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1. Background
This is the Communications Policy of Derbyshire Pension Fund (administered by Derbyshire County Council), which sets out how the Fund communicates and engages with its stakeholders.
The Policy has been developed in accordance with Regulation 61 of the Local Government Pension Scheme Regulations 2013 (Regulation 61) and takes into account guidance from The Pensions Regulator.
Regulation 61 requires that the Policy covers:
- the provision of information and publicity about the Local Government Pension Scheme (LGPS) to scheme members, representatives of scheme members and scheme employers
- the format, frequency, and method of distributing such information or publicity
- the promotion of the LGPS to prospective scheme members and scheme employers
This policy also incorporates the Fund’s plans for developing its communications over the three-year period 2024 to 2027.
Progress will be reviewed annually, and the policy will be reviewed at least every 3 years or when there is a material change to the Fund’s methods of communication or engagement with its stakeholders.
The Pensions Regulator oversees pension schemes and provides guidance on how they should best be governed and administered. This includes guidance on communicating with scheme members in a way that, as well as being accurate, is clear and simple to understand, and avoids jargon. Much of what the Fund is required to communicate to scheme members, and time limits on these communications is set out in regulation. To ensure compliance with these regulations, the Fund has appropriate internal controls in place.
2. The Fund’s stakeholders and audience
The Fund currently has over 93,000 individual scheme members with approximately 110,000 separate pension records which are split by active and deferred membership, and pensioner membership where benefits are being paid.
The active membership (currently approximately 38,000) incorporates employees from over 340 participating employers. These employers range from Councils, Academies and Colleges to private companies who have been contracted to deliver public services.
The Fund’s stakeholders and other organisations with which it regularly communicates include:
Other external bodies including:
The Fund recognises that a variety of methods of communication are required to engage effectively with different groups of stakeholders.
3. Objectives
The Fund’s overriding objective is to ensure that it delivers clear, timely and accessible communications to its stakeholders.
The Fund aims to achieve this by delivering communications to its stakeholders which are:
- Targeted: with the aim of delivering clear, accurate and effective communications to each different audience group in terms of the style of content and the method of delivery
- Easy to understand: providing clear and easy to follow explanations or summary of pension issues, particularly where pension related decisions are being made
- Accessible: ensuring that all scheme members and other stakeholders can access the Fund’s services, online content, and communications equally
- Cost effective: to help save resource, time and expenditure
By communicating in this way, the Fund aims to:
- Communicate information about the LGPS rules and regulations in an effective, jargon-free, and timely manner to the different groups of members, employers and other stakeholders to enable them to make fully informed pensions decisions
- Keep members, employers and other stakeholders informed about the management and administration of the Fund
- Consult with key stakeholders on changes to policies and procedures that affect the Fund and its stakeholders
- Seek to continually improve the Fund’s communication methods by requesting and analysing feedback
- Promote the LGPS as an attractive benefit to scheme members and an important tool in recruitment for employers
- Work with employers to enable them to fulfil their responsibility to communicate and share information with members in relation to the scheme
- Maintain the Fund’s commitment to regional and national initiatives, taking advantage of partnership working and innovative communication methods developed and tested elsewhere, and sharing the Fund’s own experience in return
- Enable equality of access to Fund communications
- Manage information securely to the standards required by the Data Protection Act 2018
4. Accessibility
The Fund aims to broaden inclusion to ensure all members have equal access to its services, online content, and communications, and is committed to increasing digital access and delivery of services, making the best use of technology.
In respect of online content, public sector organisations have a legal duty to make sure their websites meet accessibility requirements, currently set at compliance with World Wide Web Consortium Accessibility Guidelines (WCAG version 2.1 AA standard), published by The Worldwide Web Consortium (W3C), which requires that a website must be accessible by making it ‘perceivable, operable, understandable and robust’.
The Fund’s website is designed to ensure that new content meets the WCAG version 2.1 AA standard, which is currently the recommended minimum standard for all council hosted websites, and its accessibility statement, sets out how documents held on the website meet those standards.
Regular analysis of the accessibility of the content and functionality of the website is undertaken using Silktide. This is an online tool which identifies issues for attention across the website.
