Request

1) What processes are in place and what activities are carried out when a scheme member is found to have had their pension records confused with another scheme members?

2) How are the records separated?

3) Do you inform both parties?

Response

Question 1

Firstly, the incident would be reported and investigated as a personal data breach.

To resolve an incident as described in your request, we would review the member record and contact the employers and/or members to determine the correct details before rectifying the records. This would involve setting up records for each member under the correct NI numbers with the relevant employment history for each member.

Question 2

Remedial action:

If a record is identified with incorrect details, the following process would be followed:

• Establish the correct details;

• System updates/amendments We would update the record with the correct details which may involve the movement of data from one record to another. This information is updated by pensions administrators using standard data maintenance protocols. System updates would go through normal quality checking/sampling process.

• Document updates/amendments The service uses an Electronic Document Management (EDM) system to store member records, including copies of forms and letters. If documents held on the system’s Electronic Document Management (EDM) required moving these documents would be moved by a Pension Administrator with the assistance of our Service Desk. The Service Desk will then arrange for this work to be carried out and the administrator would quality check that the relevant files had been moved/deleted correctly.

Question 3

The customers affected may be notified in the event of a personal data breach (including, but not limited to, mixing up of records) as required by data protection law, and in accordance with the guidance provided by NHS Digital, found at the below web link:

https://www.dsptoolkit.nhs.uk/Help/Attachment/148

Guidance on whether we ought to notify an individual of a personal data breach can be found summarised on page 24 of the document linked to above.

Please note that this request and our response is published on our Freedom of Information disclosure log at:

https://opendata.nhsbsa.net/dataset/foi-24405

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