Safeguarding Policy

2. How We Identify Vulnerability

Vulnerability is not always obvious. Our staff are trained to recognise a wide range of circumstances that may indicate a client needs additional care or support. Indicators include, but are not limited to:

• Difficulty understanding, processing, or recalling written or verbal information
• Signs of distress, anxiety, or confusion about their own financial situation
• Expressed urgency that seems disproportionate to their circumstances
• Indicators of undue pressure from a third party — family member, carer, or otherwise
• Requests made on behalf of a client without clear legal authority or consent
• Communication suggesting bereavement, serious illness, or recent life crisis
• Literacy or language barriers that affect ability to engage with written materials

Vulnerability may be temporary, fluctuating, or permanent. We treat all situations individually and do not make assumptions. A client who has capacity to engage may still benefit from additional communication support.

3. Adjustments We Offer

We will make reasonable adjustments to the way we communicate and deliver our service. Clients may request any of the following at no additional cost:

To request any adjustment, email safeguarding@pensiontech.uk or call us on +44 1432 805386 (PensionTech — Hereford).

4. Power of Attorney & Court of Protection

Where a client lacks capacity to manage their own financial affairs, or has chosen to appoint someone to act on their behalf, we will work with the authorised representative provided they supply appropriate legal documentation.

4.1 Lasting Power of Attorney (LPA)

An attorney acting under a registered Lasting Power of Attorney (property and financial affairs) may engage our services and receive findings on behalf of the pension holder. We will require:

• A certified copy (or original for inspection) of the registered LPA
• Confirmation of the donor's name, date of birth, and pension scheme membership
• Contact details for the attorney

We will correspond with the attorney, not the donor, once authority is confirmed. However, we will take reasonable steps to ensure the donor's interests are protected and will not proceed where we have concerns that the attorney may be acting improperly.

4.2 Court of Protection Orders

Where a deputy has been appointed by the Court of Protection to manage a person's property and affairs, we will accept a certified copy of the court order as authority to engage on the pension holder's behalf.

4.3 General (Ordinary) Power of Attorney

A general power of attorney is only valid while the donor has mental capacity. We will accept this form of authority for administrative correspondence but will carry out additional checks if there is any indication of capacity concerns.

5. Family & Next-of-Kin Representation

A family member or trusted person may assist a client who retains capacity but wants support during the audit process. This is different from a Power of Attorney arrangement.

To authorise a representative, the pension holder must provide written consent — by email or signed letter — confirming:

• The name and contact details of the person they wish to involve
• The scope of authority (e.g. “to receive correspondence” or “to act on my behalf in all matters”)
• That they understand they may revoke this authority at any time by contacting us

We will not share personal data or audit findings with a family member or third party without this written consent, regardless of the relationship claimed. This protects the client from unauthorised disclosure and from potential financial abuse by people known to them.

5.1 Deceased Pension Holders

If you are enquiring on behalf of a deceased pension holder — for example as an executor or personal representative — please contact us at safeguarding@pensiontech.uk. We will ask for a copy of the death certificate and Grant of Probate (or letters of administration) before proceeding. We handle bereavement cases with sensitivity and without unnecessary delay.

6. Scam Awareness & Financial Abuse

Pension scams and financial abuse targeting older and vulnerable adults are serious and increasing risks. We take active steps to protect clients and to ensure our own service is never used to facilitate harm.

6.1 How to Recognise a Pension Scam

Warning signs that you may be targeted by a scam include:

• An unsolicited call, text, or email about your pension — legitimate organisations rarely contact you out of the blue
• Promises of unusually high returns, guaranteed income, or “risk-free” investments
• Pressure to act quickly before an “exclusive offer expires”
• Requests to transfer your pension into an unfamiliar scheme or overseas arrangement
• Someone offering to help you unlock your pension before age 55 (57 from 2028) — this is almost always a scam and may result in a large HMRC tax charge
• Anyone who claims to work with Pension Tech but does not use @pensiontech.uk email addresses