The Government Digital Service, which monitors public sector bodies’ compliance with accessibility requirements, is currently reviewing how to assess WCAG 2.2 with a view to monitoring the accessibility of public sector websites on new criteria from October 2024. WCAG 2.2 was formally approved in October 2023 by the Worldwide Web Consortium as the most up-to-date international standard for web accessibility.
The Fund will review and identify changes required to meet the requirements of WCAG 2.2 following the Government Digital Service’s assessment.
All print and electronic communications are designed with consideration for those with additional needs, with alternative formats, such as large print or braille available on request.
The Fund offers a Pensions Helpline (tel: 01629 538900), which is available for anyone having difficulty accessing or understanding any of the Fund’s documents.
5. How we communicate
The Fund has developed a variety of communication methods to ensure that all stakeholders are informed and up to date. A number of these communication methods are targeted at specific stakeholder groups and are set out later in this policy. The following methods are used to communicate with all stakeholders:
5.1 Derbyshire Pension Fund website
This website is our primary source of generic and Fund specific LGPS material with sections providing an extensive information resource for all existing and prospective members and Fund employers.
Resources include:
The website also has sections dedicated to the Fund’s governance arrangements including its policies, strategies, and statements.
The website has been designed to be easily browsed, accessible and user friendly from desktop, laptop, tablet, and smartphone devices.
As well as an information resource on the LGPS, the website contains downloadable forms and factsheets for members on a range of topics.
It also includes several online forms, which enable members to engage quickly and easily with the Fund.
These include:
Online forms have also been developed to enable employers to:
- inform the Fund of outsourcing arrangements which impact on an individual’s LGPS eligibility and membership (Initial admission bodies notification form)
- respond to consultations via Microsoft Office 365 forms
- provide feedback on training delivered by the Fund via Microsoft Office 365 forms
All forms embedded on the website are securely transferred to the appropriate Fund email inbox.
The website also enables members to easily access the Fund’s online member self-service portal My Pension Online, which launched in June 2021.
The Fund will continue to maintain and develop its website and ensure it remains its primary source of Fund and LGPS information for members and employers.
Google Analytics is used to collect information about how visitors use the Fund’s website. This information is not used to identify visitors to the website but is used to analyse traffic and engagement with a view to improving the user experience.
5.2 Email communications
The Fund maintains several secure email inboxes used by members and employers for the submission of general and individual enquiries, the provision of information and other-directed information. The details of each inbox and their purpose is explained in the following bulleted list:
5.3 Phone enquiries
The Fund has a dedicated Pensions Helpline number (tel: 01629 538900) for members to contact the Fund. The Helpline is currently available Monday to Friday 9am to 5pm.
5.4 My Pension Online
Scheme members are able to access their pension account by registering for My Pension Online.
My Pension Online is hosted by Aquila Heywood which provides the Fund’s pension administration system.
The online platform is a secure area, allowing members to access and update some of their personal details held by the Fund. Active and deferred members are also able to access their latest, and previous Annual Benefit Statements and run their own pension estimates. As the service continues to develop and registrations increase, more correspondence and the issuing of pension documents will be online and, as a result, provide a more timely service to members and consequently reduce printing and postage.
Since launching in June 2021, the Fund has concentrated developments on (and promoted registrations from) active and deferred members. This is because My Pension Online's functionality is fundamentally based on scheme membership before retirement. As at the date of this policy being prepared, approximately 1 in 3 of the overall active and deferred membership had completed their registration.
As part of the initial registration process, members are required to provide their personal email address to the Fund by completing a secure online access form.
My Pension Online is continuing to be developed, including a review of an updated version of the platform developed by the system provider, Aquila Heywood. It is labelled as the 'Transformational Member Experience' and will include improvements to the registration process and the introduction of Two-Factor Authentication (2FA) to provide an extra layer of security. The Fund will continue to monitor this development as part of its ongoing review of the available functionality.
In respect of encouraging registrations from active and deferred members, the Fund works extensively with employers and also provides information to members about the service in letters and other communications where the opportunity arises.
There are 3 categories of scheme member:
It is recognised that communication with each category requires a different, specific and targeted approach.
