The role of the Sussex Police Pension Board is to assist the Scheme Manager (the Chief Constable) in ensuring good governance and effective and efficient administration of the Police Pension Scheme.

Iain McCulloch

Chair

Chief Financial Officer

Office of the Police & Crime Commissioner for Sussex

Pete Gillett

Employer – Deputy Chair

Director of Finance

Sussex Police

Matt Webb

Member

Police Federation

Sussex Police

Daisanne Summerfield

Employer

Head of Shared Business Services

Sussex Police

C/Supt Lisa Bell

Member

Superintendents Association

Sussex Police

ACC Dave Miller

Employer

Assistant Chief Constable

Sussex Police

Graham Bradley

Member

Narpo

Retired

 

Contact us

If you'd like to contact the Board, please email pensions@sussex.pnn.police.uk with the subject heading Sussex Police Pension Board.

Minutes

Department/ Division: SBS
Name: Sussex Police Pensions Board
Location of meeting: Malling House Room 1
Date: 6th February 2020
Time: 10:00-12:00


Chair Iain McCulloch IM Chair
Board Members: Pete Gillett PG Employer Representative – Director of finance
Matt Webb MW Employee Representative – Federation
Graham Bradley GB Employee Representative – NARPO
C/Supt Lisa Bell LB Employee Representative - Superintendents Association
Daisanne Summersfield DS Employer Representative – Head of SBS
Board Advisors: Jo Langley JL Finance Lead
Kelly Ellison KE Pensions Officer
Ben Read BR Equiniti
John Kakatsos JK Equiniti
James Casey JC Equiniti

Kevin Courtney KC NPCC Pension Advisor

Minutes: Annalise King AK Secretary

Apologies: ACC Dave Miller DM Employer Representative - Assistant Chief Constable


1 Introduction and Apologies

• Declaration by the Chair that the meeting is quorate
• Apologies for absence and welcome to Guests
• Conflicts of Interest IM


2 Minutes / Actions from Previous Meeting

• To agree the minutes and actions of previous meetings
• Progress on actions log IM


3 Member Web Portal Demonstration (Equiniti Presentation)

Equiniti gave a demonstration of how the web portal will work and what it will look like. JK/JC


A Pension Administrator Update (BR)

• Quarterly update to the Board
• Current progress with the Improvement Plan.

Firstly, there is a new Team leader, who is the first point of contact for any queries; her contact details can be found on the report.

Equiniti received 1,600 items during this period. It was noted that the SLA % on page 6 was low at 88.83% and shows all transactions that were missed. BR went over the improvement plan and advised all work is now being completed within target. MW questioned the cases that have missed SLA found on page 8-16; BR has assured that these have now all been completed.

Phone calls in to the help desk are at a high number and a break down can be found on page 17-19 of what the calls are made up from. The 253 not listed in the key relate to Annual Benefit Statements. BR to revise this on the report.

Complaints during the period have been listed, the majority relating to benefit statements and issues around that. JL informed the board that a report has been sent to The Pensions Regulator (TPR) regarding the data breach however we haven’t had anything back or any comments back to date.

LB asked if she can share this document wider than this meeting; BR informed the Board that a redacted version of this document can be shared to put on the website. Put in communications around this paper that figures have been improved and that all issues have now been resolved and this is noted in previous minutes.

Action PPB/005/2020 – 2 BR Produce a redacted version of the Q3 Quarterly report removing the team telephone numbers for public viewing.

Membership movement on pages 22 & 23 activity shown and last page gives details of officers who have opted out/career break/retirement etc. Additional officers coming in so will see this number increasing.

IM has some concerns on why officers have opted out and what follow up takes place around this. DS informed they will explore options but the employer cannot be seen to influence an individual’s decision.
DS advised we are drafting a one page document for Op Uplift and will explore what else we can do to inform new recruits. MW believes that this is down to the individual’s affordability.

Action PPB/005/2020 – 3 DS to take this away and find out the follow up around officers opting out.

MW suggested that we dedicate a certain team to talk to individuals with regards to financial advice about opting out of the pension scheme. There is a website available called Unbiased.co.uk which provides details of financial advisors which we can direct officers to if requested. BR

DS/JL - To take this away and look at providing information about the pension plan so they can make an informed decision

Additionally, auto re-enrolment takes place this year and all officers who have previously opted out will be re-enrolled.

5 Legacy Complaints and compensation – an agreed way to gather facts to specific issues

MW informed us that this is about dealing with potential legacy complaints. It was unclear what was meant by the term legacy and DS wanted some examples so we could put a plan in place.

LB advised that she has had conversations with members around the HMRC Scheme Pays fines from 2016/17 and officers are now understanding what Equiniti’s role is in this. What officers would like to know is who will be accountable for these errors?

BR informed the Board that Equiniti would provide administration support for any issues relating to this but would not take liability for the previous administrator’s errors. We have Scheme Pays plans submitted but this is yet to be actioned. Scheme Pays payment that have not been made are being issued with HMRC fines from possibly the previous provider’s actions.

We would need to gather the details on a case by case. Suggested Officers send any documentation relating to their specific issue to KE so it can be collated. In addition, a meeting will be arranged with the Chief Constable so that the issues can be clarified and understood. Sussex Police requires the facts and evidence to capture this and find a way forward.

Action PPB/005/2020 – 4 DS to set this up with KE & JL to start collating information to look into this further.

PG has recommended that we consider sending a letter to HMRC to explain the background and clarifying the context re the pension transfer.

Action PPB/005/2020 – 5 PG/DS To follow up with Ben Read after meeting with the Chief Constable and others.

Finally, it was reminded that any complaints should go through the internal disputes resolution process (IDRP); if officers are still unsatisfied then they can go to the Pension Ombudsman. MW

6 Pension Remedy / McCloud Update

KC informed that the NPCC are working with the Home and the legal process is still ongoing. Sides have put forward final resolution and this is still being discussed. The legal process still ongoing for the claimants. There are approximately 1,300 claimants nationally.
Tactical discussion with each scheme advisory board are underway and it is expected that there will be a three month of consultation commencing April/May then legislated changes will have to be made. Any messages that go out around this need to state that remedy is not KC / DS

the resolution. There is a National Pensions Remedy Group set up and meeting monthly to inform, capture and share information surrounding this complex issue.

DS informed the Board that the Sussex & Surrey Remedy Working Group has been set up and a project board is in place. We have linked in with Corporate Communications to get a dedicated page on the website for this issue. We will also need to increase resourcing to cope with the massive demands and work activities relating to this issue.

7 Review of Reported Breaches

• Review any breaches during the quarter
• Annual Benefit Statements
• Reporting Breaches Procedures Nothing to report JL

8 Work Plan

• Monitoring of the work plan

We are busy working on this. Board papers are being published on the website. Under FOIs.

Action PPB/005/2020 – 6 BR to look at providing historical pension increase percentages on the portal.

Action PPB/005/2020 – 7 DS/JL to look into the content for sending the newsletter out in April. Ensure GB has sight of this before it is sent. JL

9 Risk Register

• To review and update the Pension Board risk register

Need to show were risk sits. Keep Data accuracy at 12 as we need time to assess the issue. JL would like to perform data checks before Go Live for the Web Portal. As part of the communications we will ask members to also check their details.

Monthly interface report from payroll into Equiniti states it is sent Monthly, however this normally falls quarterly due to current system issues so this needs to be updated on the risk register.

Potential loss of digital data of deferred records; this needs to be rethought through and reworded to physical data.

Cyber risks paper to be reference in the risk registry report and score adjusted if deemed appropriate.

Member portal to be changed to amber.

Latest date on document needs to be updated. JL

• Cyber risks register- Report has been set up and will be updated yearly.

Action PPB/005/2020 – 8 KE/JL to update point 9 on the Cyber Risks paper to include ‘and Pension Board’ after scheme manager.

IM gave his thanks to KE & JL on their hard work and effort put into this paper.

10 Ill Health Retirement & Injury Award Update / Injury Award Reviews

No paper on this as LM was not able to attend She has informed us that she will try to make it to the next meeting.

Action PPB/005/2020 – 9 PG to send LM an email about attending the next meeting and bringing the paper. DS

11 Board Member Training

All online training is up to date. LB needs to be added to this.

Action PPB/005/2020 – 10 KE Write to LB to ask whether she will be a standing member of the board and ask her to complete the pension board training.

- Cyber Risk Training in conjunction with Surrey Board (11th November 2020) IM

12 Consideration and Discussion of Actions in advance of the next meeting

Nothing to raise at this stage. IM

13 AOB

Web Portal – Member self-service project board is being set up with initial meetings to start looking at the layout etc with the Surrey & Sussex Police communications lead for the project. Following this, the project board will be opened to representatives from both boards and key users. It is to be noted that the more customisation that is done, may cause delays however the aim is to deliver the portal as soon as possible.

Action PPB/005/2020 – 11 DS to provide a paper for Board overview.

Action PPB/005/2020 – 12 BR to do some investigation around the NARPO deduction issues and will update on what has happened with GB. All

Date / Location of next meeting: Thursday 30 April 2020: Malling House Meeting Room 2

Minutes

Department/ Division: SBS
Name: Pensions Board
Location of meeting: MR – HQ – Amberley Block Meeting Room 1 (First Floor)
Date: Thursday 7 November 2019
Time: 10:00 – 12:00


Iain McCulloch IMc Chair
Matt Webb MW Member Representative - Federation
Pete Gillett PG Employer Representative - Director of Finance
ACC Dave Miller DM Employer Representative - Assistant Chief Constable
Graham Bradley GB Member Representative - North Sussex NARPO
Daisanne Summersfield DS Employer Representative - Head of SBS
Board Advisors
Jo Langley JL Finance Technical Lead
Ben Read BR Equiniti
John Kankatsos JK Equiniti
Julia Wyatt JW Equiniti
Laura Pertile LP Equiniti
Kelly Ellison KE Pensions Officer
Annalise King AK Secretary
Holly Cobby HC Secretary

Apologies: D/Supt Carwyn Hughes CH Member Representative - Superintendents Association


1 Introduction and Apologies

• Declaration by the Chair that the meeting is quorate
• Apologies for absence and welcome to Guests
• Conflicts of Interest - None IMc

2 Annual Review of the Terms of Reference

The current Terms of reference (TOR) were included on the agenda for discussion.

MW brought up the fact that some people out there have a separate business for income. This is taking them over their lifetime allowance. Suggested that we put something in the TOR to increases knowledge around this issue. As a force we need to consider a wider knowledge and understand on this and provide relevant advice. This has already been looked at and we have held a number of sessions around raising awareness. This should be included in section 5 of the TOR.

Election of members – As approved by the Chief Constable

On the 21st August 2019 IMc met with CC Giles York to present an annual report of the agreed work plan. IM was appointed Chair again and PG was appointed as the Deputy Chair, which is the first time that a deputy has been appointed. MW was reappointed as his term had lapsed. The Board welcomed ACC Dave Miller as an Employer Representative. The Chief sent thanks to the Board for all their work. IMc

3 Minutes / Actions from Previous Meeting

The minutes of the last Pension Board were agreed.

In the future, it was agreed that the draft minutes would be sent around shortly after the board meeting so any changes can be made

Progress on actions log recorded. IMc

4 Pension Administrator Update Quarterly update to the Board

The team have appointed a new team leader, she will be responsible for looking after Surrey and Sussex.

Data Breach

The 2019 benefit statements went out on the 30th August. It then came to light that there was an issue around some of the addresses that were on the system which resulted in a number of statements being sent to an incorrect address. This resulted in a data breach and a Gold command team was set up to deal with correcting this. (Further details of the breach can be found in Section 5 Breaches.)

DM informed the Board that a number of officers still hadn’t had their annual benefit statement, including himself, and would like to know what is being done to resolve this issue.

Equiniti are liaising with JL and team for a list of any officers who hadn’t received their benefit statement. JL has passed these details on and the statements have been sent out. Equiniti are sending out statements as and when enquiries are received. BR

Action PPB/004/2019 – 1: LP/BR To go through the list of officers still awaiting their statements and come back to JL in 5 working days with the list and how this is being dealt with.

Other matters were raised by Board members at this point that they have received poor responses through the helpdesk, there have been P60 issues, the data breach, slow to process retirements, and also the customer service when making a complaint needs to be looked at. All these issues need to be reflected on.

MW raised a case which had some significant issues and it concerns him that there are still ongoing issues.

Action PPB/004/2019 – 2: MW To send information on this case to BR in an email so that Equiniti are able to look into this and report back

LP informed the Board that there has been a base team built in Crawley. Listening to the feedback from this meeting, she is aware that Equiniti, as a company, have a knowledge issue. They have assured the Board that they are capable of putting this right.

