Agenda item

This report considers changes made to the risk register for the Surrey Pension Team in Quarter 4 of 2023/24.

Speakers:

Paul Titcomb, Head of Accounting & Governance

Tom Lewis, Head of Service Delivery

Neil Mason, LGPS Senior Officer

Key points raised during the discussion:

1.    A Member queried risk 13 on regulatory compliance and would the expectation be that once the work on those areas around GMP and McCloud was complete that the assessment of the likelihood would drop and the risk profile decrease? The Head of Service Delivery stated that this was difficult to answer because the risk noted in the register is broader than those specific areas and it is not clear what might be coming from government legislation further ahead. So it could be that those two material items are cleared and at that point the risk on those items alone has come right down only for something else to require the assessment to go back up again.

2.    The Chair stated that he had a potential issue with risks 13 and 14 which he felt could be rated as unlikely but having heard what the Head of Service Delivery said that the risk area was broader so maybe those risks should stay as they are. The Head of Service Delivery responded that this was an inherent risk and ratings would fluctuate accordingly.

3.    The Head of Accounting & Governance stated that the ongoing issues with MySurrey had been well articulated in the report and annex. The payroll data area had been a significant issue. The primary issue was with access and reporting out of the system.

4.    A Member asked if the position was that the information coming through from other employers or employers, other than Surrey County Council, was now more readily going into the pension fund and meeting pension fund requirements? The Head of Service Delivery responded that from an employer data perspective, the flow of data coming across from Surrey has been minimal or the frequency has been late. He explained in detail the differing processes that were being used.   This had disrupted the way in which information was flowing in. Then there was the work that they're trying to do, not just to rectify pensions work.  They don't have the resource to return to the more manual way of doing it or providing it in a different way, bar for those cases where they're deemed critical.  The biggest issue was not receiving leaver information and he explained the support that the Administration Team had provided to try to get things on track.

5.    The LGPS Senior Officer explained that the urgency of this had been elevated and that regular meetings took place at which the Board and Committee Chairs attended. Ultimately, there was a need to be confident in the way this was being looked at and that serious steps on remediation were being taken by Surrey County Council.  If they were not, then a recommendation to the Board that Surrey County Council be reported to the Pension Regulator may be considered appropriate. A Member asked at what point did officers think that this may need to happen.  The Head of Service Delivery estimated a month from the tipping point because if left any later and the information had still not been received then there would be an issue delivering the annual benefit statements. 

6.    A Member also pointed out that if starter/leaver information was not received then that would impact on external audit not being able to give a clean opinion on the accounts. The Head of Accounting & Governance responded that the accounts would be prepared with the best available information and if there were estimates required then the estimates would go into the accounts.

7.    The Chair stated that there was a meeting on this specific topic on Tuesday where both he and the Committee Chair would be.  They would learn the latest position at that meeting. Therefore, it was determined that the Board should monitor the issue closely.  It was agreed that a note on the outcome of this meeting be shared with the Board.

8.    A Member asked if no one's been entered on the system for however long it was, how many people was that in a normal period? The Head of Service Delivery responded that new starters were included in the rectification work that had been done, so they've been identified, and their records updated. He estimated about 300 to 400. New starters were not a big work burden because once the data flowed in then new starter packs would be issued in bulk, but the problem was that they may then start contacting the customer relations team questioning why they are getting a pack when they started some time ago. This may then cause a knock on effect to other service areas.

9.    The LGPS Senior Officer explained the process prior to reporting to the Pension Regulator describing the traffic light system for the materiality of a breach.  That the risk was at amber at the moment but if it was felt to be going into the red then the Breaches Policy would be followed as part of next steps. This would involve consulting with senior officers in the organisation, including the monitoring officer and the Chairs of the Committee and the Board, and make a recommendation to those bodies before any formal reporting was made. Currently the remediation and mitigation were underway, but it was coming to the point whereby it may need to be reported.

10.  There was some discussion around whether the risk rating for risk number 16 should be raised to the highest level and on the advice of the LGPS Senior Officer agreed to hold off on any changes until after the meeting to be held on Tuesday with relevant parties and the Chairs as the next two weeks were critical.

11.  A Member also asked if the mitigation for risk no 16 should be changed and again it was agreed that this decision would be deferred until after the Chairs meeting on Tuesday. 

Actions/ further information to be provided:

That a note on the detail and outcome of Tuesday’s meeting be shared with the Board.

Recommendations:

1.    That the report be noted.

2.     To recommend that if appropriate, following a meeting of the Chairs and officers, that the Pension Fund Committee review the risk score and mitigation of risk 16.