TPR Data strategy 2025 (1).pdf Data strategy

Data strategy
Transforming our data
for better saver outcomes
March 2025

Contents
page
Our data strategy at a glance 3
Introduction 4
Who this strategy is for 4
Where we want to get to 4
What we're going to do 6
Our strategy for industry 7
Our data strategy 9
Data principles and data professionals 9
An internal data marketplace and the wider data ecosystem 12
Data value for better saver outcomes 14
What this means for you 15
Delivering our plan 19
How to contact us back cover
2
Data strategy Transforming our data for better saver outcomes

Our data strategy at a glance
This strategy is part of our overarching digital,
data and technology (DDaT) strategy, which sets
out a collaborative and adaptive fve-year plan
to drive adoption of the latest technologies and
standards for data.
An ecosystem with less friction will reduce burden on pensions schemes, enable
efective market competition and beneft savers through innovation. While this
document focuses on the data elements of the overarching DDaT strategy, it
is important to note that it fts within a wider programme that we hope will
transform the way both we at The Pensions Regulator (TPR) and the industry
operate to drive innovation and beneft savers.
The pensions system is undergoing radical change with greater data sharing and
transparency, creating new opportunities for savers and the industry.
Savers expect their fnancial needs to be met, their data to be accessible, and
their pension schemes to be transparent and accountable. Good, modern
investment and governance decisions require high-quality, fully digitised data to
avoid inconsistencies, increased costs and security risks.
Artifcial intelligence is also predicted to reshape fnancial markets and the
pensions landscape, introducing new opportunities and risks.
In response, we will be focusing on three key areas:
1. Building strong foundations by implementing data principles, developing
forward-thinking data professionals and advocating for open standards
for data to collect, analyse, and interpret high-quality data for better
decision-making.
2. Taking a wider data approach and reducing regulatory burden by creating an
internal data marketplace that links to the government’s National Data Library
and the wider external data ecosystem.
3. Focusing on adding value by making sure all the data we collect is directly
related to good saver outcomes and supports efcient and efective
regulation, competition and industry innovation.
3

Introduction
The pensions system stands on the brink of radical transformation. With greater
data-sharing improvements around transparency and technology, there are new
opportunities emerging for us, savers and the industry. These changes promise
to enhance regulatory compliance, foster innovation, and improve the overall
efectiveness of the pensions landscape.
Who this strategy is for
In today’s data-driven world, it is important for people at all levels within
all organisations to understand the power of data. This strategy is for data
professionals and non-data people alike. It includes scheme administrators,
trustees, anyone involved in managing pension schemes, and us at TPR. It
provides an overview of our vision for the coming years, outlining expected
changes at TPR and how these will afect you and how you work with us.
Where we want to get to
Data is growing exponentially, and our industry is no exception. Artifcial
intelligence (AI) is poised to reshape fnancial markets and the pensions
landscape, introducing new opportunities and risks.
Artifcial Intelligence involves developing computer systems to perform
tasks requiring human intelligence, like perception, recognition, decision-
making and translation. It uses machine learning algorithms to identify
patterns in data.
At the broadest level, we want savers to receive value for money throughout
their savings journey and into retirement. Empowered by technology, savers
expect their fnancial needs to be met, their data to be appropriately accessible,
and their pension schemes and providers to be transparent and accountable.
Just as people have benefted from the ease of open banking and modern
mobile technology, we aim to see similar benefts in pensions, where savers can
easily access information about their pension savings and trust the reliability and
accuracy of the data.
4

At a more detailed level at TPR, as AI and data science advance rapidly, we need
to make sure we keep pace, fnding skilled data professionals, bridging skills
gaps, and fostering continuous learning around data. We want to expand our
data platforms to manage larger datasets, while modernising our data collection
and publishing methods.
As a regulator, our role includes understanding individual scheme performance,
monitoring investment risk strategies, and evaluating the overall risk picture and
its impact on specifc groups of savers.
We need more data to meet our regulatory duties, and industry needs more data
to demonstrate regulatory compliance, enhance transparency, support digital
transformation, and enable better decision-making for the beneft of savers. We
need to ensure the data is properly joined up, searchable, and provides value,
while balancing any potential burdens.
5