JK explained that the next step is to come back to the Board with what Equiniti are going to do to correct the issues that have been raised, together with a timeframe as Equiniti will need to do investigations around all these issues. The priority for the board is to look at all the annual benefit statements and Pensions savings statements then to work through other issues. Equiniti will collate a paper to share with the board.

IMc has suggested that, given the issues, an extra ordinary Pension Board meeting with Equiniti needs to be scheduled to come up with a resolution.

Action PPB/004/2019 – 3: DS to set up an additional meeting with Equiniti to discuss current issues and how they are to be resolved

Apologies from Equiniti have been given for all the issues that have occurred recently.

Member Web Portal Update

With regards to the member web portal we have been working internally on further updates. The next step is awaiting sign off; this is currently sitting with the InfoSec teams at Surrey and Sussex Police. Equiniti and JL are setting up a meeting to include Info Sec and ensuring the right people are in that meeting.

Action PPB/004/2019 – 4: JL to secure an attendee from InfoSec at the Sign Off meeting next week

Step one is to finish the build, step two is to upgrade the system that the force is currently on. From that point they can then launch the portal. Equiniti expect to launch the self-service by June 2020. This is a priority and the force are currently at the top of the IT list.

DS has asked that we have the assurance that the web portal is being done as this has been the key driver to why the forces are in contract with Equiniti.

IMc has expressed his disappointment that the system is still not ready to be deployed despite the concerns that have been consistently raised by Sussex and that had the system been deployed we would not have suffered the ABS data breach issue.

Action PPB/004/2019 – 5: JK / EQ to set up a project plan and have the key stakeholders working together to create a fully detailed project plan.

Action PPB/004/2019 – 6: JL/DS to have a weekly catch ups with the team and Equiniti for progression.
5 Review of Reported Breaches

BR gave a brief summary on what happened during August 2019 data breach. This list was updated with the correct addresses, however there were 746 statements sent out to previous addresses. This was picked up 3 weeks later. This data breach came to light due to the higher number of queries coming in and forwarded letters from a previous address. There were also a lot returned to Equiniti.

Full check of everyone at the point of the breach had been made and Equiniti raised the breach to JL, where JL was able to liaise internally with the data breach officer in Sussex. Equiniti have since updated the pensions system and there are now no old addresses held on the system.

During this data breach a Gold command group was set up straight away. The report has been sent to ICO and this has come back with no further action required and no fine has been issued by them.

Equiniti have had around 10 responses in the way of complaints.

The breach was also raised with The Pensions Regulator (TPR). There has not been any feedback from TPR as yet.

Action PPB/004/2019 – 7: JL To share the ICO response and the TPO response with the Board to confirm the responses received and to update the risk register if applicable for any outcomes. BR

6 Work Plan

Monitoring of the work plan

There is a proposal to have a joint pension board with Surrey. JL is planning to set up a workshop to scope the look and feel of the Board JL will try to get this done before Christmas, with the plan for the merge to go ahead in April 2020. (See Section 8 below)

Temporary salary - MW and DS have both taken legal advice around this. Based on the legal advice given, the letters are scheduled to be sent out the week of 18th November. This issue has affected approximately 300 officers.

Action PPB/004/2019 – 8: DS To send latest briefing note around to all

Action PPB/004/2019 – 9: DS To send draft temporary salary letter to MW to review and possibly add additional paragraph. JL

7 Risk Register

To review and update the Pension Board risk register.

Revised risk register has been completed. Need to look at the Cyber security area which is currently marked as a Risk 4. A full risk assessment needs to be completed on this. We also need to have assurance around Equiniti’s cyber security. IMc

8 Surrey/Sussex Joint Pension Board Proposal

Look to align the tender process as well as the joining of both pension boards. Ian Perkin is leaving Surrey and would like the Board to consider the joining of both pensions’ boards before he leaves in April 2020. GB is not 100% sure the Sussex board is functioning perfectly yet. The Board think that there could be benefits to merge both pension boards together but would like to see both boards functioning well before merging as one. DS/JL will set up a working group to explore the options relating to combining Sussex and Surrey Pension Boards in the future.

Action PPB/004/2019 – 10: DS/JL to get a working group together to work through the governance and structure to combine the two Pension Boards DS/JL

9 Cyber Security Arrangements – Review and risk assessment

NPCC are raising this as a top issue. Review what we have in place and how we transfer data. We need to understand Equiniti’s process as well as our own.

Action PPB/004/2019 – 11: JL/KE to work through the NPCC paper and commence a full risk assessment JL/KE

Date / Location of next meeting: Thursday 6th February 2020 at 10:00-12:00 in Malling House Room 1

Minutes

 

Name:

Pensions

Pensions Board

Location of meeting:

MR – HQ – Malling House Meeting Room 1 (First Floor)

Date:

Thursday 8 August 2019

Time:

10:00 – 12:00

 

Attendee

Role

Attendance

Board Members

 

 

Iain McCulloch (IMc)

Chair - Chief Finance Officer, PCC

Present

Matt Webb (MW)

Member Representative - Police Federation (Deputy Chair)

Present

Daisanne Summersfield (DS)

Employer Representative - Head of Shared Business Services

Present

Graham Bradley (GB)

Member Representative - North Sussex NARPO

Present

Peter Gillett (PG)

Employer Representative – Exec Director Finance Commercial Services

Apologies

D/Supt Carwyn Hughes (CH)

Member Representative - Superintendents Association

Present

Board Advisers

 

 

Ben Read (BR)

Equiniti - Service Manager

Present

Joanna Langley (JL)

Surrey Police – Finance Technical Lead

Present

Kelly Ellison (KE)

Sussex Police – Pensions Officer

Present

Marcus Potter (MP)

Information Management

Present

Louise Monk (LM)

Occupational Health

Apologies

Minutes

Holly Muggeridge

Present

 

Welcome (Chair)

  • Declaration by the Chair that the meeting is quorate

  • Apologies for absence and welcome to Guests

  • Conflicts of Interest

No conflicts of interest were declared.

PART 1

  1. Minutes / Actions from Previous Meeting (Chair)

The previous minutes and actions were agreed as an accurate record.

IMc to share the bullet points of the Police Pension Board event and advice following the meeting.

GB highlighted that some of the actions in the minutes did not appear in the action log; this will be corrected. It was noted that GB was passionate about matters during the last meeting which did not come through in the minutes. Following on for the last meeting there is an update regarding the recruitment letters; these have been sent out by NARPO resulting in 67 new members which is positive.

Action 002/2017 – 1 – this action relates to online papers being made available electronically. The papers and agenda for this meeting are all available electronically and all public facing papers are reviewed and redacted. GB, BR and IMc cannot access the papers as they are all external. DS will follow this up with JL to ensure that papers can be available. This action will be moved onto the work plan under the current project section and will be removed from the action log.

Action 7 (9/5/18) Joint Pension Board - DS will meet with KC to gather information on how to progress. BR attends Surrey Pension Board as well. This is to be moved to the work plan as an ongoing project.

PPB 002/2018 – 5 Temporary Salary- There is a lot of ongoing work being done; this is something that MW has highlighted for years. The project team are in place and have done manual calculations. The letter has been drafted and is now with legal for oversight; this will then be sent to MW. When the letter has been completed it will be shared with the board for information purposes and, as long as senior stakeholders are in agreement, the letter will be sent out in early September. The letter will detail the amount that each of them owes and how much we take back; the payments will be as flexible as possible. If this causes any financial hardship then it will be dealt with as there are mechanisms of how to pay.

GB asked that he be kept updated with the progress as this affects retired officers. GB asked whether it would be useful to have a scheme manager’s recommendation; this is something that IMc would like to do.

IMc would like to know the total value of the contributions and a breakdown of whose pension it will and will not affect; there may be retired individuals who are on the correct pension but need to make a contribution.

JL has this information and will collate by Tuesday 20th August 2019. A telephone conference is to be arranged with JG, DS, IMc and MW to discuss.

This item to be taken off the actions and added to the Work Plan.

PPB/002/2018 – 6 McCloud Case - JL said that there was an update that came out at the end of July and she looked at the comms that came out around that on the audit but there is no update currently. The Home Office and Government are looking at what this now means and how to make that right. IMc said that actuaries revalued the pension scheme and it is important to identify who has been impacted.

IMc asked what the best way would be to communicate with retired officers who are implicated. BR said that the population of retired officers would be very small as those affected transitioned into the 2015 scheme and are likely to still be active officers. The others affected would be ill health pensioners but the number of this would be very small due to the period of retiring from the 2015 scheme.

This item to be taken off the actions – on the Work Plan.

PPB/003/2018 – 5 Member Web Services - At the end of May 2019 DS and BR met with designers and InfoSec from Surrey and Sussex where they presented a high level document giving the structure that Equiniti proposed to build; this has been agreed in principle. There have been security questionnaires from Surrey and Sussex InfoSec as well as compliance questionnaires and risk assessments to ensure that there is the right risk assessment.

A low level design document is now being worked on and should be available by the end of August. Following this, Equiniti would be in a position to provide a timeline of delivery. When the compliance questionnaires and risk assessments are back from InfoSec, Equiniti will be ready to start the build.

GB asked that he and MW are kept updated with this work. DS said that when it comes to branding and designing of the product she would like to engage all those who may be interested. BR advised that Equiniti would give a workshop approach with a demo to give users the opportunity to decide what goes into the design; a branding exercise can be performed when the system is live on the screen. It would be beneficial to have involvement from those on the operational side.

Item to be taken off the actions – on the Work Plan

PPB/001/2019 – 1 Abandoned Calls – BR explained that one part of the action as to give the board information on the category of abandoned calls; this is difficult to know as the calls were not answered. DS asked whether this relates to the busy volume areas such as annual benefit statements; BR advised that as we are still in the first year of the Sussex contract, he has not been in the position to identify trends across Equiniti. The number of calls up 30- 40% up on what is expected and there is a lot of general interest around pensions. The number of calls peak when P60’s and pay slips come out.

PPB/001/2019 – 2 – Scheme Movement Data – The board agreed that the movement data has been really well presented. BR provides 2 versions of the report; one being sent to JL, DS and KE including members data, and another for the pension board removing any member data; due to GDPR members names and personal data are not included.

MW said that his focus was around the missed SLA matters but this has since been clarified and is 100%; some were missed but this was only by a couple of days.

PPB/002/2019 – 6 – Publishing Pension Scheme Information - There were a number of concerns from GB; an action came from this for PG to raise the compliance issue with JL as since the Single Online Home was introduced, the Board Papers are no longer available.

This is due to migration issues. Both forces are breaching what we should be doing. GB felt that the focus of the website has changed from an informational tool to an operational tool.

2.            Pension Administrator Update (BR)

  • Member Web Services

  • Scheme Movement Data

  • Abandoned calls

  • Scheme Breakdown

  • Pension Payment Advice Slips

During the period there were 1270 transactions which was an increase on the previous quarter. Overall there have been a drop in calls over the quarter but the help desks in general have been busy. The team has strengthened over time. There were some missed SLA’s; one due to divorce and a police transfer out.

It was mentioned that nothing has been recorded on the report around annual benefit statements; BR advised that these are currently being worked through at the moment and are due to be out at the end of August. KE sent through an up to date address list for all officers to Equiniti.

GB noted that there are two categories missing on the key on page 9 (Call Types); 21% (orange) should be P60’s and 4% (light blue) is benefit statements; BR is to amend this and add volumes as well as percentages.

Action- BR to amend the admin report to show missing categories as well as volumes and percentages.

There have been no complaints or compliments recorded during the period; anything raised will have been answered and therefore has not turned into a complaint. GB raised concerns on two key areas around widow pensions and incidences where widows are being ‘harassed’ for overpayments at a really poor time. BR advised that where a pension payment is made before Equiniti have been notified of the member’s death, this can result in a mismatch of payments. Equiniti are looking into this matter and there is a process in place to improve how they request any overpayments. It was reminded that Equiniti should be notified immediately in the event of a pensioner’s death so that they can stop any future payments and minimise any overpayments.

GB raised an issue regarding 300 P60’s for pensioners that were not sent out; this was initially raised with the Hastings NARPO branch. BR explained that the pension system can hold multiple addresses but only one active address can be listed; the information received from Capita showed the current addresses and previous addresses and therefore no P60’s were generated. MW queried whether these matters are listed as complaints. GB explained that the report goes until the end of June and the matters did not come to light until July; they will likely appear on the next report.