6.2 How We Protect You

• We never cold-call clients or contact you about your pension unless you have requested it
• We do not advise on, facilitate, or accept instructions involving pension transfers or investment arrangements
• We will decline to proceed if we believe a client is being influenced by a third party acting against their interests
• We train all staff to recognise and escalate suspected financial abuse cases

7. Reporting Suspected Abuse or Harm

Where a member of our staff reasonably suspects that a client is at risk of harm — whether financial, physical, or emotional — we have a duty to act. We will follow the procedure below:

7.1 Internal escalation

Any concern must be escalated immediately to our Designated Safeguarding Lead. The case will be documented, and a decision made on whether external reporting is required. We will not proceed with an audit if doing so could put the client at further risk.

7.2 External reporting

Depending on the nature of the concern, we may report to one or more of the following:

We will inform the client (or their authorised representative) that a report has been made, unless doing so would put the client at greater risk.

8. Sensitive Data Protection

8.1 What We Collect

To carry out a pension audit, we may collect and process the following categories of personal data:

• Full name, date of birth, and National Insurance number
• Employment history, start and end dates, and pensionable service records
• Pension scheme membership details and scheme reference numbers
• Annual benefit statements, service extracts, and pension projections
• Details of career breaks, maternity/paternity leave, or part-time working patterns
• Transfer records and previous pension arrangements
• Health or disability information, where relevant to an ill-health pension or injury award (with explicit consent only — see our Privacy Policy)

8.2 How We Protect It

• All data is transmitted and stored with AES-256 encryption
• Access to client data is restricted to authorised staff on a need-to-know basis
• We do not sell, share, or transfer personal data to third parties except where required to deliver the audit service
• All systems are subject to regular security review

For full details of how we handle personal data — including your rights under UK GDPR — please read our Privacy Policy.

9. Scope of Service & Non-Advice Boundary

PensionTech provides pension audit and analysis services — we identify and report on potential errors, omissions, and discrepancies in pension records based on the documents you provide. Our work is informational only.

We do not provide financial advice, pension advice, investment advice, or any other regulated activity as defined by the Financial Services and Markets Act 2000. PensionTech is not authorised or regulated by the Financial Conduct Authority (FCA).

Clients are strongly encouraged to consult a regulated Independent Financial Adviser (IFA) before taking any action based on our audit reports — including raising corrections with their scheme, transferring benefits, or making retirement decisions.

For vulnerable clients or those at particular financial risk, this recommendation is made explicit within our written findings.

10. Staff Training & Competence

10.1 Induction training

All staff who handle client data or interact with clients directly must complete the following before doing so:

• UK GDPR and Data Protection Act 2018 awareness training
• Safeguarding and vulnerable client awareness
• Information security and data handling procedures
• Pension scam and financial abuse awareness
• PensionTech code of conduct and ethics policy

10.2 Ongoing training

Training is refreshed [PLACEHOLDER: annually / every 18 months] or whenever material changes to regulation or best practice occur. Staff are expected to:

• Stay current with ICO guidance and FCA Consumer Duty principles
• Report suspected data breaches or safeguarding concerns to the Designated Safeguarding Lead immediately
• Participate in periodic case reviews and quality assurance exercises

10.3 Designated Safeguarding Lead

PensionTech maintains a Designated Safeguarding Lead responsible for oversight of this policy, staff training, escalated concerns, and reporting obligations. Safeguarding concerns — whether about a client or about a member of staff — may be raised confidentially at safeguarding@pensiontech.uk.

11. Policy Review & Contact

This policy is reviewed annually and updated whenever significant changes to law, regulation, or best practice occur. Significant updates will be communicated to all relevant staff and reflected on this page with an updated “Last reviewed” date.

Any client who has a concern about their treatment, the conduct of a member of staff, or how their data has been handled should contact us in the first instance:

If your concern is not resolved to your satisfaction, or if it involves a data protection matter, you may escalate to the Information Commissioner's Office: ico.org.uk • 0303 123 1113.