How pension funds can find the route for members who moved abroad

A pension fund can find the route for a member who moved abroad by starting from the country the member moved to, not from the last address on file. For each country we cover, we hold the national pension authority, its contact, the official route from abroad where we have one, and the dated rules that can apply to someone who left. A fund sends us its list of gone-away members, and for each member we return that route with a dated audit trail. Names and dates of birth never reach our server. The service is described on our page for pension funds.

Why does domestic tracing stop at the border?

Tracing is an expected part of looking after member data. Among the controls The Pensions Regulator (TPR) expects administrators to run is "conducting regular data tracing and mortality screening exercises" (TPR, scheme member data quality, read 13 October 2026).

Much of the data behind domestic tracing is organised around domestic addresses, as we set out in our post on dashboards and gone-away members. Once a member has moved to another country, the new address sits in that country's systems.

The last resort in the UK has limits too. The Department for Work and Pensions forwards letters for pension companies, but its guidance says "Every effort must have been made to trace the person concerned before asking us to forward any letters" and that DWP "will not disclose information to the letter sender about any individual" (DWP, Bulk Letter Forwarding service guidance, read 13 October 2026).

So the useful question for a member abroad is a different one: in the country this member moved to, which authority holds the records, how is it reached from outside, and which dated rules apply to the years the member worked for the fund?

What does a fund send us?

One row per gone-away member, in a CSV file with these columns and no others: name, date_of_birth, country_moved_to, employment_from, employment_to, case_ref. That is the member's name, the date of birth, the country the member moved to, the employment period and the fund's own case reference. Name and date of birth may be left blank.

We do not accept national ID numbers, bank account numbers, IBANs or amounts. A file that carries any of them is refused whole, with a message for each row, and our server repeats the same checks on what it receives.

What do we return for each member?

For each row, we return:

• the country route from abroad, as our data states it, where we hold one;
• the authority in that country and its contact;
• the dated obligations that apply to the member's employment period;
• any written answer that authority has given us, with its date;
• an audit trail in which each step names its source and the date we read it, or says plainly that our data records no date.

A member who moved to a country outside our coverage comes back marked as not covered, and so does a country name we do not recognise. We make no guess. The results come back as a CSV file and a JSON file, keyed by the fund's case reference.

Why do names and dates of birth stay out of our server?

Because the answer does not depend on them. The route, the authority and the dated rules depend on the country and the employment period, so those are the only member details the lookup sends, together with the case reference. The list is read in the browser in which it is opened, and names and dates of birth are joined back there for the downloaded results. Nothing about the members is stored.

This follows the data minimisation principle, which requires personal data to be "adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed" (UK GDPR, Article 5, read 13 October 2026).

What is in place before real member data?

A signed data processing agreement between the fund and us. UK GDPR states that "Processing by a processor shall be governed by a contract or other legal act" that is binding on the processor with regard to the controller (UK GDPR, Article 28, read 13 October 2026). We sign that agreement before any real member data is used.

How is it priced, and how does a fund start?

The service is priced per engagement and agreed directly with the fund. We take no percentage of anyone's pension and no commission. A fund starts by writing to hello@pensionhunter.ai. Our page for pension funds sets out the service, and our page for trustees describes how we trace the members themselves across borders.

Frequently asked questions

Does the fund have to send names? No. Name and date of birth may be left blank. The lookup needs the country the member moved to, the employment period and the fund's case reference.

What happens to a member who moved to a country you do not cover? That member comes back marked as not covered, with no route and no guess.

Do you contact members? Not as part of this lookup. It returns the route, the authority and the audit trail for each member. Our trustees page describes our separate tracing work.

Do you give advice? No. We identify routes and authorities. Decisions about any benefit stay with the fund and the member.

Sources

The Pensions Regulator, scheme member data quality, read 13 October 2026.

Department for Work and Pensions, Bulk Letter Forwarding service detailed guidance, read 13 October 2026.

UK GDPR, Articles 5 and 28, on legislation.gov.uk, read 13 October 2026.