IMc asked what DS’s view is on the performance of Equiniti; DS goes over individual cases if something comes up. She is confident that everything is being dealt with and everyone knows the routes in if they need to. IMc said that it is important to strategically think about the 20k new officers and recruitment plans; we currently do not know the funding or numbers for this.

3.         Annual Report 2018/19 – Drafting & Content (Chair)

This is outstanding and will be completed within the next few weeks. IMc is attending a meeting on 21st August 2019 with Chief Constable Giles York and would like any board member to attend also. The information for this will be circulated outside of this meeting. IMc would welcome an offline chat with Board members to ensure all are happy with the Annual Report to be presented.

4.         Annual Review of the Terms of Reference

This will be discussed at the next board meeting. MW’s TOR membership has expired but the board wish to nominate him again if he is happy to be a part of the board; this can only be for a year and then MW’s successor will need to be nominated.

PART 2

  1. GDPR / Data Protection Legislation Update (MP)

Presentation on GDPR/ Data Protection Legislation given by MP, Head of Information Management. Presentation was distributed with the papers for this meeting.

2.         Scheme Advisory Board – Bulletin July 2019

  • McCloud case

  • The Pensions Regulator Annual Governance and Administration Survey Results / Key Issues: Cyber Risks

  • Evans & Ashcroft v South Wales Constabulary

Nothing to raise. MW had recent announcements around NHS pensions and allowances; MW to send the links that cover this to everyone as an update.

3.         Board Member Training (Chair)

  • Update

Training Schedule to be kept up to date; MW has provided his to KE. There is another Fire Training Course on 12th November 2019 around Pensions and Tax issues.

4.         Work Plan (JL)

  • Monitoring of the work plan

IMc said that the new work plan is brilliant as JL has picked up on the comments from the recent Government Scheme event.

GB questioned where we are currently with the GMP reconciliation. BR said the GMP consultant met with Capita for the handover and since that meeting there has been no progress. Capita are progressing with Phase 2 ready for Equiniti to do the reification of the scheme for Sussex. JL to chase Capita for an update on current progress.

Action- DS to escalate with Capita for an update.

Cyber risks is be added as an ongoing project. There is a TPR survey response to demonstrate that we have reviewed it and will inform the risk register; this has been done and DS will report back at the next board.

MW said there is a pension increase for people aged 55 or over or those under Ill Health Retirement with an uplift every year and asked whether anything has been given to the under 55’s to explain the uplift that will occur on their 55th birthday.

GB said that there used to be a letter notifying those of the increase along with GMP information meaning that the individuals would be able to calculate their state pension and what their pension would likely be at 55. GB to send through the letter about increases to pensions to JL who can incorporate this into the newsletter.

Action- GB to send through the pension increase letters to JL.

DS advised that over the next two months Sussex and Surrey Police are holding pensions tax awareness sessions for individuals in association with Barnett Waddingham and dates are currently being secured. JL has scoped who fell into the category, as well as LGPS groups, and also lower ranking officers with second business interests; vetting should be able to have an idea of who this would cover.

Sussex and Surrey Police also plan to hold some annual benefit statement drop in session at 3 locations in Brighton, Crawley and Eastbourne. MW said that he is looking at pension seminars and can ask attendees to bring in their annual benefit statements. CH said that a representative from the board can come along to the Superintendents Association to have the biggest cohort in the force.

5.         Risk Register (JL)

  • To review and update the Pension Board risk register

Cyber risks have been added onto the risk register and there is more work to be done around this. The red risks are around data being complete and accurate; the data scoring project with Equiniti is ongoing and so is the interface report out of the payroll system. The current payroll interface is not working how it should; the data needs to be extracted out of the payroll system SAP which is not easy to do. The new payroll system and Equip will hopefully be live in February 2020. DS said that the member web services should be showing as red and not green.

GB felt that the descriptions of risk should be more than one liners because it is unclear what the risk actually is. Some of the items listed are risks but some are control measures. There needs to be some improvements made to the risk register but it is far easier to read than before. IMc said that anything on the risk register showing as red should be reported to the strategic risk register. GB queried the role of the risk register because there is an organisational risk or whether this is solely for the pension board. IMc explained that the purpose of the risk register is to review the risks and demonstrate what we are doing as a pension board.

Action - GB to send his thoughts on the risk register to JL to update for the next board meeting

  1. Breaches Log (JL)

  • Review any breaches during the quarter

Nothing to add on there and there are no new breaches to report. Some of the breaches are 3 years old and should be kept on for the year of reporting but if they are dealt with they can archived after the year.

7.         Ill Health Retirement & Injury Award Update / Injury Award Reviews

LM was unable to make this meeting but she will be attending the next board meeting to explain the Ill Health Retirement Process.

Sussex Police Pension Board MINUTES

Thursday 16th May 2019

Meeting Room 1, Malling House, Police HQ Lewes

Attendee

Role

Attendance

Board Members

 

 

Iain McCulloch (IMc)

Chair - Chief Financial Officer, PCC

Present

Matt Webb (MW)

Member Representative - Police Federation (Deputy Chair)

Apologies

Daisanne Summersfield (DS)

Employer Representative - Head of Shared Business Services

Present

Graham Bradley (GB)

Member Representative - North Sussex NARPO

Present

Peter Gillett (PG)

Employer Representative – Exec Director Finance Commercial Services

Present

D/Supt Carwyn Hughes (CH)

Member Representative - Superintendents Association

Apologies

Board Advisers

 

 

Ben Read (BR)

Equiniti - Service Manager

Present

Joanna Langley (JL)

Surrey Police – Finance Technical Lead

Apologies

Kelly Ellison (KE)

Sussex Police – Pensions Officer

Present

Minutes

Holly Muggeridge / Dani Glenister

Present

 

Part 1 - Open Session

  1. Welcome

Introductions were provided as above; apologies were received from MW and CH, and also from Louise Monk and Marcus Potter who would attend the next board meeting in August. IM confirmed that today’s meeting was not quorate, however, as there were no decisions to be made by the Board that the meeting would proceed. IM asked Board Members whether there were any conflicts of interest to declare. It was confirmed there were no items to declare.

IM advised that there is one Board vacancy for an Employer Representative. PG advised he will speak to ACC Dave Miller to see whether he can sit on both boards (Sussex & Surrey).

2.   Pension Administrator (Equiniti)

Quarterly Performance & Reporting Update -

It was stated during this quarter, a total of 1,192 transactions were received, with only 6 items completed outside the targeted Service Level Agreement (SLA). All pension and lump sum payments were made on time within the SLA.

Following the Annual Benefit Statements (ABS) being issued in December, Equiniti received 137 queries up to 31st March 2019, which is a relatively low number of queries. All these queries have been resolved.

ACTION: DS raised the 504 general enquiry items on page 6 and whether it was possible to have a breakdown of what these were and, if there were any particular themes, we could focus on these to minimise certain enquiries.

Abandoned calls: BR advised that it is difficult to categorise abandoned calls – the average waiting time is a more useful way to measure where improvements can be made to the call turnaround time. Previously the Team Leader had a manager wait screen so they could keep any eye on call wait times but this facility is no longer available in Crawley - EQ are trying to get this facility working again.

ACTION: DS asked whether the high call volume days relate to the abandoned calls and whether this could be checked.

IMc raised why there were no new member starts during the period – BR advised this is due to the interface which updates any new starters.

Complaint

Equiniti received a complaint during the quarter. There was an error to estimate pension figures which did not take into account the Officers rank on retirement. One of the contributing factors is that EQ had not been provided with ranks of police officers during the transition, which is something that should be held on the record as there are different rules with retirement for different ranks of officers. Equiniti now have all of the ranks from Sussex to stop this issue from happening again. Compensation has been offered and the officer has made a formal complaint through the pension’s ombudsmen. DS has asked if Equiniti could look at this case again as the file she read showed that there was some financial hardship on this. BR will put the views forward. Ranks are not part of the common data model, they are scheme specific. Awaiting the outcome from the ombudsmen. CC Giles York is aware.

Membership

IMc was interested in whether members were opting out of the pension within the Movement table. BR advised if there has been any members who have Opted Out during the period, these would be included on page 13.  There has been none in this quarter.

GB asked if the retirements include ill health retirements and BR confirmed that those numbers do. DS advised it would be good to include because then could do some budget projections and trends on this.

ACTION: BR will feed this back to the team and include a split between standard retirement and ill health retirement, as well as including any opt outs.

BR advised that Equiniti have a record of if any member who have joined the scheme and opted out but not from those who have opted out from the beginning.

ACTION: KE to gather data for those who have opted out of this pension from day one and let Equiniti know.

The membership has been broken down into two schemes but last year it showed as three schemes.

ACTION: BR to have a breakdown of the two schemes to be completed by the end of March to be consistent for the financial year. It goes into the annual report for the Chief Constable. To provide a comprehensive breakdown on where we are at with the membership and a look forward.

Part 2

  • Minutes and Actions from the Previous Meeting

The minutes and actions from the meeting held in January 2019 were reviewed and agreed. Please refer to the separate action log for full updates.

2.2          Board Member Training

DS & IMc have completed training. KE has updated the table.

ACTION: KE to remind any board members who have outstanding training to get it done ASAP.

2.3  Annual Report

IMc would like to set out a draft report based on what we did last year and allocate it out to each member to add some points and tables into it. Could either invite CC York to the August meeting or meet with him separately.

ACTION: KE to check if CC Giles York is able to attend the August board meeting. If not then to arrange an hour meeting with him.

ACTION: IMc to prep the template for the 2019 report and circulate to all board members.

2.5  Work Plan

No change from last time. It was discussed how this information could be better represented and it was demonstrated from Governance Event, the use of a pie chart to show annual events. It was thought maybe going forward we could adopt this style so it is clearer for each quarter.

The national dash board and the cloud, cyber risk and the portal will be added to the Work Plan.

ACTION: KE – add additional items to the Work Plan. ACTION: IMc – a work plan for the board is also required.

2.6          Risk Register

KE ran through the register and the updates that have been made. The Board concentrated on the risk items in red.

The quarterly report – JL has been looking at this and has updated the status. This will be reviewed again in August. It has already been to Equiniti.

ACTION – KE to put in a new section in data security and IT

One more meeting before some of these risks go onto the force risk register for the ORB meeting. PG can send it to David Tonkin.

2.7          Breaches Log

There has been one breach this quarter.

The breach occurred when the address report for the Annual Benefit Statements, which was run from SAP to update EQ with current addresses, used the incorrect date criteria. This resulted in the current address for some members not being picked up and their old address was reported instead.

174 Officers were affected by this error and 4 of these contacted Sussex Police to advise they hadn't received a statement. The members were ensured the addresses were updated correctly and new ABS's sent out to those affected. Additional checks to be made in future reports from SAP to ensure correct information. This has been reported to the Pensions Regulator. No response back from TPR and there is now a process in plan to avoid this happening again in the future.

ACTION: KE to update breaches log with previous breaches ready for the annual report.

DS confirmed that JL will have a record of all previous breaches to add to the Breaches Log. IMc confirmed that not all breaches need to be reported to TPR and we have a policy here.

2.8          Publishing Pension Scheme Information

GB Raised some concerns regarding our legal requirement to publish information about the Pension Board. In as much as the Scheme Manager must publish information about the Pension Board which must be kept up to date. The information must include who the members of the board are, their representation on the board together and matters falling within the pension board’s responsibility. According to the TPR the scheme should also publish useful related information about the Board such as:

  • the employment and job title (where relevant) and any other relevant position held by each board member
  • the pension board appointment process
  • who each pension board member represents
  • the full terms of reference for the pension board, including details of how it will operate, and
  • any specific roles and responsibilities of individual pension board

The Board should also consider publishing information about the Pension Board business such as:

  • Board papers
  • Agendas
  • Minutes of meetings (redacted where legally necessary)

The scheme manager must ensure that published data is kept up to date and have in place policies and processes to monitor all published data on an ongoing basis to ensure it is accurate and complete.

Historically this information was held on the Sussex Police Internet website on it’s own web page however, since the new website has been introduced it no longer appears on the site and some information can only be found by using the onsite search tool.

This means that the Sussex scheme could be in breach of their legal requirements and guidance provided by the TPR in respect of publishing information about the scheme.

GB proposed that the Pensions Board, on behalf of the Scheme Manager, seek to ensure that the required and recommended information in relation to the pension board is correctly and adequately published.

GB went on to propose that the Board agree the best method of publication and that an action is included in the Pension Board Workplan to ensure that the published information is both accurate and maintained on an ongoing basis.

