The Pensions Data Crisis: Mortality Manifest on Accuracy and Trust

Pensions run on data, and it's vital to make sure that data is robust enough to trust with people’s futures.

In this Sense of Identity episode, we speak with Sam Drye, Managing Director, and David Rich, Chief Data Officer at Mortality Manifest, a specialist data service that helps financial organisations address the complex realities of mortality, tracing, and overseas members.

Together, we explore why pensions data is under more pressure than ever, how poor records translate into real risk for schemes and savers, and what it takes to build a data strategy that can stand up to scrutiny.

From Death Data to Data Confidence

Sam begins with the origins of Mortality Manifest and the slightly uncomfortable truth at the heart of its work.

The company was one of the early adopters of the UK Government’s central register of deaths, helping financial firms identify when customers had passed away and prevent payments continuing indefinitely.

In pensions, even that basic question - whether a member is alive and contactable - becomes complex as records age and people move.

Mortality Manifest has since evolved from mortality screening to a broader data quality partner for schemes and providers.

Sam explains that they now support address tracing, beneficiary identification, and the particularly difficult challenge of overseas pensioners whose records no longer align with UK data sources.

"Essentially, we provide a range of automated data solutions to give financial institutions confidence in their data."

Sam Drye, Managing Director, Mortality Manifest

The Scale of the Pensions Data Crisis

When Mortality Manifest reviews member files that have not been actively maintained, they expect a significant proportion to contain errors.

These can include out-of-date addresses, missing identification details, or members who have sadly died but remain marked as active.

Frequent house moves and life changes mean inaccuracies can accumulate quickly if schemes are not tracing proactively.

David notes that this is not an edge case but a predictable outcome of long-term record-keeping across large populations.

Even modest pensions, multiplied across a growing cohort of British retirees living overseas, can result in substantial payments to people who may no longer be alive.

Some cases involve fraud, but many simply reflect outdated data and slow administrative processes.

The consequence is the same. Money intended to protect the whole scheme leaks away, leaving trustees to choose between recovery action, reputational risk, or writing off the loss.

Why Regulation Is Turning Data into a Strategic Asset

The Pensions Regulator has repeatedly stressed the importance of accurate, complete records through its dashboards guidance and research into DB administration.

These publications emphasise that data quality underpins good governance and fair member outcomes.

Government dashboards policy reinforces this shift. Connecting to the ecosystem requires schemes to “find” and “view” members reliably, using data that can be matched consistently across multiple pension pots.

The Pensions Dashboard Programme positions data preparation as an ongoing responsibility, supported by practical cleansing guidance.

Industry bodies are aligned. PASA’s Data Management Plans guidance and updated data quality standards give trustees structured ways to measure and improve data over time.

Consultancy and government commentary align with this direction. The Government’s review of DB options notes that clean, accurate data is essential for timely, cost-effective de-risking transactions.

Similar themes appear in analysis of data bottlenecks in risk transfer projects, which links data quality directly to transaction readiness. Data quality is now a strategic requirement.

The Overseas Member Challenge

David notes that more British retirees are living abroad, even as the administrative process for doing so has become more complex.

Digital connectivity has made this lifestyle more feasible, but it has widened the information gap for schemes.

Within the UK, a central death register provides reliable mortality screening. But outside the UK, no equivalent system exists.

Some countries maintain partial or regional death records, but access varies and data can be inconsistent.

Historically, schemes relied on slow, manual methods such as letters, stamped forms, and in-person verification.

Mortality Manifest now offers a more workable model. Sam describes multi-channel campaigns that combine secure digital communication, biometric checks, and human support to confirm that members are alive, contactable, and who they claim to be.

From Print, Pack, and Post to Biometric Checks

The shift from paper-based verification to digital identity checks is one of the most striking developments in this space.

Previously, verifying that a member was alive could involve long travel, fees, and slow international post.

Today, members can scan an identity document, complete a biometric match on their phone, and speak with a UK-based support team if they need reassurance.

David notes that retirees are increasingly comfortable with digital tools, especially since the pandemic normalised video calling and online services.

Sam adds that technology alone does not solve the problem. The managed service element of their service matters because it handles sequencing, reminders, and inbound queries that schemes often struggle to resource.

This reflects a broader theme of the Sense of Identity series. Identity is as much about clarity and trust as it is about technology.

