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Welcome to your weekly update from the Allen & Overy Pensions team, covering all the latest legal and regulatory developments in the world of workplace pensions.
This week we cover topics including: Dashboards: updated PASA data matching guidance.
Dashboards: updated PASA data matching guidance
The Pensions Administration Standards Association (PASA) has published updated data matching convention (DMC) guidance. When dashboards are launched, schemes will need to match ‘find requests’ from dashboards users against their records – the DMC guidance (first published in December 2021) is aimed at helping schemes decide their approach to matching.
The updated version includes a new chapter on next steps, setting out topics planned for future additional guidance and why that additional guidance is needed. The topics include:
- how to treat verified and self-asserted personal identifiers (some personal identifiers which a dashboard user provides for their find request will be verified, but some will rely on the member providing accurate data: schemes will need to decide whether to rely on this data for matching);
- options for matching without a national insurance number;
- possible matching (where the data flags that there may be a match, but this could be a false positive); and
- considerations for split administration scenarios.
The guidance also now refers to the Pensions Regulator’s dashboards guidance, which includes a section on matching.