Finally GB proposed that details of the scheme internal dispute resolution policy and procedure should be included in the published information.

ACTION: KE to speak to Kevin Courtney regarding what we can do with the website and what other forces are publishing.

ACTION: PG to raise this compliance issue with Joe Langford.

ACTION: The internal Intranet is to be updated with information on the Pensions Board (KE).

2.9          Sussex NARPO Branches Recruitment Letter

The Sussex NARPO Branches Recruitment Letter has been circulated.

GB reminded the Board that this item was first raised at the January Pension Board earlier this year. Concerns were raised at the Board meeting that there might be some privacy implications under GDPR and the Data Protection Act. It was agreed that DS would take an action to investigate this and submit a paper to the Board.

GB submitted full details of the proposal to DS setting out the specific requirements, the fact that the costs would be met by NARPO and a summary of the Information Commissioners guidance in these instances. As the communication going out to the non-NARPO members was a paper letter then specific consent to use their data in this way was not required and provided it could be shown that there was a legitimate interest then there would be no GDPR implications. DS consulted with the Sussex Police Information Manager who was satisfied that there was a legitimate interest and therefore approval was given to proceed.

Equiniti have since confirmed on the 15 May 2019 that the address data has been extracted, merged, and the proofs signed off. The letters are now with their external printers and it is expected that they will be sent out within the next 10 working days (if not sooner).

GB asked that the outstanding action against DS be closed.

2.10       GMP Training

-      Update on training held on 4 March 2019

Training presentation document has been circulated to the Board.

2.11       Data: Pensions in a digital era – 3 April 2019 event (GB)

Feedback on Event

GB presented his backing paper entitled ‘Data: Pensions in a digital era”. He summarised its content which outlined the event by the same title held at the LGA Offices in London on the 3 April 2019.

2.12       Police Pension Board Advisory Board Joint Governance Event – 15 May 2019

Feedback on Event

DS, PG, IMc and KE went and as well as some members from the Surrey Pension Board. IMc circulated notes taken at the event to the board.

The full meeting agenda and presentations can be found at the following link: https://www.local.gov.uk/firefighters-and-police-local-pension-boards-governance- conference-15-may-2019

Consideration and Discussion of Actions in Advance of Next Meeting Consideration to spilt up the agenda next time for the two advisors that will be attending. Anything for information should be added as a separate part of the agenda.

AOB

Pension Payment Advice Slips – Provision of Information (GB)

GB informed the Board regarding the absence of information contained in the pension payment advice slips which was previously available to scheme members prior to the commencement of the new pension administration arrangements with Equiniti.

The concerns related to a lack specific ‘GMP' information, the obscurity of the 'voluntary deductions’ and the lack of detail regarding ‘CPI related pension increases.

ACTION: Equiniti to give the members as much info as we can to provide a bit more clarity. DS will check the contract. To be taken offline.

Date of Next Meeting – Thursday 8 August.

Sussex Police Pension Board Minutes

31st  January 2019, 10.00am

Meeting Room 1, Malling House, Police HQ Lewes

ATTENDANCE DETAILS

Attendee

Role

Attendance

Board Members

 

 

Iain McCulloch (IM)

Chair

Present

Matt Webb (MW)

Member Representative - Police Federation (Deputy Chair)

Present

Daisanne Summersfield (DS)

Employer Representative

Present

D/Supt Carwyn Hughes (CH)

Member Representative - Superintendents Association

Present

Graham Bradley (GB)

Member Representative - North Sussex NARPO

Present

Peter Gillett (PG)

Exec Director Finance Commercial Services

Present

Board Advisers

 

 

Jo Guy (JG)

Advisor - Finance Technical Lead Surry Police

Present

Ben Read (BR)

Equiniti - Service Manager

Present

Kelly Ellison (KE)

Pensions Officer

Present

Guest Kevin Courtney

NPCC Pensions Advisor

Present

Minutes

Emma Chapman

Present

 

Part 1 - Open Session

  1. Welcome

Introductions were provided as above, there were no apologies. IM confirmed that today’s meeting is quorate. Thanks was extended to Kevin Courtney for joining the meeting today on behalf of the NPCC. IM also welcomed Pete Gillett to the meeting, who has now been appointed as a formal board member. Kelly Ellison was also welcomed, who has been appointed as the boards new pension’s officer.

IM asked Board Members whether there were any conflicts of interest to declare. It was confirmed there were no items to declare.

2.               Pension Administrator (Equiniti)

Quarterly Performance & Reporting Update -

BR provided an update for the period 1st  October to 31st  December 2018. It was reported the transition process has gone well and the inherited backlogs have all been cleared. There are now only a small amount of queries outstanding and it is hoped to have these resolved by the end of this week.

It was clarified that abandoned calls are where the caller has terminated the call before the ops team have answered the call.

Action: It was agreed further analysis would be provided which categorises abandoned calls. This will include information relating to the external influences effecting call rates.

All agreed the new style of reports and level of data being provided is a positive move forward and to have an Equiniti representative present at meetings is helpful. Feedback from members with regards to the new service has also been very positive.

Scheme Movement Data -

Concerns were raised that data is not reflective of those actually coming in to the scheme and those leaving. It was confirmed JG receives more detailed reports and that the reports the board are provided with are redacted versions. Discussion took place regarding how this can be developed for use by the board and how this can be given more context without divulging personal information.

Action: Work will take place regarding how data is presented of scheme movement on a rolling monthly basis. i.e. new entrants and individuals opting out. This will ensure information is linked in with recruitment and L&D.

Action: Annual allowance/pension savings statement information will be included within future reports provided.

Decision: Proactive communications will be provided to make members aware that there could be delays due to the transition over to a new provider.

Pension Estimation Dates -

Discussion followed with regards to pension estimation dates and it was confirmed there can be flexibility around this - the standard is two per year on specified dates. Ill health estimates can also be provided if the request has been approved through the correct channels. Annual allowance queries are treated as general enquiries. A breakdown of benefit statement data will be provided on the next quarterly report published.

Deferred Pensions -

It was confirmed individuals with deferred pensions and those approaching 60 will be contacted automatically, providing Equiniti hold the correct contact details. This is still something that needs to be reinforced to individuals regarding the importance of updating personal data.

Internal Data Controls -

It was confirmed internal control requirements around data was considered during the procurement process and that Equiniti have provided the required certification.

Action: DS agreed to share this information again to reiterate controls and security requirements.

Equiniti Administration Centre -

An update was provided with regards to the head office moves from London to Crawley. The move has provided more resilience to the team and teams can be flexible to provide support where it is most needed. Extensive training has taken place for all staff to ensure they are familiar with the police pension schemes. A comms plan will be developed to ensure members are aware of the new address details for Equiniti.

Member Web Service Portal -

The planned delivery date for the 28th February 2019 has unfortunately been deferred to later on this year. This is due to a number of security issues and also internal issues at Equiniti with regards to the design and rollout. The issues are due to the security levels required by police. Equiniti are therefore trying to build one solution which can cover all police forces. It is hoped the revised date can be negotiated and brought forward. Security conversations are being progressed and a written proposal has been drafted to determine if this can be achieved. DS has raised concerns over the delays, which have been an ongoing issue for 3 years. It is believed having the portal will alleviate a lot of the issues we are currently discussing, it is therefore vital this is resolved and given priority to reduce demand.

Scheme member participation once the portal becomes available will be key and therefore an understanding of both the implementation and communication plans would be helpful.

Action: A copy of the implementation/comms plan will be provided to the board in relation to the Member Web Services Portal.

Action: IM agreed to provide something in writing outlining requirements and non compliance/out of contract due to significant delays. BR will provide details of who to write to.

Action: Work on promoting benefits of the scheme will be considered - Possible vlog.

Sussex NARPO Branches Recruitment Letter –

GB raised the subject of an initiative being backed and financed by NARPO HQ involving the London NARPO Branch to send out a letter to all the Metropolitan Police Pensioners who are not members of NARPO setting out the benefits and inviting them to join. GB went on to say that the Sussex NARPO Branches were keen to follow a similar initiative.

During the subsequent discussion at the meeting MW raised some potential concerns as to whether this might be construed as 3rd Party Supplier marketing and whether there might be some GDPR issues that would need to be considered. DS agreed to take an action to make some internal enquiries and produce a paper for the Board. She also added that the Board may need to consider any implications, associated costs and where ownership of the initiative would sit.

BR also agreed to take an informal action to make enquiries with the team working with London NARPO initiative to ascertain whether there were any GDPR issues and feedback.

Action: DS to undertake internal enquiries with the Sussex Police Information Manager and provide a paper for the Board regarding the GDPR and Data Protection guidance.

  1. Minutes and Actions from the Previous Meeting

The minutes and actions from the meeting held on 5th September 2018 were reviewed and agreed. Please refer to the separate action log for full updates.

MW provided an update from a previous discussion at the last meeting which related to a case and issues of the reinstatement of a widow’s pension. It was noted that this has now been resolved and the individual concerned extended thanks with regards to how this was dealt with.

4.              Pensions Workloads and Scheme Advisory Board

Kevin Courtney attend the meeting to provide a summary on behalf of the NPCC Pensions Advisory Board.

Work has taken place to review the pensions dashboards. Proposals relating to the dashboard were detailed in the paper circulated prior to the meeting. It has been agreed to add annual benefit statement data, which will be rolled out scheme by scheme depending on scheme size - we are somewhere in the middle.

Decisions with regards to when deferred information will be incorporated are still awaited. It was confirmed this will not create problems for the web services portal as it is a separate issue.

The Home Office are going to start collating opt out data nationally, in an attempt to streamline the way this is done via a workforce census. It is yet to be confirmed exactly what information this will request.

The Workforce Transformation Programme will not be considering pensions. Pension and tax issues with regards to promotion remains ongoing and a questionnaire has been circulated.

A House of Commons Statement regarding pension arrangements was circulated, which confirmed the improvement in accrual rates will not be adopted for the time being, but employer contribution rates will be reviewed and changed to 31%. Confirmation regarding whether the Government will be able to appeal the judgement made regarding firefighters is still awaited.

Action: Forces are requested to check internal websites, to ensure links to the TPR website is still accessible and current.

Details were also discussed in relation to the High Court ruling on GMP equalisation, which states that that schemes must equalise the discriminatory effects of GMPs and that this can be achieved using various methods. Concerns have been raised relating to this, but it has been confirmed this will not impact current methods used to achieve equalisation and indexation in public service pension schemes.

Other updates included:

- The announcement made last year, for civil partnerships to be extended to opposite sex couples.

5.               Board Member Training

Board member training was discussed. It was confirmed JG has now sent EC the training template so that a record can be kept centrally for all member training completed. All were reminded to forward any details to EC. A reminder was also provided to sign up to the TPR public service training toolkit.

6.               Pension Scheme - Regularity and Compliance

Details of actions and updates of progress were provided, as a result of the Local Government event attended by IM.

Action: JG agreed to add dates to the actions coming out of the Local Government event.

Updates were provided detailed in a report relating to the Annual Allowance and Scheme Pays, plus the Brewster Judgement and Walker Judgement. MW stated the Fed are awaiting further updates and receipt of legal advice as to whether our position changes and whether this will be challenged.

A Privacy Notice was circulated, outlining what personal information is held on members and how it is used.

Action: It was agreed Marcus Potter would be contacted with regards to seeking any legal advice surrounding this.

  1. Work Plan

The work plan was circulated for information, which outlined tasks for the forthcoming year. This was noted.

8.               Risk Register

The register was circulated, which has been broken down into 4 key risk areas - operations, financial, funding and regulatory/compliance.

Discussion took place regarding a possible new risk around dissatisfaction of information on annual benefits. It was agreed to ensure this does not escalate into any formal complaints, the board will monitor this.

Action: Monitoring risks will be kept on the agenda as a standing item and a direction of travel will be added to illustrate whether risk levels are changing. Agreed the board will only review red and amber risks going forward.

Decision: Agreed incorporating additional information regarding annual allowances would address this in part, but that this issue would be kept as a standing agenda item to ensure the board are formally monitoring.

Decision: Consideration will be given to introducing an issues register, to ensure a record is kept of key issues discussed.

BR highlighted that anomalies had been found by Equiniti with Capitas data, but that this was being addressed. Equiniti work closely with payroll and proactively query records which appear to have inaccuracies in order to mitigate this.

9.               Breaches

A paper was circulated outlining the process for reporting breaches. It was confirmed there had been no breaches in the last quarter.

10.                 GMP Reconciliation

Reports were shared on the Sussex Police Authority Scheme and the new Police Pension Scheme 2006, which detailed progress of stage 2 actions and decision cases.