What we’re going to do
Build strong foundations
Good investment and governance decisions require good quality, fully digitised
data. Some employers, schemes and their administrators are yet to fully
digitise their records and processes. Poor data quality leads to inconsistencies,
increased costs, and security risks. Isolated data storage in silos hinders analysis
and decision-making, while managing and protecting vast amounts of data,
especially sensitive information, becomes increasingly complex.
There are changes on the horizon. With the arrival of pensions dashboards, and
as schemes become fewer and larger, the standards required for data including
quality, management, and safety grow increasingly more important due to the
potential impacts of failure. Open standards for data will help us more easily
collect, analyse, and interpret high-quality data for better decision-making. Data
skills are more important than ever. We are working collectively with trustees and
the largest administrators to understand their issues, help raise standards and
mitigate systemic risks.
Take a wider data approach
Advances in technology have revolutionised the way we share and exchange
data, making it signifcantly easier for industry and government to collaborate
or regulate, enabling better information sharing. As government creates the
National Data Library, making it easier to fnd and reuse data across public
sector organisations, we will create an internal data ‘marketplace’ where our staf
can access relevant data from one central location. This will allow our data to
feed into the National Data Library and the wider ecosystem. By updating and
improving our data processes and controls, and sharing data more efciently
and efectively, we aim to reduce the burden on schemes.
Focus on adding value
Having the right, good quality data is fundamental to understanding trends and
predicting the future to derive value from the data. This is essential to enhance
regulatory compliance, foster innovation and improve the overall pensions
landscape. We are changing our ways of working while ensuring we are focused
on saver outcomes. The evolution of this strategy will be key to supporting our
future way of operating, as well as driving change.
We must be ready to embrace, adapt, innovate and lead in raising standards
across all scheme types, ensuring clear, accessible, and reliable pensions data
that meets savers’ changing needs.
6

Our data strategy for industry
Our corporate plan sets out three pillars: that we will protect savers’ money,
enhance the pensions system, and innovate in savers’ interests. As laid out in our
DDaT strategy, this translates for industry as follows:
• Reduce unnecessary regulatory burden and protect savers’ money.
• Facilitate efective market competition.
• Beneft savers through industry innovation.
To achieve these objectives, we want to put TPR as a key enabler of the pensions
data ecosystem, advocating for open standards for data.
Figure 1: This illustration demonstrates how TPR operates within an ecosystem where data can
fow seamlessly in and out of organisations and highlights how data exchanges can have a direct
impact on savers.
7

Open standards for data are simple rules that make it easy to share and use
data from diferent places. Having them would enable us to collect, analyse and
interpret high-quality pensions data from new and existing sources, allowing us
to make better evidence-based decisions and understand changing dynamics
in the pensions landscape. By modernising how we collect and make use
of our data, we would reduce the burden on employers, schemes and their
administrators, advisers and trustees.
The move to open standards would also provide an opportunity for efective
competition and innovation that can beneft savers. This would enable us to
understand the role pensions play in the wider fnancial landscape and the status
of individual schemes’ performance against their peers. Savers would beneft
from increased transparency, product provision and a competitive dynamic
market, helping them to make better and more informed retirement decisions.
8

Our data strategy
We will change how we work over the next fve years by focusing on three key
development areas:
1. Implementing strong data principles and developing forward-thinking
data professionals.
2. Creating an internal data marketplace that links to the external data
ecosystem, enabling us to make the most efective use of all our data and
reduce regulatory burden.
3. Ensuring that the value of data is focused on saver outcomes.
1. Data principles and data professionals
Empowered and forward-thinking data professionals are key to maximising the
use of data, both within TPR and across the wider pension industry, ensuring we
all build solid foundations to work from.
What we are planning
We are implementing a series of data principles to set high expectations for
data management and efective data governance. We will then share and
demonstrate our ways of working across industry with the aim of establishing a
baseline for good practice.
Our data principles
1. We value our data
2. We design data with users in mind
3. We secure and protect our data
4. We care for our data
5. We make sure our data is accessible and shared, where appropriate
6. We enable trust in our data
7. We make sure our data is easy to fnd
8. We drive the innovative use of data
9