5.5 Communication with active members
On joining the scheme, new active members are provided with:
- confirmation of their LGPS membership
- a link to the scheme information on the website
- forms and information to enable them to request a transfer in of previous pensionable service with other LGPS Funds or other public service pension schemes
Each year the Fund provides annual benefit statements to active members. These statements summarise pension account balances to the previous 31 March and are issued to My Pension Online. Emails are sent to members when their annual benefit statements are available. The exception to this is if members have notified the Fund that they wish to continue to receive paper copies.
A letter is currently issued to each member who has not registered for My Pension Online to inform them that their annual benefit statement is available, with guidance on the steps to begin the registration process.
The Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013 require that members are notified on at least 2 occasions that information (such as their annual benefit statement) is being issued on a website and asked to provide their email address for registration purposes. At present the Fund is continuing to write to unregistered members to notify them when their annual benefit statement is available on My Pension Online. This communication is reviewed each year.
The provision of annual benefit statements is subject to scheme employers providing timely and accurate information to the Fund.
The Fund also produces an active member newsletter each year in collaboration with a regional Joint Communications Group, which is published on the Fund website. Active members are directed to the newsletter by a link provided in their annual benefit statement. The content comprises current pension topics within the LGPS and the pensions industry in general, plus important repeated messages.
Individual meetings and information sessions with active members are offered through their employer and are undertaken either virtually or in-person. These are mainly delivered in the form of “Understanding your LGPS pension” presentations and drop-in sessions at venues around the county hosted by scheme employers.
The presentations are delivered to help explain any significant changes in the LGPS regulations over time, and to assist where an employer is going through a restructuring or outsourcing exercise that will have pension-related implications. Drop-in sessions may be targeted to coincide with events, such as the issue of the annual benefit statements. The nature of the drop-in sessions allow that members can meet an experienced member of the Fund team informally and ask questions they may have about their pension.
5.6 Communications with deferred members
Each year, the Fund provides annual benefit statements to deferred members.
These statements summarise a member’s pension account balance at the first Monday after the start of the new financial year and are issued to My Pension Online. The exception to this is if a member has notified the Fund that they wish to continue to receive paper copies.
As with the procedure for active members, a letter is currently issued to each deferred member who has not registered for My Pension Online to inform them that their annual benefit statement is available, with guidance on the steps to begin the registration process.
The Fund also produces a deferred member newsletter each year in collaboration with a regional Joint Communications Group and publishes it on the Fund website. Deferred members are directed to the newsletter by a link provided in their annual benefit statement. The content comprises current pension topics within the LGPS and the pensions industry in general, plus important repeated messages.
5.7 Communication with pensioner members
The Fund’s pension payroll is currently provided by Derbyshire County Council’s HR services. The Council, as part of its service provision, issues pay advice slips to pensioners to coincide with their first pension payment and subsequently at each March, April and May. The April pay advice includes information about the percentage rate of annual pension increase and explaining how it is applied.
Pensioners will also be sent further payslips to alert them to any further variations in their net monthly amount of 1% or more. P60s are issued annually in respect of the pension received in the previous financial year.
The Fund participates in the National Fraud Initiative and may share information with other bodies responsible for auditing or administering public funds for the purpose of preventing and detecting fraud. The Fund includes brief details about the National Fraud Initiative on payslips for pensioner members at least once per year. The details provided include a link to the Derbyshire County Council's National Fraud Initiative privacy notice.
Life certificates, or alternative electronic solutions, are issued annually to pensioners living abroad to ensure that they maintain eligibility for payment of their pension. The Fund currently engages a specialist tracing service, Target Professional Services, to aim to reduce the liabilities which result from pension overpayments following the death of pensioner members living overseas, through the use of secure electronic solutions.
5.8 Communication with prospective members
Prospective scheme members are provided with basic information on the LGPS by their employer. Employers are supported in promoting the scheme to all their employees and information is provided to employers to signpost their employees to the Fund’s website and to highlight the benefits of joining our scheme.
5.9 Communication with scheme employers
The Fund’s Pension Administration Strategy is reviewed annually. It sets out the standards of performance and best practice that the Fund and its employers should aim to meet when carrying out their LGPS related functions and responsibilities.
The Strategy also sets out the approach the Fund will take to underperformance by employers, including a structure for the charging of avoidable administration costs.
The Fund provides employer training (virtually or in-person) to assist individual employers with specific issues and / or provide direct training to their staff. The sessions can be booked directly by employers, but the Fund is also proactive where it identifies that an employer would benefit from assistance.