Decision: A request was made for recommendations detailed in the reports on proposed action is reviewed. If the recommendations are agreed, those cases requiring further investigation will be separated from the majority to allow cases that have been reconciled to progress to the final stages.

The next steps are to develop an understanding of how this will be managed due to the transfer over to Equiniti. Until a formal handover takes place from Capita it is difficult to assess what implications this will have. Once this has taken place it will be key to ensure consideration is being given to providing those effected information on any action which might be required on their part.

KC stated there is currently no national approach in place to dictate how this is actioned by forces. All stated it would be useful to have more detail and guidance regarding over and under payments and how this will be addressed. DS confirmed once this phase has concluded our position will be clearer.

Action: GMP reconciliation will be added to the risk log. A joint board initiative will be developed regarding GMP and consideration also given to running a training session.

  1. Consideration and Discussion of Actions in Advance of the Next Meeting

No actions were raised.

12.            AOB

Discussion took place in relation to the forces position regarding the discretionary decision of the N.Ireland ruling / 87 Scheme issue, which was discussed at May’s meeting last year. It was confirmed this surrounds nomination of beneficiaries and stated this is now going through all schemes but does not apply to the 87 Scheme. Forces will have no authority or influence over this.

Action: A message surrounding the 87 Scheme decision will be incorporated into the comms which will go to pensioners in April. There is currently no formal wording for this and KC agreed to provide details once available.

  1. Next Meeting - Date to be arranged.

Sussex Police Pension Board MINUTES

31st  May 2018 at 10.00am

Meeting Room 1, Malling House, Police HQ Lewes

ATTENDANCE DETAILS

Attendee

Role

Attendance

Board Members

   

Iain McCulloch (IM)

Chair

Present

Matt Webb (MW)

Member Representative - Police Federation (Deputy Chair)

Present

Bill Davis (BD)

Employer Representative

Dialling In

Daisanne Summersfield (DS)

Employer Representative

Present

D/Supt Carwyn Hughes (CH)

Member Representative - Superintendents Association

Present

Graham Bradley (GB)

Member Representative - North Sussex NARPO

Present

Board Advisers

   

Jo Guy (JG)

Advisor - Finance Technical Lead Surry Police

Present

Peter Gillett (PG)

Advisor - CFO Sussex Police

Present

Paul James (PJ)

Advisor - Pensions (CAPITA)

Apologies

Clare Chambers (CC)

Advisor - Pensions (CAPITA)

Apologies

Terry Langworthy (TL)

Advisor - Pensions WSCC

Apologies

Tara Atkins (TA)

Advisor - Pensions WSCC

Apologies

Dave Byles (DB)

Pensions WSCC

Dialling In

Minutes

Emma Chapman

 

 

Part 1 - Open Session

  1. WELCOME

IMc confirmed that today’s meeting is quorate. Introductions and apologies were provided as detailed on page 1. It was reported Clare Chambers has now resigned from the organisation. Concerns were raised regarding her departure and a request has been made for a report providing reassurance with regards to plans in the interim. IMc agreed to make contact with Katherine Eberhart to highlight the Boards concerns.

IMc asked Board Members whether there were any conflicts of interest to declare. It was confirmed there were no items to declare.

2.    PENSION ADMINISTRATION REPORT - CAPITA

Reports were provided summarising activity and performance, detailing caseloads, membership movement and transition dates. There are a number of actions arising from the reports submitted to the previous meeting, which also need re-visiting and therefore remain outstanding. Concerns were raised over lateness in circulation of information, which DS agreed to highlight with TA.

The main focus of work is ensuring the data transfer and associated queries runs smoothly, as well as business as usual. Regular project meetings are in place to monitor and oversee this process.

It was stated LGPS are looking to relocate to Hampshire, for a new supplier. It was unclear as to who the prospective supplier would be, but word of caution was given regarding H3 due to issues raised regarding general service delivery provided. All agreed formal discussions are required surrounding 3rd party implications and what our requirements are from LGPS. This is because although the service is outsourced, it still continues to remain responsibility of the board manager.

Police GMP Data -

Concerns were raised due to lack of detail around categories and it was agreed the board requires a better understanding of where we are with GMP. It was stated this information has been requested on a number of occasions which has not been provided, highlighting yet another example of poor service delivery by CAPITA. This could have many implications and impact upon how benefits are paid further down the line.

GB will be providing a paper explaining more about the GMP to ensure individuals are knowledgeable and able to self-check information ensuring they are receiving the correct increases, as there is currently lack of information available. The paper will not be to advise, but just to sign post and will be purely factual.

Action: It was agreed a report would be requested from Simon Gray at CAPITA, which provides more detail behind the figures below. This is to be provided within the next week. An extraordinary meeting will then be arranged once this is received to discuss.

Action: GB will also share a copy of the report he is preparing surrounding GMP for agreement from the Board before final circulation.

Part 2 - Closed Session

  1. MINUTES/ACTIONS FROM PREVIOUS MEETING

The minutes and actions from the meeting held on 1st February 2018 were reviewed and agreed. Please refer to the separate action log for full updates.

4.    BOARD MEMBER TRAINING

Board member training was discussed.

Action: JG will forward a copy of the training log so that EC can keep a central record of all board member training.

Action: It was also agreed GDPR training available on the website for completion by members should be added to the log, including details of the half day training session held for board members on 5th April.

Action: BD referred to training which has taken place for Surrey Pension Board and agreed to forward details, which will also be included on the log.

5.   PENSION SCHEME - REGULATORY AND COMPLIANCE REPORT

The above report was circulated to Board members. JG summarised key points within the report.

6.    PENSIONS TRANSFER PROJECT

DS provided a summary to the Board of progress made to date, surrounding preparations for the transfer over to Equiniti. It has presented some challenges and has made a significant impact on resourcing. Maintaining relationships has been and will continue to be key during this period. Progress has been positive and the project remains on track.

The first data transfer has taken place. DS is in progress of negotiating the contract start date for July 1st - for the payroll run element, although we need to remain mindful there will be an interim period whilst the shut down and handover process takes place. Contingency plans have been developed around this.

Action: Possible risks around meeting payroll deadlines for July should be added to the risk register.

Comms have been circulated internally, although GB expressed disappointment due to NARPO not circulating any of the advice he had provided to members. It was agreed this is difficult to mitigate as we are not always sighted, to enable us to be sure the relevant information is communicated in the right way. It was suggested it could be worthwhile testing on a selection of members.

Action: Further consideration will be given and comms will be drafted in order to provide reassurance and to address expectations. We need to be realistic with the timescales given.

Annual Benefit Statements -

Discussion took place regarding the delays faced with publishing this years statements. The Board agreed they would be willing to accept delay in publishing annual benefits, if it means things are delivered correctly and as accurately as possible - taking into account previous errors made by WSCC. We will strive for a date at the end of October, bearing in mind other competing demands such as the annual allowance.

Decision: The Board agreed to option 3, subject to consultation with TPR. Which would involve WSCC/Capita proving the EOY data and the calculations for the CARE scheme to assist Equiniti with the reconciliation process, using their own templates. It is accepted this does carry some risks for members as they will not get an ABS statement by 31st August, but with specific comms which Equiniti will help to draft, this should alleviate immediate concerns. A new deadline would therefore be proposed for 31st December. DS will follow this up outside of the meeting and provide an update on outcomes following further discussions.

Action: A formal letter will be sent to CAPITA once the contract has concluded to obtain confirmation that they are no longer in possession of any data. Although there may still remain some data which has not been reconciled - by exception. An interim and final check will be made to provide reassurance.

7.    WORK PLAN

A summary was provided of work planned over the next 12 month period. As previously discussed, the main bulk of work has been dedicated to the preparation of the pensions transfer.

It was confirmed an update has been provided by the Home Office since preparing the initial work plan, advising that commutation will be withdrawn, as there is no business case to provide funding.

8.   RISK REGISTER

The register was circulated. ABS currently presents the main risk, which will continue to be reviewed. Combine with issues to manage and provided better oversight??

9.   LOCAL PENSION BOARD GOVERNANCE EVENT

Notes and actions emerging from the above were circulated, which took place on 9th May. Actions emerging have been highlighted with JG to progress on behalf of the Board.

IMc stated the event was well represented and the topics covered reinforce that we have good processes in place as a force, with regular meetings and TOR in place. Another key item covered related to Cyber threats which has a key link with GDPR.

It was agreed once Equiniti have formally taken over the contract, further consideration will be given to combine Surrey and Sussex Boards. This will be re-visited in the Spring to allow time for the transfer to take effect and business as usual to return to normal. Discussion also took place to explore appointing a pensions expert as an independent member to chair future meetings.

Action: EC to transfer pensions governance event actions over to the Boards main action log.

10.                   ANNUAL REPORT

Discussions took place with regards to preparation and planning for publication of the up and coming annual report. The report for the previous year was also circulated as a point of reference. The CC is attending September’s meeting and all agreed it would be good to be

in a position to have the report finalised for that meeting. IMc stated he is keen to open up this year’s report for wider contribution by Board members and welcomed any input.

Action: IMc will use last year’s annual report template as a basis for this year’s report, which will be circulated for input and feedback from Board Members. This will be reviewed at the planning meeting on 16th August.

Action: EC to review records for accuracy of board member attendance to meetings throughout the year.

11.  PENSION BOARD FOCUS GROUP

Details were provided from the internal focus group which took place on 5th April. TOR was updated and re-circulated following discussion at that focus group. It was highlighted the majority of information remains unchanged with exception to appendix A - which outlines the functions of the Board. A section will also be added detailing requirements and standards of monitoring reports provided by Equiniti going forward.

Action: The TOR was agreed today and will be included in the new annual report for final agreement and sign off by the CC at the meeting in September.

Action: JG to transfer actions from the Focus Group to the Boards main action log.

12.                   GDPR

Include content here from GBs email

13.  CONSIDERATION OF ACTIONS IN ADVANCE TO NEXT MEETING

Discussion took place regarding proposed items in advance to the next meeting. The main action log will incorporate all new actions agreed at today’s meeting.

14.                   SUSSEX NARPO BRANCHES

GB outlined for the Board the existing working relationships between the Sussex NARPO Branch Secretaries and Capita, which essentially consists of two key areas.

Firstly, supporting the collection of NARPO subscriptions in the February of each year collected direct from the pension payments from those members in receipt of Sussex Police Pensions, together with the provision of a follow up report used for reconciliation purposes by the Branch Secretaries.

Secondly, the provision of a point of contact with the Capita/WSCC Pension Team for ad hoc queries on behalf of the Branch or occasionally individual Branch Members.

On the first point, each Branch seem to operate slightly different processes in their relationship with Capita and the collection of subscriptions. On the second point the relationship with two points of contact in Capita appeared to become informal and rely very much upon the goodwill of the Capita staff who were formally WSCC employees before being TUPE’d over to Capita.

Enquiries with the Surrey NARPO Branch Secretary revealed that this working relationship with Equiniti whilst very good, the subscription collection processes has been through some iterations and is still subject of development into a final workable solution.

GB recently met with all the Sussex Branch Secretaries and the respective Chairs at one of their regular joint meetings. It was agreed that GB should become a member of that meeting, as link between the Pensions Board and retired member feedback and also take the lead on progressing the future working relationships between the Sussex NARPO Branches and Equiniti.

Given that the Surrey Pension scheme is also being, and will continue to be, administered by Equiniti, GB put forward a proposal that a joint meeting of both Sussex and Surrey NARPO Branch Secretaries together with Equiniti should take place following the transition, possibly in September or early October, to map out and agree the working relationship processes going forward.

Action: The Board members supported this proposal and JG took the action to progress the meeting arrangements.

15.                   AOB

MW raised the matter surrounding the treatment of temporary salaried officers and the issue of salaries being made pensionable.

This has been having an impact regarding correct contributions. Work has been ongoing to rectify the problems which currently sits with payroll, who are trying to identify and reconcile. We are still unclear as to the extent of the problem and it was flagged there could be some duplication of numbers. It is estimated there are around 3,637 cases, which could date back to February 2012. It was suggested DS may have better oversight of this matter as the payroll function sits under her portfolio as Head of SBS.

Action: IMc to seek a formal update on reassurance and status of this issue, which has been ongoing for a long period of time. This will be re-visited as a possible agenda item for September’s meeting. This will also be placed on the risk register.

87 Scheme -

MW provided brief details of a case which has been brought to his attention, involving anomaly over payments to spouse (survivor’s pension). Consideration is being given to overall legislation and possible changes in order to bring more in line with other existing schemes as current rules are very archaic.

