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Matching people with their pensions

When a member uses a pensions dashboard, you will receive certain personal data. You will need to use the data to search your records and determine if you have a pension for them. This process is called ‘matching’.

Some of this data will be independently verified by an identity service before it reaches you. This means you can be confident that the member is who they say they are.

This data will consist of:

  • first name and last name
  • date of birth
  • current address

The member will also be encouraged to provide other data to help you find their records. This information will not be independently verified:

  • National Insurance number
  • previous last name
  • previous address
  • email address
  • mobile phone number

Match is found

If you are confident that you have found a member’s pension record using the information they provided, you have ‘made a match’.

You should create and register a unique identifier with the system. This does not contain any pensions information but acknowledges that there is a match. The member can then ask to view their information and you should return the relevant data directly to the dashboard. For more information, see information to provide to members.

If someone leaves your scheme or retires, you need to remove their match from the system by ‘de-registering’ their unique identifier as soon as possible.

Possible match is found

In some cases, you might not be certain enough that you have ‘made a match’ to release a member’s pension data.

For example, the National Insurance number and date of birth match, but the last name doesn’t. This could happen if a member has married but failed to notify the scheme of their new last name.

In these circumstances you should return a ‘possible match’ to the member. You should create and register a unique identifier. However, in this case you don’t send the member any personal data, only an error message and contact details for your scheme. The member will then know that a match may have been found, but that they need to contact you and provide more information within 30 days to confirm this.

If a match is subsequently confirmed, you would need to notify MaPS that the match is now confirmed, and provide the relevant data to the dashboard when you are asked to.

If you are still unable to make a match, you must delete the member’s personal data as there are no legal reasons to keep it.

Match cannot be found

If you determine that you do not hold a pension for the member, you must delete the personal information provided as there are no legal reasons to keep it.

Setting the criteria for matching

Under current proposals, trustees or scheme managers should set their own criteria to determine what data to use to match members to their pensions.

Current thinking on the data that will be sent to schemes is summarised above. It’s also set out in more detail in the data usage guide from the Money and Pensions Service.

Data quality and accuracy

You need to be confident in the accuracy of the data you are using for matching. If your data is not reliable, you risk returning data for the wrong person or not finding a pension record when you should. This may lead to enforcement action being taken against you by the Information Commissioner’s Office or by us.

Your matching criteria will depend on what data you have available and whether you are confident that it is accurate. The data will also need to be digitally searchable. You should audit your data and discuss with your administrator or other suppliers / advisers which items are most suitable for you to use. You should put a plan in place to improve data and / or digitise this data if needed.

Your matching criteria may evolve over time. It’s anticipated that many schemes will use last name, date of birth, and National Insurance numbers for matching. But if you are not satisfied with the quality of this data, you could widen your matching criteria to include further personal data items such as first name or postcode. This should increase your confidence that you are matching to the right person, without increasing the risk that you fail to find someone when you should. When your data quality has improved, you can update your matching criteria accordingly.

To help schemes, the Pensions Administration Standards Association (PASA) has published data matching convention guidance, which it updated in August 2022. You may wish to refer to this guidance when deciding on your approach to matching.

You will be required to keep a record of your matching policy. You should record the matching criteria you are using for the scheme generally — you are not expected to record the criteria used for each individual search.

Matching, combining or comparing data from multiple sources requires a Data Protection Impact Assessment (DPIA) under the UK GDPR so you will need to produce one. If you already have a DPIA, you may need to update this. You can find out more about DPIAs on the ICO’s website.

Connecting to pensions dashboards
Information to provide to members