Employers are kept up to date with developments which impact on their application of the LGPS regulations by monthly employer newsletters, which are emailed to nominated employer contacts.
The Fund monitors engagement with the employer newsletters by interpreting the delivery data provided through system delivery reports. A further in-depth report is also reviewed to assist the Fund in maintaining an up-to-date circulation list of employer contacts where emails have bounced or failed.
5.10 Communication with Fund Team
It is important to ensure that all members of the Fund's Team have access to the relevant information and technical knowledge to enable them to:
- perform their duties
- understand their role in the delivery of the Fund’s services
- be aware of the wider context of the LGPS
This is achieved through use of email, internal meetings, team briefings as well as internal and external training events on specific topics.
6. Pensions and Investments Committee
The Pensions and Investments Committee meets approximately 6 to 8 times each year, including training sessions on at least 2 occasions per year. It is responsible for the management and administration of the Fund on behalf of Derbyshire County Council.
Members of the Fund’s team work closely with the Chair, Deputy Chair and Members of the Committee to ensure that they are fully informed about Fund matters and that they are fully supported in fulfilling their duties and responsibilities.
Members of the Committee receive reports from Fund Officers on matters to be determined or reviewed. These reports include:
- quarterly investments reports
- other investment related updates
- half-year administration reports
- reviews of new LGPS related legislation
- determination of local policies
- reviews of the Fund’s Risk Register
- Annual Report and Annual Service Plan
- summaries of the adjudication of appeals and disagreements
2 trade union representatives are entitled to attend meetings of the Committee as non-voting members and to receive all the Committee papers.
Minutes of meetings (except for restricted items) are available from the Derbyshire County Council democracy website.
7. Derbyshire Pension Board
The Derbyshire Pension Board was set up to assist Derbyshire County Council in its role as the administering authority in complying with relevant requirements of Scheme governance and administration responsibilities and complying with the requirements of the Pensions Regulator.
The Board comprises an independent Chair, 2 Employer Representatives and 2 Member Representatives.
Members of the Fund’s team work closely with the Pension Board, attending meetings which are held at least twice per year, and ensuring that Board members can fulfil their duties and responsibilities.
Board members are invited to attend meetings of the Pensions and Investments Committee as observers and receive all Committee papers prepared for each meeting. Board members are also invited to training sessions delivered to the Committee.
Information about the Pension Board and summaries of Pension Board meetings are published on the Fund’s website.
8. Plan for the development of communications 2024 to 2027
Communications are a fundamental part of all Fund activity.
Meeting the Fund’s objective of delivering clear, timely and relevant communication to all stakeholders as the Local Government Pension Scheme becomes more complex, with increasing governance obligations requires the Fund to continually improve and develop its communications.
Additionally, there is greater expectation that digital platforms will continually advance, including in meeting accessibility standards.
The following have been identified as key communication-related objectives over the 3-year period to 2027:
- Continuing development of My Pension Online to improve functionality for the member experience
- Encouraging increased member engagement and understanding of the LGPS, including the development of a member engagement forum
- Continuing to improve methods of communication with the aim of broadening inclusion to ensure that all stakeholders are able to access and engage with the Fund’s services
- Increasing consistency of communications, ensuring that content is accurate, easy to understand and helpful to members and employers
- Improving engagement with all participating employers
8.1 Development of My Pension Online
The Fund introduced My Pension Online in 2021 to improve the service provision for scheme members. The service enables members to securely access their LGPS membership information at any time, as well as being able to update some of their personal details.
Since 2021 approximately 25,000 active and deferred scheme members have registered to access My Pension Online enabling them to:
- check the personal details held by the Fund
- access their LGPS membership history
- access their latest Annual Benefit Statement
- support retirement planning through the ability to run unlimited pension estimates from live data
- submit queries directly from My Pension Online
The development by the system provider, Aquila Heywood, of a Transformational Member Experience programme for My Pension Online aims to:
- improve the presentation of members’ LGPS information
- simplify the registration process
- add a multi-layered approach to cybersecurity
The Fund will continue to monitor this development of the enhanced platform as part of its ongoing review of the service’s available functionality.