Establishing an internal data professionals community, increasing collaboration
across diferent skill bases, and empowering our forward-thinking people will
underpin our transformation.
Some specifc initiatives include the following:
• Aligning roles and responsibilities to the relevant parts of our organisation,
collaborating between teams and streamlining controls.
• Creating a data management function to handle a broader range of data.
• Working with our policy and digital teams to design modern data collection
and exchange methods. We want to move away from form-based data entry
to Application Programming Interface (API)-based data ingestion.
• Ensuring our data professionals can use agile solutions and AI technologies to
deliver new insights and trends, and to focus on more strategic and analytical
work, thereby increasing overall productivity.
An Application Programming Interface is a set of rules and protocols
that lets diferent software applications talk to each other and share
information easily.
Agile is a way to manage projects that focuses on working in small steps,
collaborating with others, and being fexible to changes.
10

We will extend our data professional community to collaborate with industry to
bring in best practice and good innovation ideas. This will help us to implement
several further initiatives:
• Establishing a set of data taxonomies and standards for open data exchange.
• Explore moving from a system where data is sent automatically (push-
based) to one where data is requested as needed (pull-based). This can make
retrieving data more efcient and responsive and could lower the burden of
reporting for schemes.
• Collaborating with industry and sharing best practice to help facilitate the
change in our professions while maintaining existing expertise around saver
and scheme fnancial outcomes and risk.
• Setting up a working group with industry experts to help the pensions
industry improve its use of digital tools, data and technology, unlocking its
full potential.
• Bringing together pension and technology experts, along with professionals
from other felds, to design a framework for responsible innovation in pensions.
This collaboration will help share ideas and speed up impactful innovations.
• Establishing an AI advisory council, comprised of TPR staf and external
experts, to oversee the ethical use of AI technologies.
11

2. An internal data marketplace and
the wider data ecosystem
Using standardised data that fows across the wider ecosystem will reduce
regulatory burden and encourage innovation and transparency in the pensions
market for the beneft of savers.
We are frst taking stock of all the data we currently have, ensuring it is well
managed and easy to locate and use. We will then modernise how we collect,
use, and share it.
• Creating an internal data marketplace (a central place for people in TPR to
easily fnd, access and share data).
• Connecting and feeding into the cross-government National Data Library and
the wider ecosystem by publishing data where appropriate.
• Collaborating with government departments and partners on open standards
for data to improve data fow. We want to share the data we can, with the aim
of people just providing it to us once.
• Improving our data platform to enable a radical overhaul of our data collection
and exchange mechanisms, using modern API-based methods to securely
exchange data.
• Using our improved data platform to analyse diferent data sources including
large volumes of market data, near real time where needed, and enhancing
our horizon scanning and risk analysis.
• Performing cohort analysis to understand market impacts on individual savers
diferently, and developing policies for fairer outcomes.
12

We are also working on our ‘master data’ so that:
• scheme and employer data is accurate, externally verifed where possible and
joined up, eliminating duplication and inaccuracies
• contacts and companies we interact with have up-to-date details so we
can analyse our interactions, take a risk-based approach, and focus on the
right areas
• staf and other internal data are accurate and fow efectively
Master data is the core data that is essential for operations in a business.
13

