Our Approach to Data Integrity

Data Principles

CEM is a leading data and insights firm. For us high data integrity is non-negotiable.

Our data strategy is built upon the core data principles shared below. These interconnected principles are our north star and, as such, guide all of our efforts. The principles are owned by our internal data governance committee and revisited at least annually.

Our execution is based on three pillars: industry standards called the Global Reporting Principles (GRP), assessment of data integrity by institutional investor, and investments in our team and internal processes. CEM has an expert team with over 30 years of experience, employing custom systems and processes to identify and rectify data issues and ensure high-quality data for our institutional investors. We also actively seek client input, so that we can improve our practices.

Our Data Principles

Our data integrity efforts are based on the following interconnected principles:

Completeness

While our preference is that all data is provided by institutional investors, we recognize that this is not always possible. To be included in the CEM database, the data must be unambiguous. We must be able to interpret the information provided with context. Where we have incomplete data sets, we observe the following:

- We treat incomplete data as missing, rather than as zero or non-existent. Only where needed, we enrich the data.
- We only construct benchmarks from complete, known, and relevant data points that do not require enrichment.

Comparability

We present all data and insights in a consistent context, across all key dimensions of comparison. Where there are unavoidable differences, we call them out.

Accuracy

We validate all data using a combination of our proprietary tools and expertise. If in our professional judgment specific data points are not of sufficient quality, we do not use them.

Confidentiality

We ensure that individual non-public data cannot be read nor derived from publicly available CEM materials or CEM reporting, current nor legacy. Any non-public, client identifiable information that is shared is only done so with explicit client consent.

Providence

While we encourage client commentary, we hold ultimate decision rights on the structure of our analyses and application of data within them.

Timeliness

We provide insights on a timely basis, corresponding with the provision of the data from a client and its peers. We take all necessary steps to provide reliable delivery dates.

Transparency

We disclose all areas where we have enhanced and/or enriched data, including providing a summary of the approaches, and the sources of the data used for the enhancement/enrichment.

Security

We take industry-standard precautions to ensure all data is protected from potential threats. If/when there is an incident, we act with pace, discipline, and open communication.

These principles are owned by CEM’s Data Governance Committee, which comprises a group of CEM’s senior leaders and data experts. They are reviewed at least once a year.

Living our Data Principles

We proactively action our data principles through:

- Global Reporting Principles for the Investment Industry
- Data Integrity Scores for Individual Institutional Investors
- Processes & Experience for CEM Team Members

Below, we dive into each application separately.

Institutional Investor Industry

In 2022, we undertook a multi-year effort to create CEM’s Global Reporting Principles (GRP). These principles were launched in 2024.

Prior to creating GRP, we observed that standards and templates exist in specific countries, like Australia, the Netherlands, and the UK. However, the global institutional investment industry lacked a single consistent set of principles that span performance, cost, and timing. We worked with seven leading global pension funds to create these principles. The complete list of GRP principles can be found here.

CEM’s Global Reporting Principles will evolve over time. The release schedule was designed to allow for both feedback from market participants as well as for institutional investors to develop the systems, data, and personnel to action. The future releases, currently slated for 2026 and 2029, are shared here.

The elements of GRP that pertain to public reporting have been connected to the Global Pension Transparency Benchmark. This benchmark assesses the efficacy of the public reporting funds in fifteen countries against four factors: Performance, Cost, Responsible Investing, and Governance. More details on the GPTB can be found here.

Finally, we periodically do bespoke research on data quality-related topics for the benefit of the industry. Our publically available research papers can be found here.

Institutional Investors

For over 30 years, institutional investors globally have provided fund cost, performance, and structure data to CEM. We carefully assess the quality of the data provided, using a combination of data rules and deep expertise. More detail on the process is available in the “our team” section.

In 2024, we started quantitatively assessing the quality of the data provided by each CEM-defined benefit pension fund client. We assess each client’s data set using the following rubric and provide a summary of the performance data, cost data and timeliness. Institutional investors are invited to review the data scorecard and make improvements. The data assessment is being beta-tested in 2024. An example of a scorecard can be found here.

Our Team

CEM’s data principles have been connected directly to our systems, processes, and training. Here are the seven steps our team takes to validate the data:

Finally, we retain a leading third-party cybersecurity firm to conduct an annual information security assessment on our systems and processes. All high and medium-risk items identified in the last assessment have been fully addressed.

Should you have any questions or comments on our data integrity efforts, please contact us at product@cembenchmarking.com.