Pension scheme trustees urged to review policies affected by Covid-19

Pension scheme trustees should keep policies and protocols potentially affected by Covid-19 under review and schedule periodic assessments as part of their business planning, Squire Patton Boggs (SPB) has said.

In its Pensions Lessons for Trustees – The Lockdown Year publication, SPB noted that recently evolved policies may not be operating effectively due to the altered working conditions that many pension schemes and workforces are adapting to.

Trustees were encouraged to assess whether recently changed policies, stemming from GDPR or cybersecurity for example, have been affected by remote working, virtual meetings, furlough or shielding.

Furthermore, SPB urged trustees to consider whether these policies reflected the changing nature of risks faced by schemes “given the inevitable change to the economic outlook, volatility in investments, and potential financial pressures on sponsoring employers”.

The law firm highlighted trustees’ data privacy policy and queried whether it considered individuals working from home or accessing scheme data on personal devices, and whether recent postal delays had prompted greater reliance on sharing information digitally.

SPB said that trustees should check whether their policy is up to date so information can be shared and updated securely, and to identify how data subject access requests should be handled.

“High-profile cybersecurity attacks have emphasised the importance of having up-to-date and operational data breach response plans,” the report continued.

“It is important to test these plans and to ensure the availability of key individuals who are responsible for setting the wheels in motion and ensuring that tight deadlines for reporting a breach are met.

“We also recommend discussions with service providers who process scheme personal data to ensure that measures are up to date for identifying, reporting, investigating and responding to a suspected data breach event quickly.”

SPB also encouraged trustees to consider the benefits of following the Pension Protection Fund’s sponsor insolvency contingency plan guidance to protect members if insolvencies were to occur.

Furthermore, trustees were urged to consider having a training session on the importance of legal privilege and adopting a protocol governing how privileged material should be shared, referred to, recorded, stored, and created.

“Where legal advice is sought (or litigation or regulatory intervention could be on the horizon) then the ability of the trustees to claim privilege can often be enhanced, and not inadvertently lost, by taking simple precautionary steps,” SPB concluded.

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