The Role of Tracing, Addresses, and Contactable Data

The discussion returns to a fundamental question: can schemes reliably reach the people whose data they hold?

Sam emphasises that pension providers have a duty to maintain accurate contact information for long-term assets and lifetime payments.

Mortality Manifest strengthens these with historic address data and live credit indicators to locate members whose records have drifted.

The same principles apply to digital contact details.

Email is becoming a critical communication channel, particularly for overseas members. However, many schemes still rely on work email addresses, which quickly become obsolete.

Mortality Manifest appends opt-in email addresses with evidence of when and how they were collected, supporting regulatory clarity and member trust.

Secure Digital Communication and Monthly “Pulse” Checks

David explains that secure email, when implemented correctly, is widely understood, accessible, and increasingly recognised as a legitimate channel for regulated communication.

This creates an opportunity to rethink proof-of-life practices.

Sam outlines a model where biometric verification is followed by monthly secure email “pulse” checks before each payroll run.

Members confirm they are present and able to access their funds. Missed checks provide schemes with a clear audit trail for investigation.

The approach is intentionally low-friction for members and high-assurance for schemes, but it relies on accurate contact data and strong security controls.

Data Governance in Practice: From Scores to Plans

Sam and David outline what effective data governance looks like, pointing to industry guidance suggesting schemes focus on four areas.

• Data quality scoring: regularly assessing completeness and accuracy.
• Data Management Plans: documenting data sources, processes, and risks.
• Improvement planning: defining targeted actions to remediate gaps.
• Governance and oversight: ensuring data is a standing priority, not a one-off project.

External analysis of data bottlenecks in pension risk transfers reinforces that clean data supports smoother insurer engagement and fewer delays.

Sam acknowledges the operational challenge for schemes. Campaigns, queries, and verification touchpoints are resource-intensive.

The Practical Questions for Trustees and Providers

The episode leaves trustees and pension managers with several practical questions:

Do you understand the quality of your data today across both UK-based and overseas members?

Do you have an ongoing plan to improve that data rather than rely on periodic cleansing?

Are you making best use of secure digital communication to reach members wherever they are?

And do you have the capacity to manage complex tracing and mortality checks, or should you work with a specialist partner?

As Sam notes, this is not a problem you fix once.

People move, circumstances change, and sadly people pass away.

Data must be maintained continuously to give members the confidence they deserve.

References

Defined Benefit Survey Research Report, The Pensions Regulator, 2021

Pensions Dashboards Guidance for Trustees, The Pensions Regulator, 2025

Pensions Dashboards: Guidance on Connection, UK Government (DWP), 2025

Getting Data Ready for Dashboards, Pensions Dashboards Programme, 2025

Cleansing Data in Readiness for Dashboards, Pensions Dashboards Programme, 2022

Data Management Plans Guidance, PASA, 2021

Data Standards and Management Guidance, PASA, 2021

Buy-In Data Guidance, PASA, 2025

Trustees Urged to Treat Member Data as Strategic Asset, Pensions Age, 2025

New Data Quality Guidance for Dashboards, Pensions Age, 2025

Government Response: Options for DB Schemes, UK Government (DWP), 2025

Data Bottlenecks in DB Pension Risk Transfers, Spence & Partners, 2025

FAQs

Why is poor data such a significant problem for pension schemes?

Poor data makes it difficult to pay the right benefits to the right people at the right time.

It increases the risk of fraud, disputes, overpayments, and delays in dashboards or risk transfer activity.

How do overseas pensioners make data management more difficult?

No single global death register exists, overseas postal communication is often slow, and retirees may move several times.

This makes it harder for schemes to maintain accurate contact and identity records.

What does good data governance look like in practice?

It typically includes regular data scoring, targeted improvement actions, and ongoing trustee oversight.

It often also involves specialist support for complex tracing and verification tasks.

Can secure email be used for sensitive pension communications?

Yes, when supported by appropriate security and a clear consent trail, secure email is increasingly recognised as a valid durable channel.

It provides timely and reliable communication, especially for overseas pensioners.

Where should schemes begin if their data challenges feel overwhelming?

A practical starting point is assessing current data quality, focusing on the highest-risk cohorts, and building an initial improvement plan.

From there, data governance can become a continuous process rather than a one-off exercise.

Reviewed by

Sam Kendall, 10.12.2025