Anonymised copy of public sector pension scheme data

Summary

The requester asked for anonymised public sector pension data in an actuarial valuation format to assess potential insurance buy-out costs, but the Public Sector Pensions Authority refused the request citing that it would require substantial compilation and analysis of data.

Key Facts

• The request was refused under Section 11(3) of the Freedom of Information Act 2015 as it required substantial compilation and analysis.
• The Authority suggested existing public reports could be used to estimate liabilities instead of providing raw data.
• All public sector pension schemes managed by the PSPA are unfunded 'pay-as-you-go' schemes with no direct assets.
• The estimated cost to buy out the schemes is approximately £4.3bn based on the 2018-19 valuation.
• The Public Sector Pensions Act 2011 does not currently allow for a bulk buy-out of liabilities.

Data Disclosed

• 1690745
• 2021-03-03
• 2021-03-09
• 31 March 2019
• 31 March 2018
• 31 March 2016
• £4.3bn
• Section 11 (3)
• Section 15

Exemptions Cited

• Section 11(3) of the Freedom of Information Act 2015 (not required to create, derive, research, analyse, or substantially compile information)

Original Request

I wish to request an anonymised copy of the data for all public sector pension schemes in the Isle of Man, in the format that would be provided for an actuarial valuation. As it is likely that these pension schemes will eventually need to be bought out by insurance companies, it is in the public interest that the data required to enable the cost of doing so to be assessed should be available. I intend to undertake such an exercise on a best endeavours basis with the resources I have available.

Data Tables (1)

Full Response Text

9 Laureston Close Douglas Isle of Man IM2 4BF Chief Executive Officer Ian T Murray BCom (Hons), FPMI 3rd Floor Prospect House 27-29 Prospect Hill Douglas, Isle of Man, IM1 1ET E-mail:
pensions@pspa.im Website:
www.pspa.im

Our ref: 1690745 9 March 2021 Dear ###

This request is being handled under the Freedom of Information Act 2015.

We write further to your request which was received on 3 March 2021 and which states:

"I wish to request an anonymised copy of the data for all public sector pension schemes in the Isle of Man, in the format that would be provided for an actuarial valuation. As it is likely that these pension schemes will eventually need to be bought out by insurance companies, it is in the public interest that the data required to enable the cost of doing so to be assessed should be available. I intend to undertake such an exercise on a best endeavours basis with the resources I have available." Whilst our aim is to provide information whenever possible, in this instance the Public Sector Pensions Authority (PSPA) is unable to provide the data that you have requested for the following reason: Section 11 (3) of the Freedom of Information Act 2015 states that: “ a public authority is not required to: (a) create or derive information from information that it holds; (b) undertake research into, or analysis of, information that it holds; or (c) undertake substantial compilation or collation of information that it holds” In particular with reference to Section 11 3 (b) and (c), to provide you with this information would require the PSPA to undertake a substantial amount of work to appraise the data it has, identify the data that you will need, prepare and secure spreadsheets comprising a considerable amount of data and then it would need to undertake substantial collation to prepare its data in a format suitable to send to you, therefore in this regard we are unable to provide you with the information you have

requested. Section 15 of the Act requires the PSPA to provide reasonable advice and assistance to persons making a request for information, therefore the PSPA would add the following to assist in this request: The PSPA is of the view that the data you require to undertake an informal actuarial valuation for the purposes of an insurance company buy out is reasonably accessible via the three publications listed and linked below that are held publically on the IOM Government Treasury (www.gov.im/treasury) and the PSPA (www.pspa.im) websites. Isle of Man Government Audited Accounts Year End 31 March 2019 Isle of Man Public Service Pension Schemes - Actuarial Valuation for Accounting Purposes 31 March 2018
Public Sector Pensions Valuation Report 31 March 2016 The latest version of the Isle of Man Government Audited Accounts Year End 31 March 2019 and separate report on the Actuarial Valuation for Accounting Purposes states the public sector pension scheme liability and the underlying actuarial assumptions. Matched with the Public Sector Pensions Valuation Report as at 31 March 2016, the PSPA is of the view that an Actuary would be able to combine the information held in these reports and estimate the value of the liabilities on an insurance company buy out basis.
The PSPA would however clarify that all public sector pension schemes under the management of the PSPA are unfunded, “pay-as-you-go” schemes with any shortfall between income and expenditure being met by Treasury. Therefore, there are no assets held directly by the schemes in the way that private sector defined benefit schemes would have invested assets. The PSPA is not aware of any unfunded public sector schemes (of which there are several in the UK operated by the UK Government) being bought out via an insurance company as the physical cost to buy out the schemes and pay funds from IOM Government (or indeed any Government) to an insurance company to meet the liabilities, in the way you suggest, would be significant to the Government. In the case of the schemes managed by PSPA, the cost will likely be in the region of £4.3bn (2018-19 Government accounting pensions valuation). For this reason the IoM Government is unlikely to consider such an option. Public sector schemes under the management of the PSPA are managed in accordance with the Public Sector Pensions Act 2011 (the Act). Any changes to the schemes including how superannuation benefits are funded, must first be consulted upon with scheme members and their representatives and approved by Treasury and Tynwald. The Act does not allow a bulk buy-out of liabilities in the way you have outlined.

Please quote the reference number 1690745 in any future communications.

Your right to request a review

If you are unhappy with this response to your freedom of information request, you may ask us to carry out an internal review of the response, by completing a complaint form and submitting it electronically or by delivery/post.

An electronic version of our complaint form can be found by going to our website at https://services.gov.im/freedom-of-information/Review . If you would like a paper version of our complaint form to be sent to you by post, please contact me and I will be happy to arrange for this. Your review request should explain why you are dissatisfied with this response, and should be made as soon as practicable. We will respond as soon as the review has been concluded.

If you are not satisfied with the result of the review, you then have the right to appeal to the Information Commissioner for a decision on; 1. Whether we have responded to your request for information in accordance with Part 2 of the Freedom of Information Act 2015; or 2. Whether we are justified in refusing to give you the information requested.
In response to an application for review, the Information Commissioner may, at any time, attempt to resolve a matter by negotiation, conciliation, mediation or another form of alternative dispute resolution and will have regard to any outcome of this in making any subsequent decision. More detailed information on your right to a review can be found on the Information Commissioner’s website at www.inforights.im. Should you have any queries concerning this letter, please do not hesitate to contact me. Further information about freedom of information requests can be found at www.gov.im/foi.

I will now close your request as of this date.

Yours sincerely