3. Data value for better saver outcomes
We want the data we collect and use to support our regulatory functions and
industry innovation. We are working with industry to drive that innovation to
enhance all savers’ interests and potentially provide new commercial opportunities.
Our internal expert analysts and analytics groups are collaborating to make full
use of our new internal data marketplace, sharing skills to better use AI, data
science, actuarial and risk models.
• Increasing the data profciency for our internal teams to make the most of
new and developing analytical capabilities.
• Embedding knowledge management and the efective use of our
unstructured document data across case teams, legal professionals,
intelligence and others.
• Understanding and maximising our data quality, which will allow us to set
standards and demand high-quality data from ourselves and others.
• Alongside existing scheme returns, recovery plans and HMRC PAYE data that
we already collect, we will bring in additional market data including scheme
asset allocation, investment strategy details, and frequent valuation or market
pricing data.
• Accelerating our AI journey by exploring appropriate and use cases to
enhance our capabilities and drive innovation.
We are improving our ability to experiment with AI, allowing us to innovate
both within our organisation and in collaboration with industry. This will include
creating an AI sandbox as part of our broader regulatory sandbox strategy.
A sandbox is a safe, isolated environment where you can test and
experiment with software or data without afecting the rest of your system.
14

What this means for you
We want to capitalise on initiatives like open fnance in our industry, allowing
savers to better manage their pensions by integrating various fnancial services
and fostering greater engagement with their retirement planning.
We want the pensions industry to adopt good data practice, embrace the
modern data ecosystem, understand the wider benefts of sharing data
efectively, and collaborate to help defne how this can work for schemes,
employers, and savers.
Bad data (information that is incorrect, incomplete, outdated or poorly
formatted) drives extra costs. For defned beneft schemes, these costs make
them less attractive to buy out. For all schemes, pensions dashboards are raising
expectations from savers that need to be met. We recognise the diferent
lifecycles of defned contribution and defned beneft schemes and how this
impacts your data. But at the heart of this, all schemes require good data to
ensure they are efective and efcient.
Using our data in a better way will improve how we work, provide guidance,
direction and encourage innovation. We need the pensions industry to engage to
help us take this forward.
15

The impacts of our plans are as follows:
Reduced unnecessary regulatory burden
With strong principles and a community of experienced data professionals
working closer together, we will make better use of data we already have,
reducing the need to ask for more information unnecessarily.
Whatever your role, you can have confdence that we are using data and AI
efectively, efciently, and ethically to target our regulation to best protect saver
outcomes. We are expecting the industry to digitise personal member data
currently in paper form and extract it into databases. We will work with industry
to set clear standards for data management and record-keeping, and clear
expectations for data skills and fuency across the industry, as well as working
together on unlocking the potential of AI.
If you are an employer, trustee, or adviser, the way we collect data from you will
change. We will introduce standards such as standardised data shared through
APIs from diferent scheme systems. As we start to capture and analyse data at a
more granular level via modern methods, it will reduce the burden to summarise
information for us and reduce the efort in manually transferring data.
Our investment in new tools will improve our modelling, analysis, and forecasting.
This means we will record and analyse interactions with you more efectively as
part of our regulatory oversight and respond more quickly to non-compliance.
We are committed to working with other government agencies to move to
a model where we ask for data only once, reducing regulatory burden and
supporting industry. We will publish our data where possible to enable you to
build on our datasets and gain additional insight.
We’re tapping into cross-governmental initiatives like Essential Shared Data
Assets and utilising the Ofce for National Statistics’ Integrated Data Service
to ensure our policies are designed with the best information available. If you
are one of our direct government partners like the Money and Pensions Service
(MaPS) or the Financial Conduct Authority, we will continue working with you
to ensure that we can move to modern data-sharing technologies with the
appropriate governance.
16

