Pensions Bulletin 2026/07
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This edition: ICO guidance on handling data protection complaints and Alphabet’s new 100 year bond to impact company pension figures.
ICO guidance on handling data protection complaints
The Data (Use and Access) Act, which received Royal Assent on 19 June 2025 (see Pensions Bulletin 2025/25), introduced reforms to the UK’s data protection framework intended to be phased in between June 2025 and June 2026.
Although not pensions specific, some aspects of the new legislation and associated guidance produced by the Information Commissioner’s Office (ICO) affect how pension schemes operate in some areas.
One such area is that with effect from 19 June 2026 all organisations must have a process for handling data protection complaints. The ICO has now produced practical guidance to assist data controllers (such as pension scheme trustees) with meeting this requirement, setting out among other things: what constitutes a data protection complaint, actions required after such a complaint is received, how to comply with the requirement to give people a way to complain, and the timeframes within which to handle the complaints.
Comment
The guidance provides helpful practical advice to assist data controllers in preparing to meet their legal obligations in this regard, within the relevant timescales, in advance of the requirements actually coming into force. The ICO views much of what is suggested as good practice anyway, so hopefully these new requirements will not be unduly onerous to comply with.
Alphabet’s new 100 year bond to impact company pension figures
On 13 February 2026, Alphabet (Google’s parent company), issued over £5bn worth of corporate bonds in Sterling, including an ultra-long dated bond with a 100 year term, maturing in 2126.
When companies sponsoring pension schemes measure their liability values for their annual reports, they use yields on high quality corporate bonds to set their discount rates. Alphabet have now, for the first time, issued high quality corporate bonds in the UK. In doing so they have immediately become one of the most important issuers of such bonds in the UK, especially for bonds of long term. This issuance will therefore affect how companies reporting long-term pensions obligations set their discount rates, and consequently affect their reported figures.
Comment
The amounts being spent on AI data centres by Google, alongside others such as Microsoft and Amazon, are colossal, in the hundreds of billions of dollars. The borrowing to fund this enormous spending will have impacts felt around the world – including on the pensions figures of companies sponsoring UK pension schemes. If Google and their peers continue to increase their spending and borrowing through the AI boom, we can expect this influence to only increase.
The impacts on company pensions figures will vary depending on the methods used to set discount rates – a variety of approaches are used in the industry and by auditors. Companies should consider their positioning carefully.
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