MW stated that the purpose of bringing to the Board today was to discuss current arrangements and agree how the particular case he is currently dealing with is responded to. It is generally the appointed scheme manager who makes a decision on cases, which in this force sits with the CC. The CC has therefore requested recommendations from the Board to facilitate his decision. Although it is accepted these cases are few and far between.

All agreed the Board requires more information in order to gauge how many this could apply to and whether there may be further financial implications.

Action: A decision could not be reached today and it was agreed MW would provide further details for formal decision at the next meeting. Consideration is also be given to aligning with Surrey processes.

Next Meeting - 5 September

FULL PRIVACY NOTICE

for the members and beneficiaries of the Sussex Police Pension

This notice is for members of the Sussex Police Pension (the "Scheme"). It has been prepared by The Chief Constable of Sussex (the "Police Pension Authority", or "we") in their capacity as the manager of the Scheme (the "Scheme Manager").

Why we are providing this notice to you

As Scheme Manager we hold certain information about you ("personal data") which we use to administer the Scheme and to pay benefits from it. This notice is designed to give you information about the data we hold about you, how we use it, your rights in relation to it and the safeguards that are in place to protect it.

The technical bit

The Police Pension Authority holds personal data about you in its capacity as data controller for the proper handling of all matters relating to the Scheme, including its administration and management. This includes the need to process your data to contact you, to calculate, secure and pay your benefits, for statistical and financial modelling and for reference purposes (for example, when we assess how much money is needed to provide members' benefits and to inform the Home Office of any additional funding requirements), and to manage liabilities and administer the Scheme generally. Further information about how we use your personal data is provided below.

The legal basis for our use of your personal data will generally be one or more of the following:

  1. we need to process your personal data to satisfy our legal obligations as Scheme Manager; and

  2. we need to process your personal data to carry out a task in the public interest or in the exercise of official authority in our capacity as a public body;

  3. we need to process your personal data for the legitimate interests of administering and managing the Scheme and liabilities under it, calculating, securing and paying benefits and performing our obligations and exercising any rights, duties and discretions the Scheme Manager has in relation to the Scheme.

  4. Where we have no other legal basis we will ask for your consent to process your personal data.

The Scheme Manager has appointed the Sussex Police Pension Board, as detailed in the Pension Board Terms of Reference, to assist in the management and administration of the Scheme.

What personal data we hold, and how we obtain it

The types of personal data we hold and process about you can include:

  • Contact details, including name, address, telephone numbers and email address.

  • Identifying details, including date of birth, national insurance number and employee and membership numbers.

  • Information that is used to calculate and assess eligibility for benefits, for example, length of service or membership and salary information.

  • Financial information relevant to the calculation or payment of benefits, for example, bank account and tax details.

  • Information about your family, dependents or personal circumstances, for example, marital status and information relevant to the distribution and allocation of benefits payable on death.

  • Information about your health, for example, to assess eligibility for Ill Health or Injury on Duty benefits or where your health may be relevant to a claim made by your beneficiary’s following your death.

  • Information about a criminal conviction where this may result in pension forfeiture.

We obtain some of this personal data directly from you. We may also obtain data (for example, salary information) from your current or past employer(s), from a member of the Scheme (where you are or could be a beneficiary of the Scheme as a consequence of that person's membership of the Scheme) and from a variety of other sources including public databases (such as the Register of Births, Deaths and Marriages), our advisers and government or regulatory bodies, including those in the list of organisations that we may share your personal data with set out below.

Where we obtain information concerning certain "special categories" of particularly sensitive data, such as health information, extra protections apply under the data protection legislation. We will only process your personal data falling within one of the special categories with your consent, unless we can lawfully process this data for another reason permitted by that legislation. You have the right to withdraw your consent to the processing at any time by notifying the Police Pension Authority in writing. However, if you do not give consent, or subsequently withdraw it, the Police Pension Authority may not be able to process the relevant information to make decisions based on it, including decisions regarding the payment of your benefits.

Where you have provided us with personal data about other individuals, such as family members, dependants or potential beneficiaries under the Scheme, please ensure that those individuals are aware of the information contained within this notice.

How we will use your personal data

We will use this data to deal with all matters relating to the Scheme, including its administration and management. This can include the processing of your personal data for all or any of the following purposes:

  • to contact you.

  • to assess eligibility for, calculate and provide you (and, if you are a member of the Scheme, your beneficiaries upon your death) with benefits.

  • to identify your potential or actual benefit options and, where relevant, implement those options.

  • for statistical and financial modelling and reference purposes (for example, when we assess how much money is needed to provide members' benefits).

  • to comply with our legal and regulatory obligations as Scheme Manager.

  • to address queries from members and other beneficiaries and to respond to any actual or potential disputes concerning the Scheme.

  • the management of the Scheme's liabilities.

Organisations that we may share your personal data with

From time to time we will share your personal data with advisers and service providers so that they can help us carry out our duties, rights and discretions in relation to the Scheme. Some of those organisations will simply process your personal data on our behalf and in accordance with our instructions. Other organisations will be responsible to you directly for their use of personal data that we share with them. They are referred to as data controllers and we have highlighted them in the table below. The data controllers may be obliged under the data protection legislation to provide you with additional information regarding the personal data that they hold about you and how and why they process that data. Further information may be provided to you in a separate notice or may be obtained from the advisers and service providers direct, for example, via their websites.

These organisations include the Scheme's:

Data processors

 

·         Administrator - (currently Equiniti Paymaster).

·         Tracing bureaus for mortality screening and locating members - (currently Equiniti Paymaster)

·         Overseas payments provider to transmit payments to scheme member with non-UK accounts - (currently Equiniti)

Data controllers

 

·         Legal adviser - (currently Weightmans LLP)

·         External auditor - (currently Ernst & Young LLP)

·         Internal auditor - (currently RSM Risk Assurance Services LLP)

·         Police Medical Appeals Board

·         The Department for Work and Pensions

·         The Government Actuary's Department

·         The Cabinet Office - for the purposes of the National Fraud Initiative

·         HMRC

·         The Courts of England and Wales - for the purpose of processing pension sharing orders on divorce

 

In each case we will only do this to the extent that we consider the information is reasonably required for these purposes.

From time to time, if applicable, we may provide some of your data to your employer and their relevant subsidiaries and advisers for the purposes of enabling your employer to understand its liabilities to the Scheme. Your employer would generally be a controller of the personal data shared with it in those circumstances.

As part of an ill health application or injury on duty award if there is an appeal, we may provide your health information to the Police Medical Appeals Board.

Where requested or if we consider that it is reasonably required, we may also provide your data to government bodies and dispute resolution and law enforcement organisations, including those listed above, the Pensions Regulator, the Pensions Ombudsman and Her Majesty's Revenue and Customs (HMRC). They may then use the data to carry out their functions.

The organisations referred to in the paragraphs above may use the personal data to perform their functions in relation to the Scheme as well as for statistical and financial modelling (such as calculating expected average benefit costs and mortality rates) and planning, business administration and regulatory purposes. They may also pass the data to other third parties, to the extent they consider the information is reasonably required for a legitimate purpose.

In some cases recipients of your personal data may be outside the UK. This means your personal data may be transferred outside the European Economic Area ("EEA") to a jurisdiction that may not offer an equivalent level of protection as is required by EEA countries. If this occurs, we are obliged to verify that appropriate safeguards are implemented with a view to protecting your data in accordance with applicable laws. Please use the contact details below if you want more information about the safeguards that are currently in place.

We do not use your personal data for marketing purposes and will not share this data with anyone for the purpose of marketing to you or any other member.

How long we keep your personal data

We will only keep your personal data for as long as we need to in order to fulfil the purpose(s) for which it was collected and for so long afterwards as we consider may be required to deal with any questions or complaints that we may receive about our administration of the Scheme, unless we elect to retain your data for a longer period to comply with our legal and regulatory obligations. In practice, this means that your personal data will be retained for such period as you (or any beneficiary who receives benefits after your death) are entitled to benefits from the Scheme and for a period of 15 years after those benefits stop being paid. For the same reason, your personal data may also need to be retained where you have received a transfer, or refund, from the Scheme in respect of your benefit entitlement.

Your rights

You have a right to access and obtain a copy of the personal data that the Police Pension Authority holds about you and to ask the Police Pension Authority to correct your personal data if there are any errors or it is out of date or incomplete. In certain circumstances you have the right to object to the processing of your personal data; for example you have the right to object to processing of your personal data which is based on the legitimate interests identified in the section above headed "The Technical Bit", or where the processing is for direct marketing purposes. In some cases you may also have a right to ask the Police Pension Authority to restrict the processing of your personal data until any errors are corrected or to transfer or (in very limited circumstances) erase your personal data. You can obtain further information about these rights from the Information Commissioner's Office at: www.ico.org.uk or via its telephone helpline (0303 123 1113).

If you wish to exercise any of these rights or have any queries or concerns regarding the processing of your personal data, please contact the Administrator as indicated below. You also have the right to lodge a complaint in relation to this privacy notice or the Police Pension Authority's processing activities with the Information Commissioner's Office which you can do through the website above or their telephone helpline.

As explained in the section above headed "How we will use your personal data", one of the reasons we collect and hold your personal data is to administer your Scheme benefits. If you do not provide the information we request, or ask that the personal data we already hold is deleted or that the processing of the personal data be restricted, this may affect our ability to administer your benefits, including the payment of benefits from the Scheme. In some cases it could mean the Police Pension Authority is unable to put your pension, or an element of the pension, into payment, or has to stop your pension (if already in payment).

Updates

We may update this notice periodically. Where we do this we will inform members of the changes and the date on which the changes take effect.

This notice was last updated on 17 January 2020.

Contacting us

For queries on benefit payments, annual statements etc., please contact the Administrator, Equiniti Paymaster, for further information.

Email: sussex.police@equiniti.com Tel: 0333 207 5967

Address:

Equiniti

Sutherland House Russell way Crawley

RH10 1UH

You can find a copy of Equiniti’s Privacy Policy here: https://equiniti.com/uk/privacy-policy/

For all other queries, or if you have a complaint about how your information has been collected, how it has been used or how long we keep it for, please contact Joanna Langley, Pensions Lead:

SBSC, PO BOX 101

Guildford Surrey GU1 9PE

Email: pensions@sussex.pnn.police.uk

Data Protection Officer

You may also contact our data protection officer, Marcus Potter, for further information.

Data Protection Officer

Malling House

Sussex Police Headquarters Church Lane

Lewes

East Sussex BN7 2DZ

Email: DPO@sussex.pnn.police.uk

POLICE PENSION BOARD TERMS OF REFERENCE FOR THE POLICE PENSION BOARD FOR SUSSEX

  1. INTRODUCTION

The purpose of this document is to set out the Terms of Reference for the Police Pension Board for Sussex (the Board).

The Board was established on 1 April 2015 by Chief Constable Giles York, as Chief Constable of the Sussex Police (the “Scheme Manager”) according to section 5 of Act and regulation 13 of the 2015 Regulations.

2.   POWERS OF THE POLICE PENSION BOARD

The Board will exercise all its powers and carry out its duties in accordance with the law and these Terms of Reference.

3.   AMENDMENT OF THESE TERMS OF REFERENCE

Subject always to the Act and Regulations, the Board may amend any term of these Terms of Reference where, in its reasonable judgement, such amendment would promote the efficiency and smooth working of the Board.

A Board Member may propose an amendment at any meeting of the Board. The Board Member shall have informed the Chair of his or her proposal and the Chair shall have included the proposal in the meeting agenda and / or papers circulated prior to a meeting of the Board. Such amendment shall be made where a majority of the Board Members present and voting at any meeting are in favour of the proposal.

4.   FUNCTIONS OF THE BOARD

The role of the Pensions Board is, under regulation 13(1) of the Regulations, to assist the Scheme Manager:

To secure compliance with:

  • the Regulations;

  • any other legislation relating to the governance and administration of the Police Pension Scheme (the “Scheme”) (and any statutory pension scheme that is connected with it);

  • any requirements imposed by the Pension Regulator in relation to the Scheme (and any statutory pension scheme that is connected with it); and

In the performance of the Scheme Manager’s functions under the Regulations.

The Scheme Manager considers that “assisting the Scheme Manager” should be interpreted as helping the Scheme Manager in his/her management or administration of the Scheme pursuant to sections 4 and 5 of the Act and the Regulations.

This shall include, but shall not be limited to, doing, in a timely manner, such work and tasks as requested by the Scheme Manager in relation to such aspects of governance and administration of the Scheme as the Scheme Manager determines.