8.2 Increased member engagement
Approximately 1-in-3 active and deferred members have registered for My Pension Online to potentially increase their engagement with the Fund and the LGPS in general. Therefore, 2-in-3 members are still to register.
The Fund will continue its campaign to promote registration both directly with members and through participating employers.
Higher levels of registration will enable the Fund to further develop and increase the correspondence issued to members electronically, and as a result, provide:
- more timely communications
- reduce printing levels
- reduce posting levels
The Fund is also progressing plans to set up a Member Engagement Forum. To ensure that the Forum has a broad range of Fund member representation, all members will be offered the opportunity to express interest in taking part.
The aims of the Forum will include:
- seeking to promote understanding of the LGPS
- providing an opportunity to receive feedback on members’ experiences of Fund services
- discussing developments in the Fund’s communications with members (such as sharing key messages)
- obtaining opinions on website changes, including My Pension Online
8.3 Accessibility of Fund services
Improving the accessibility of the Fund’s services is an important ongoing target as the expectation for digital development increases.
Statistics from the government's Family Resources Survey for 2021 / 2022 show that almost 1 in 4 people reported as having a disability, which may include visual, hearing, motor or cognitive impairments.
The challenge of ensuring that the Fund’s services are accessible relates, not only to the presentation of online content, but also to making content clear and concise.
Improving the accessibility of the Fund’s digital content will have a positive impact for users, including those who find technical and jargon-heavy language difficult to engage with.
The concept of accessibility also applies to users who may have different needs at different times and in different circumstances such as where they are when accessing the Fund’s content, their health and also the device they are using:
- Understanding: The Fund will aim to ensure that its communications are as accessible as possible by the use of short sentences, sub-headings to explain what a section of content covers and easy to understand language.
- Presentation: The Fund will aim to ensure its digital content is inclusive and accessible, including choice of a suitable font, font size, colour text and backgrounds and, where possible, limited use of PDF attachments (PDF attachments are often inaccessible for some users, difficult to use on mobile devices and resource heavy in keeping up to date). The Fund will aim where possible, to present content which may previously have been prepared in PDF form, as website pages. Where PDF is the only suitable method of presentation, they will be prepared as accessible as possible to ensure content is searchable, has clear and descriptive headings and images have clear and descriptive alternative text.
- Training: The Fund will aim to develop understanding and deliver training to highlight the importance of making the service accessible to all, including digital content, and the style of standard and non-standard communications.
8.4 Consistency in communications
Development of a Fund style guide is continuing, and the scope is extending to include accessibility as a core objective.
Benefits that a style guide will bring include:
- consistency
- clear messaging
- time saving
- improvements in communications between teams
- greater efficiency
- prevention of complaints
- provision of a consistent tone
- provision of a professional look and feel
- building of confidence
- making information easily accessible
- recognition of the Fund’s identity
8.5 Letters project
Aided by the style guide in progress, a project to review approximately 500 standard letters to provide accurate and easy to understand content is continuing and will provide a significant benefit for the Fund’s members.
8.6 Employer engagement
The Fund will continue to develop its engagement with employers:
- during the admissions bodies process
- during onboarding to i-Connect
- through regular communications to Fund employers during an employer’s participation in the Fund
- in the run-up to employer exits from the Fund
8.7 Continued implementation of i-Connect
i-Connect is the Fund’s secure data transmission service which is enabling employers to provide efficient and timely data submissions to the Fund. By November 2023 approximately 80% of the Fund’s employers had implemented i-Connect covering approximately 90% of the total of active members.
i-Connect provides benefits to employers and the Fund through reductions in cost and risk associated with data submissions and processing.
8.8 Employer communications
Ongoing improvements in employer communications will be targeted to support:
- employers to understand their responsibilities
- the continued development of employer covenant reviews
- employers to improve their engagement with their outsourced providers and to improve understanding of risk-sharing arrangements
- closer Fund relationships with resolution bodies (Town and Parish Councils)
- engagement with employers on new employer flexibilities following the development of an employer flexibilities policy
9. Communications Policy review
The policy will be reviewed in the event of changes to regulations or procedures, or to reflect technological or best practice developments. A full review of the policy and the Fund’s strategy for the development of its communications will be undertaken at least every 3 years.
This Fund policy was approved by Derbyshire County Council’s Pensions and Investments Committee on 6 December 2023.