Reduced unnecessary regulatory burden continued...
If you are an employer, pension scheme, trustee or adviser, our teams will
have new tools to analyse trends and predict risk. We will have more nuanced
conversations with schemes about their investment decisions and risk controls,
enabling proactive regulatory interventions. Using our data models and AI tools,
we will augment regulatory activity, analyse scheme investment strategies, and
fag high-risk strategies.
If you are a saver, we will enhance the protection of your money by using
signifcantly more market data for horizon scanning and market risk assessment.
We will prioritise enforcement and intervention activities on higher-risk
employers and schemes. We will start to measure our own performance based
on your outcomes.
Enabling efective market competition
We will actively encourage partnerships across the pension tech industries
to share insights and develop integrated solutions. We will help develop
standardised data structures and taxonomies for use across the industry,
benefting employers, pension scheme providers, trustees, and their advisers.
If you are a partner, we will have improved standardised ways of securely sharing
data with you to improve collaboration outcomes. If you are an employer, pension
scheme, trustee, adviser, or administrator, we want to ensure that savers can see,
in plain numbers, what they’re getting for their money. We will engage with you
to develop the policy framework to enable improved transparency. This additional
transparency will enable employers to make better decisions, drive competition
among providers to improve performance, and enhance market efciency.
We want to contribute to the development and alignment of international
standards for pensions data that prioritise transparency and security, enabling
efective competition and good decision-making for savers. We will continue
to actively collaborate with MaPS, supporting pensions dashboards for full
transparency of fnancial health for savers.
17

Benefting savers through industry innovation
We believe the changes we make because of our strategy will positively afect
millions of savers across the £2 trillion pensions landscape. We intend to keep
building our teams of experienced data professionals and innovative thinkers to
push forward ideas and processes for better retirement outcomes.
AI is helping businesses run more efciently and with better insight. Generative
AI-enabled tools will provide access to regulatory expertise in a completely
radical way. By collecting and publishing data to the overall data ecosystem
using open standards, we will support third-party innovation, which could lead to
new business opportunities for a thriving pensions system.
If you are a market entrant or pensions technology provider, we want to
support the development and adoption of new technologies that enhance the
transparency and efciency of pension services. We will work with industry to
generate a safe space to collaborate with us on data and AI.
We will encourage the development of pension products that prioritise
environmental sustainability and societal impact. We will develop a framework
for ethical technology and data use that all pension providers can adopt. Better
use of data will enable us to drive innovative approaches to improve saver
outcomes, leading to better and more personalised help and products for savers.
18

Delivering our plan
The external environment is volatile, uncertain and fast-moving, particularly
in the world of data. This demands a fexible, adaptive approach to strategy
development, which allows us to pivot and prepare for diferent eventualities.
Elements of our strategy and the data ecosystem will develop at diferent paces,
allowing us to adjust our ambitions as needed.
We have already started delivering our plan, and industry will notice a diference
in how we interact with them around data. As part of our DDaT strategy, we
commit to working in the open, sharing our progress via industry engagement and
reporting on our key measures of success in our Annual Report and Accounts.
We will engage with trustees, pensions professionals and schemes to get their
feedback and ideas. We will connect with established industry and government
working groups, and also establish our own where needed, to develop and
implement common standards. We will work with the tech industry from across
sectors and countries to learn lessons and move the industry in the UK forward.
We have also invited some of the largest administrators to collaborate with us to
understand how they operate and mitigate systemic risks.
With pensions dashboards no longer on the distant horizon, it is now time for
schemes to get their houses in order. We will be writing to all chairs of trustees
several times in the year leading up to their dashboard’s connection date, setting
out the clear actions they must take. We urge you to think of dashboards as
an exciting opportunity for innovation, and to use it as a springboard to start
getting to grips with your data.
We’re imagining a future where data has acted as a catalyst for pensions
innovation, transparency and regulatory efectiveness, benefting savers and
enabling them to transform the way they plan for retirement. In this future,
employers and trustees enjoy seamless data management and efortless
compliance, slashing administrative burdens and costs. A dynamic, collaborative
approach ignites innovation, fuels competition and ultimately delivers the best
outcomes for millions of savers.
We hope you will join us on this journey, be a part of this transformative
movement, and help shape the future of pensions by collaborating with us.
19

How to contact us
Telecom House, 125-135 Preston Road, Brighton BN1 6AF
customersupport@thepensionsregulator.gov.uk
https:/
/www.thepensionsregulator.gov.uk/
https:/
/trusteetoolkit.thepensionsregulator.gov.uk/
Free online learning for trustees
https:/
/education.thepensionsregulator.gov.uk/
Free online learning for those running public service schemes
Data strategy
Transforming our data for better saver outcomes
© The Pensions Regulator March 2025
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