The specific functions of the Board as determined by the Scheme Manager above the Board’s core statutory role are set are as set out in Annex A to these Terms of Reference.

5.   COMPOSITION OF THE PENSION BOARD Membership

The Board shall consist of a minimum of 4 voting members (who must be Employer or Employee Representatives) and maximum of twelve, and be constituted as follows:

  • There shall be a Chair (Independent) and a Deputy Chair (Employee) appointed by the Scheme Manager who also have the power to

  • The Chair shall appoint at least 6 members of the Board and there shall be an equal number of Employer Representatives and Employee Representatives. The Chair may appoint any Independent Member to the

  • Board Members should be able to demonstrate their capacity to attend and complete the necessary preparation for meetings and participate in training as

  • Employee Representatives shall either be scheme members, active or deferred or pensioner or have capacity to represent members of the

Appointment and Removal of Chair and Deputy Chair

The scheme Manager has a responsibility under the Regulations to appoint the Chair and Deputy Chair of the Board for a term not exceeding a period of 3 years.

Where the Scheme Manger does not appoint an independent Chair, the office of Chair must be filled alternately by an Employer Representative and an Employee Representative; and

Where the Chair is an Employer Representative, the Deputy Chair must be an Employee Representative, and vice versa.

If the Chair or the Deputy Chair’s term of office:

  • Terminates by natural expiry, the Scheme Manager may re-appoint the Chair or the Deputy Chair for a further term as set out above; or

  • Terminates for any other reason, the Scheme Manager will appoint another person to replace the outgoing party externally or from the existing membership of the

The Chair will ensure that meetings are properly conducted according to these Terms of Reference and other relevant procedures adopted by the Board and the decision of the Chair on all points of procedure and order shall be final.

The role of the Deputy Chair is to assist the Chair in carrying out their functions and to carry out those functions if the chair is not present.

The Chair or Deputy Chair may delegate any of their functions apart from the responsibility to appoint Board Members.

Appointment and Removal of Board Members

The Chair of the Board shall appoint the Employer Representatives and Employee Representatives, subject to the approval of the Scheme Manager.

The eligibility and selection criteria for selecting Board Members and details as to how Board Members are to be removed are set out in the Police Pension Board Members Appointment and Removal Rules at Annex B.

6.   DECISION MAKING AND ADMINISTRATION Notice of Meetings, Agendas and Minutes

The Chair of the Board will prepare an agenda of the Board prior to each Board meeting.

Notice of meetings should be provided to all Board Members at least 1 month in advance of each meeting. If a Board Member decision is required as a matter of urgency a shorter notice period will be used.

Where a Board Member cannot attend a meeting called urgently, there is a procedure set out in section 8 below for the appointment of substitute attendee.

The Chair may decide to convene a meeting by conference call or other electronic means in accordance with these Terms as set in section 7 of these Terms below.

Board Members will be required to notify the Chair of any agenda items at least 7 working days in advance of the meeting. All agenda items are at the discretion of the Chair.

The agenda and any papers for the Board will be issued at least 5 working days (where practicable) in advance of the meeting except in the case of matters of urgency.

Minutes of each meeting, including all actions and agreements, will be recorded and circulated to all Board Members within 10 working days after the meeting. These minutes will be subject to formal agreement by the Chair taking consideration of comments by Board Members (which may be done electronically between meetings).

The minutes may, at the discretion of the Chair, be edited to exclude items on the grounds that they would involve the likely disclosure of exempt information as required under the Data Protection and Information Security Policy (Part 2), if edited, the finalised minutes shall show redacted extracts.

7.   LOCATION AND TIMING

Subject to the ability of the Board to meet by telephone or by other electronic means as set out below, the Board will normally meet at Police Headquarters, in Lewes, Sussex.

The Board may meet in person, by telephone or by other electronic means, so long as each Board Member can contribute to the business of the meeting.

The Board will meet four times in each calendar year on a three- monthly cycle. The Chair may call or agree to call, additional meetings in exceptional circumstances.

There shall also be ability for the Chair, with the consent of the Board membership and/or the Scheme Manager to require a special meeting to be convened on notice.

8.   QUORUM AND APPOINTMENT OF PROXIES

A meeting of the Board is quorate when:

  • at least 4 Members are present one of whom is the Chair or Deputy Chair and

  • there are an equal number of Employer and Member Representatives present

All Board Members are expected to regularly attend meeting. Records of attendance of all Board Members will be maintained and reported to the Scheme Manager on an annual basis.

Substitute members can be appointed to the Board subject to completion of nomination process and at the discretion of the Chair.

If for any reason a Board Member cannot attend a Board an appointed substitute (as long as they are representing the same group as the Board Member that they are substituting, can attend and vote at the meeting in their place. Such substitution only remains valid for the meetings that the Board Member cannot attend.

9.   VOTING AND DECISION-MAKING

Where all the Board Members are present at the meeting, and a decision is required, the decision will be taken on approval of a majority of Board Members present at the meeting.

Where not all Board Members are present at any given meeting of the Board but the meeting is quorate, unanimous approval of all Board Members present is required.

The Board Members may also make decisions by written resolution signed by all the Board Members. The Chair shall determine this on a case by case basis and shall ensure that all Board Members receive full information to make a proper decision. The Board may exercise this power where it is impracticable to take a decision in a given meeting of the Board.

Each Employer and Employee Representative on the Board has an individual voting right for each matter put to vote.

An Independent Member does not have a voting right unless they are appointed as the Chair or Deputy Chair.

If there is a tied vote on any issue, the Chair has a casting vote.

The results of any voting outcomes will be reported in the Board Minutes.

Creation of Working Groups/Sub-Boards

The Board has the power to set up working groups or sub-boards on whatever terms that the Board reasonably determines.

If the Board decides to create a working group or sub-board than it will prepare terms of reference for each of these sub-committees in a timely way.

10.    BUDGET

The Board will have a budget for the following purposes:

  • Reasonable fees and expenses for Board members;

  • Reasonable legal, technical and other professional advice;

  • Cost of secretarial support;

  • Reasonable accommodation and administrative support to conduct its meetings and other business accommodation costs;

  • Training for members; and

  • Anything else that the Scheme Manager reasonably

The terms of the budget are set out in the Board’s “Budget, Fees and Expenses” document. The amount of the budget shall be as notified to the Board by the Scheme Manager on an annual basis

11.    FEES AND EXPENSES

Fees and expenses of Board Members will be as set out in the Board’s “Budget, Fees and Expenses” Document.

12.    CONFLICTS OF INTEREST

The Board Members shall always act within these Terms of Reference and in accordance with the Board’s “Conflict of Interest Policy”.

Though members of the Board include representatives of specific categories of stakeholder (i.e. scheme members and employers) each Board Member is required to have due regard to the role of the Board as outlined in these Terms of Reference.

Accordingly all members are expected to work jointly with the key purpose of assisting the Scheme Manager in the management or administration of the Scheme, putting aside any individual views they may have in their private capacity or professional role. However, this should not prevent Board Members from sharing their knowledge on how matters might impact specific stakeholders of the scheme.

The Chair of the Board must be satisfied that the Board is acting within:

  • The conflicts of interest requirements of the PSPA and the Regulations; and

  • In the spirit of the Pension Regulator’s Code of Practice no. 14 in relation to conflicts of interest; and

  • In accordance with the Board’s “Conflict of Interest Policy”.

Each Board Member, or a person proposed to be appointed to the Board, (as well as attendees participating in the meeting) must provide the Scheme Manager with such information as he or she is reasonably requires for the purposes of demonstrating that there is no conflict of interest.

13.    ADVICE AND INFORMATION

The Board may appoint professional advisers, or other advisors to advise the Board on such matters that the Board determines. This will be on an ‘as required’ basis. For the avoidance of doubt, any expert adviser is not a Board Member subject to approval by the Scheme Manager.

The process for their appointment and agreeing their fees shall be on terms as the Board determines and are set out in the Fees and Expenses document.

If the Chair appoints an independent individual to the Board, he or she shall support the Board in its role and responsibilities.

The Board should request such information and documents from the Scheme Manager that it requires to carry out its functions. The Scheme Manager will be required to consider positively all reasonable requests in relation to the role of the Board whilst being mindful of value for money. The Scheme Manager shall inform the Board as soon as reasonably possible of his or her decision in relation to any request of the Board and shall carry out anything required of him/her in relation to this as soon as reasonably possible.

14.    KNOWLEDGE AND SKILLS

Under the requirements of the PSPA, a member of the Board must be conversant with:

  • The rules of the Scheme and

  • Any document recording policy about the administration of the Scheme which has been adopted in relation to the

In addition, a Board Member must have knowledge and understanding of:

  • The law relating to pensions; and

  • Any other matters which are prescribed in

The degree of knowledge and understanding referred to above is that appropriate for the purpose of enabling the individual properly to exercise the functions of a member of the Board.

It is for individual Board members to be satisfied that they have the appropriate degree of knowledge and understanding to enable them to properly exercise their functions as a member of the Board and therefore must comply with the Board’s Knowledge and Understanding and Training Policy and participate in such personal training needs analysis or other processes that are put in place in order to ensure that they maintain the required level of knowledge and understanding to carry out their role on the Board.

15.    STANDARDS OF CONDUCT

The “Code of Conduct” shall apply in relation to the standards of conduct of Board Members.

16.    REPORTING ON THE BOARD’S ACTIVITIES

The Chair shall provide the approved minutes of each meeting to the Scheme Manager and produce an annual report on the Board’s activity.

The Chair shall also report to the Sussex Police and PCC Joint Audit Committee.

17.    REPORTING BREACHES ETC

The Board shall report breaches of law in accordance with its “Reporting Procedures Policy”.

18.    ACCESS TO THE PUBLIC AND PUBLICATION OF PENSION BOARD INFORMATION

The following will be entitled to attend Board meetings in an observer capacity:

  • Officers or advisers of the Force or other employers involved with the management of the Scheme subject to approval in advance by the Chair, or on request of the Chair;

  • Any other person requested to attend by the chair;

  • Any other person subject to approval in advance by the Chair;

  • Members of the press and public can attend the meeting but the Chair reserves the right to hold part of the meeting in private (Part 2) on the grounds that it involves the likely disclosure of exempt information under the Data Protection and Security Information

  • Any such attendees will be permitted to speak on request of the Chair

19.    INDEMNITY/INSURANCE

Indemnity Insurance will be provided to members of the Board by the Local Authorities (Indemnity for Members and Officers) Order 2004.

20.    REVIEW, INTERPRETATION AND PUBLICATION OF TERMS OF REFERENCE

These Terms of Reference have been agreed by the Board and will be reviewed annually. The Terms of Reference are only effective once the Scheme Manager has provided confirmation that he approves them.

Changes to these Terms of Reference will only be approved by the Board, with the Scheme Manager’s approval; and will be made in accordance with section 3 above of these Terms of Reference.

21.    DEFINITIONS AND INTERPRETATION

The following words apply to the Terms of Reference:

“2015 Regulations”

Means the Police Pension Regulations 2015

“Act”

Means the Public Service Pensions Act 2013.

 

“Board Member”

Means a member of the Board (this includes a reference to an Employer Representative, Employee Representative and an Independent Member).

“Chair”

Means the appointed chairperson of the Pension Board.

“Code of Conduct”

Means the code of conduct adopted by the Board.

 

“Code of Practice”

Means The Pensions Regulator’s Code of Practice no. 14 entitled “Governance and administration of public service pension schemes”.

“Conflicts of Interest”

Is as defined in the Act.

“Conflicts of Interest Policy”

Means the policy on conflicts of interest as adopted by the Board.

“Deputy Chair”

Means the appointed deputy chairperson of the Board.

 

“Employee Representative”

Means a person appointed to the Board for the purpose of representing employers for the Scheme and any connected Scheme.

 

“Employer Representative”

Means a person appointed to the Board for the purpose of representing members of the scheme and any connected scheme.

“Independent Members”

Means neither and Employer Representative or a Member Representative.

“Police Pension Board Member Appointment and Removal Rules”

The document adopted by the Board setting out the nomination and selection procedure and how Board Members are to be appointed and removed.

 

“Reporting Procedure”

Means the procedure adopted by the Board setting out the Board’s procedure for reporting breaches of law and other matters.

“Scheme Manager”

The Chief Constable

“Scheme”

The Police Pension Scheme.

“Knowledge and Understanding and Training Policy”

 

Means the training policy as adopted by the Board.

 

All references to job titles of officers are to officers within the Force unless otherwise stated.

