requirement was fully compliant.

 

F2 – Does the Fund have the appropriate processes in place so employers can provide timely and accurate information?  Officers were working on training provision for ‘Your Fund’, with LPP to initially provide training to Havering, as the largest employer in the scheme.  When available, the Pension Administration Policy would be presented to the Pension Committee, for approval, although this was not currently a high priority.

 

F3 – Does the Fund keep records or and reconcile transactions as required by the Record Keeping Regulations?  Caroline Berry would discuss the process of recording those overpayments that were written off with Sarah Bryant and would report back to members.

 

F4 – Are records kept of pension board meetings as required by the Record Keeping Regulations? Members agreed that the requirement was fully compliant.

 

F5 – Are records kept of decisions made by the pension board, outside of meetings as required by the Record Keeping Regulations? Members agreed that the requirement was fully compliant.

 

F6 – Are records retained for as long as they are needed?  It was confirmed that legally records could be retained indefinitely and would not breach the General Data Protection Regulations.

 

F7 – Does the Administrating Authority have policies and processes to monitor data on an ongoing basis?  The formal monitoring of data and checks would be carried out as part of the audit process.  Furthermore, performance indicators highlighted any issues.

 

F8 – Does the Administrating Authority carry out a data review at least annually? Members agreed that the requirement was fully compliant.

 

F9 – Is a data improvement plan in place which is being monitored with a defined end date? There was currently no improvement plan in place, and this was a priority for Caroline Berry.

 

F10 – Are processes and policies in place to reconcile scheme data with employer data? Addresses were not currently checked.  Work on LPP data processes would be undertaken next year and address reconciliation would be done.  

 

F11 – Do the Administrating Authority’s member data processes meet the requirements of the Data Protection Act 1998 and the data protection principles?  Members agreed that the requirement was fully compliant.  LPP use Mimecast as their secure email facility.

 

Section H – Providing information to members and others

 

H1 – Has an annual benefit statement been provided to all active members within the required timescales? Caroline Berry was requested to investigate the process followed for providing the annual benefit statement to active members. 

 

H2 – Do these meet the legal requirements in relation to format? Members agreed that the requirement was fully compliant.

 

H3 – Has a benefit statement been provided to all active, deferred and pension credit members who have required one within the required timescales? Members agreed that the requirement was fully compliant.

 

H4 – Does this meet the legal requirements in relation to format?  Caroline Berry advised that she would check to ascertain whether the legal requirements applied to deferred statements.

 

H5 – Has an annual benefit statement been provided to all members with AVCs within the required timescales? Officers did not have authority to check  with AVC providers as to whether AVC members receive an annual benefit statement.  However, written confirmation was sought from the AVC providers that they sent an annual benefits statement to all members with AVCs within the required timescale.  Prudential had confirmed that they adhere to the requirements and no response had been received from Standard Life.  Caroline Berry advised that she would chase Standard Life for a response.

 

H6 – Do these meet the legal requirements in relation to format? Minute H5 above refers.

 

H7 – Is basic scheme information provided to all new and prospective members within the required timescales? The target had been set and contained in the service level agreement with LPP.

 

H8 – Does this meet the legal requirements in relation to format? Members agreed that the requirement was fully compliant.

 

H9 – Is all other information provided in accordance with the legal timescales?   Members agreed that the requirement was partially compliant. 

 

H10 – Where any information is only provided electronically (i.e. instead of any hard copy) does it comply with the legal requirements?  Members agreed that the requirement was fully compliant.

 

H11 – Does the Administering Authority aim to design and deliver communications in a way that ensures scheme members are able to engage with their pension provision? Members were advised that the standard letters had been reviewed when the operating system had been migrated to LPP.

 

H12 – Does the Administering Authority use a tracing service? Members agreed that the requirement was fully compliant.

 

Actions:

 

i)          F3 - To discuss the process of recording those overpayments that were written off with Sarah Bryant and would report back to members -  Caroline Berry

 

ii)         H1 – To investigate the process followed for providing the annual benefit statement to active members - Caroline Berry.

 

iii)       H4 – To check to ascertain whether the legal requirements applied to deferred statements - Caroline Berry

 

iv)       H5 – To chase Standard Life for confirmation that they send an annual benefit statement to all members within the required timescales - Caroline Berry

 

v)        Sections ‘D’ and ‘I’ to be considered at the next meeting – Victoria Freeman