  1. STANDARD AGENDA

The standard agenda will consist of the following:

  • Conflicts of interest

  • Review of minutes, actions and decisions made since the last Board meeting

  • Review of rulings from the Pensions Ombudsman relating to the Police Pension Scheme that may have a bearing on the Boards

  • Financial reports

  • Risks and Issues Register

  • SLA and service performance reports if applicable

  • Feedback from stakeholders, including any member’s forum

  • Details of any complaints about the scheme

  • Any other business acceptable to the

ANNEX A

Functions of the Board above its core statutory role

The purpose of the Board is to assist the Scheme Manager in the following matters above the Board’s core statutory role:

  1. Board to gain assurance from the SM that the scope & direction is set, controls in place to assure any new strategic approach in complied with

  2. Ensure there are proper processes in place in accordance with TPR & regulations. Feedback on experience of its members as continued improvement. Delivering what should be an economic and effective service. Work with the schemes administrator to improve pension data

  3. Challenge the performance of the administration service. Hold to account any Service Providers.

  4. Have oversight of the procurement of administration services. Ensuring there is a relationship with the service

  5. Oversight of the services required to meet the changing needs of the membership and organisation.

  6. Ensure that the administrator supports the Scheme’s members with a range of tools and communications channels to improve their understanding of the pension benefits;

  7. Ensure a suitable Risk Management framework is in place and the risks are graded and allocated

  8. Have oversight of the audit strategy for the scheme and view the audit delivery plans and reports;

  9. Monitor common areas of complaints and disputes, addressing issues arising from cases referred to the internal dispute resolution procedure and/or the Pension Ombudsman; and

  10. Any such other matters as the Scheme Manager determines from time to time.

ANNEX B

Police Pension Board Appointment and Removal Rules

These rules set out the procedures which have been agreed and adopted by the Board for the appointment and removal of Representatives (i.e. the Employer and Member Representatives and Independent Board Members.

Appointment of Representative Board Members

Nomination and selection procedure

Representative Board Members will be chosen by way of a two state nomination and selection process as follows:

Nomination Process

The Employer Representative Board Members are nominated by the Scheme Manager. Individuals are only eligible to be nominated as a Board Member if they meet the Eligibility Criteria is as follows:

The Employer Representatives must be the Chief Finance Officer for the Sussex Police and Crime Commissioner, the Head of Employee Services for Sussex and Sussex Police and the Chief Finance Officer of Sussex Police

The Employee Representatives must be a member of the Sussex Police Federation, the Superintendence Association and a current member of the scheme.

Selection Process

If more Board Members have been nominated than are required, the Chair of the Board will select who will serve on the Board.

Term of Office and Removal of Representative Employer and Member Representative Board Members

Employer and Employee Representatives are appointed for a period of 3 years from the date of establishment of the Board or the date of their appointment, if later.

The period may be extended up to 3 years if jointly agreed by the Scheme Manager and Chair.

Any Board Member may be re-appointed for further terms in line with the nomination process above

An appointment will automatically cease if:

A Board Member no longer meets the Eligibility Criteria;

A Board Member has a conflict of interest which, in the opinion of the Scheme Manager (on the advice of the Chair), cannot be managed in accordance with the Pension Board Conflict of Interest Policy;

A Board Member dies or, in the opinion of the Board, becomes incapable of acting; and

A Board Member wishes to resign, and has given one month’s notice in writing to the Chair.

Further, if a Board Member fails to attend meetings or otherwise comply with the requirements of being a Board Member, for example fails to attend the necessary knowledge and understanding training, then the Chair of the Board and the Scheme Manager can decide, whether the member should be given an opportunity to change their behaviour. Where issues of the nature arise, the Chair will hold an initial informal discussion with the Board Member about these concerns.

Where a vacancy arises for a representative member mid-term the nomination process will apply.

Review of the Rules

The Board will keep these Terms of Reference under review having due regard to the 2015 Regulations, the Code of Practice and guidance (statutory or otherwise). The Board will amend these Terms of Reference as and when it sees fit in accordance with section 3 of these terms.

ENDS

 

To:

The Chief Constable Sussex Police

From:

Chair of the Police  Pension Board

Subject:

Pension Board Annual Report

Date:

11 September 2018

 

Purpose of Report:

This report sets out the key activities of the Pension Board for the period

17 August 2017 and 31 May 2018, its membership and attendance record, the revised Terms of Reference (TOR) for approval and the proposed work plan for the year ahead.

Recommendations:

  • To note the work of the Board during the

  • To approve the revised TOR

  • To approve the work plan for 2018/19.

  • To thank the Board members for their work in support of the Scheme Manager.

The Police Pension Board For Sussex Annual Report 2017/18

Report  by   Iain McCulloch,   Chair  of the Police  Pension   Board  For Sussex

  • Introduction

    • The Board was established on 1 April 2015 by Chief Constable Giles York, as Chief Constable of the Sussex Police (the “Scheme Manager”) according to section 5 of Act and regulation 13 of the 2015

    • This report sets out highlights of the work of the Board for the meetings between 17 August 2017 and 31 May 2018 and the work planned for 2018/19.

2                    Pension Schemes Overseen

  • There are three pension schemes under administration within Sussex police pension

  • As at 30 April 2018 and 2017 total membership of each of the three pension schemes in operation (including active, deferred, pensioners and spouse/dependants) were as follows:

30 April

2018

2017

1987 Scheme

5,943

5,980

2006 Scheme

993

1,003

2015 Scheme

1,969

1,925

 

  • A summary of the benefits payable under each of the schemes can be found in Appendix

  • The Pension Fund is administered by the Chief Constable in accordance with the Police Pension Fund Regulations 2007 (SI 2007 No 1932).

  • Day to day administration of the schemes is completed by a contractor overseen by Sussex Police with actual pension payments made via Sussex

  • Payments totalling £77m were made to pensioners in 2017/18. The pension fund accounts as published in the Chief Constable’s Statement of Accounts 2017/18 are shown in the following

  • The annual deficit on the Police Pensions Account is funded by the Home Office Pension’s Top-up

3                    Board Membership and Attendance

  • Board members carry out an important role to support the Scheme Manager some of whom volunteer their time or take time out of their busy day job. I would like to take the opportunity to recognise and thank the Board members for their time and work in support of the Scheme Manager over the last

  • The Board met four times during the year on 17 August 2017, 23 November 2017, 1 February 2018 and 31 May The table below sets out the attendance of each member.

Attendee / Meetings

 

17/08/2017

23/11/2017

01/02/2018

31/05/2018

CHAIR - Iain McCulloch

Chair

Y

Y

Y

Y

Daisanne Summersfield

Employer Representative

N

Y

N

Y

Bill Davies

Employer Representative

Y

N

N

Y

Steve Whitton

Employer Representative

N - SUB

N - SUB

n/a

n/a

Matt Webb

Member Representative - Police Federation

Y

Y

Y

Y

Carwyn Hughes

Member Representative - Superintendents Association

Y

Y

Y

Y

Graham Bradley (NARPO)

Member Representative - North Sussex NARPO

Y

Y

Y

Y

  • We have enjoyed a stable membership compared with the previous year which Change in The table shows full attendance by member representatives.

4                    Revised Terms of Reference (TOR)

  • The regular review of the TOR of the Board is important to ensure that they are fit for

  • The TOR was reviewed by the Board at their focussed meeting held on

  • April 2018  and a number  of changes  have  been made including a revision to Annex A - Functions of the Board above its core statutory role.

4.3    The revised TOR is attached  at  Appendix  1      and we   are  seeking approval of these by the Scheme Manager.

5                    A summary of the work of the Board 2017/18

  • The Board completed a wide range of activities both planned and reactive during the

Work Plan - Planned Activity

Outcome

Oversee the procurement of

The East Midlands

administration services, making recommendations on the scope of the service, budget, evaluation criteria and signing off preferred provider proposals;

framework was used to go out to procurement. As well as service improvement savings were also made on both Surrey and Sussex pension contracts.              The

 

Pension Board had

 

involvement at tender

 

meetings along with the

 

scoring of bidding

 

organisations on the

 

framework.

 

Acknowledgement needs to

 

be made to the Sussex

 

Pension Transfer Project

 

Team as none of this could

 

have been achieved without

 

their commitment and hard

 

work. They ensured each

 

milestone ran as smoothly

 

as it could and to very tight

 

timelines.  This happened

 

whilst they were all doing

 

their day jobs.

Ensure issues arising from the member survey are considered by the Board and addressed where possible and monitor common areas of complaints and disputes, addressing issues arising from cases referred to the internal dispute resolution procedure and/or the Pension Ombudsman;

A member survey was completed in March 2017. This gave a range of results and helped the Board understand where issues were arising for members.

 

Ensuring the communication of the benefits of the Scheme and develop a suitable website presence for the Board to communicate its work and other pension matters with scheme members and the Regulator;

All agendas and minutes are now on the Sussex Police external website, in line with requirements set by The Pensions Regulator. More work is required, so this activity will be carried forward.

Monitoring the issue of the Annual Benefit Statements and any subsequent member feedback;

The Pension Board initiated a review from Capita; accuracy, timeliness and a review of communications was part of the review.

Complete a review of scheme governance and compliance and oversee implementation of actions to ensure it meets Regulator and legislative requirements;

Key areas have been reviewed this year:

·        Conflict policy

·        Risk register

·        Compliance

Continue to develop and scrutinise key performance and other data including  complaints and accuracy of

member records to ensure the scheme is properly administered and fully compliant ;

A standard agenda is set for each meeting. The pension administrator is also in attendance so they can provide an update on recent performance.

Continue the training and

development of Board Members;

To keep up to date with national developments to the pension scheme and oversee the development of processes and systems to incorporate any new statutory requirements;

Training  is kept up to date

via the Pensions Regulator online training.

Other training has been attended:

·        Tax and Lifetime allowance – London

·        TPR training  - Crawley

 

  • In addition the Board carried out the following  additional activities:

Activity

 

GMP reconciliation

Continued to monitor the progress to of the Guaranteed minimum  pension (GMP)

 

 

reconciliation for the contracted out defined benefit schemes that was being administered by Capita. This is remaining with Capita despite the transfer to Equiniti.

Made links  with the Scheme

Advisory Board

Invited  Kevin Courtenay to attend

the meeting on 23/11/2017.

Review of TOR and other

responsibilities  of the Board.

Held a separate focussed group

meeting on 5 April 2018 in which it reviewed the risk register, terms of reference and other forms.

Risk Register

The revision of the risk register to

manage the internal controls risk management framework based on the Pension Regulator guidance.  This is  now on the work plan for 2018/19.

Agenda Content

Continued to develop the Board agenda to include standing items. This to ensure consistent and comparable data and information to enable the Board to discharge its responsibilities;

 

6                    Board Work Plan for  2018/19

  • Looking ahead the Board guided by the revised TOR will focus on the following key areas:

  • Monitor the bedding in of the new pension administrator provider Equiniti and their interaction with the

  • Monitor the implementation of the new on-line offer including a self- service to members       and  review  feedback  from  members  on   its

  • Data Scoring – Data underlies everything in The TPR will be asking schemes to provide their scheme specific data score. The Board will review this and ask:

    • Does the scheme have the right processes in place;

    • How is ‘bad data’ corrected;

  • Determine what will be the outcomes of the TPR measuring tool will be and what investment needs to take place in data

  • Review and revise the reporting Breaches of the Law in light of guidance received from the Scheme Advisory Board;

  • Ensuring the communication of the benefits of the Scheme and develop a suitable website presence for the Board to communicate its work and other pension matters with scheme members and the Regulator;

  • Monitoring the distribution of the Annual Benefit Statements and any subsequent member feedback (Surveys);

  • Complete a review of scheme governance and compliance and oversee implementation of actions to ensure it meets Regulator and legislative requirements;

  • Continue to develop and scrutinise key performance and other data including complaints and accuracy of member records to ensure the scheme is properly administered and fully compliant;

  • Continue the training and development of Board Members so that they have the right skills to meet the requirements of The Pension Regulator;

  • Develop a network of contacts and experts that can support Members of the board g. Scheme Advisory Board;

  • To keep up to date with national developments to the pension scheme and oversee the development of processes and systems to incorporate any new statutory requirements;

  • Relationship with the Surrey Pension Board in order to share To also keep under review the possibility of amalgamating the two pension boards.

7                    Recommendations

  • To note the work of the Board during the

  • To approve the revised TOR

  • To approve the work plan for 2018/19.

  • To thank the Board members for their work in support of the Scheme Manager.

  • The approved report will be shared with the Scheme Advisory Board.