Data Integrity at CEM

CEM is a leading data and insights firm. For us, high data integrity is non-negotiable. Our data strategy is built on a set of core principles that serve as our north star, guiding every decision we make. These principles are owned by our CEM’s Data Governance Committee and revisited at least annually.

CEM's data principles:

Completeness

We treat missing data as absent rather than zero, and only build benchmarks from data points that are complete and require no enrichment.

Comparability

All data and insights are presented in a consistent context across every key dimension, with any unavoidable differences clearly flagged.

Accuracy

Every data point is validated through our proprietary tools and expert judgment, and excluded if it doesn’t meet our quality threshold.

Confidentiality

Individual, non-public data cannot be read or derived from any CEM materials, and identifiable information is only shared with explicit client consent.

Providence

We welcome client input, but CEM retains final decision rights over how data is structured and applied in our analyses.

Timeliness

We deliver insights in step with when clients and their peers provide data, and commit to reliable delivery timelines.

Transparency

Wherever data has been enhanced or enriched, we disclose it fully, including the methods used and the sources drawn upon.

Security

We apply industry-standard protections to all data, and respond to any incident with speed, discipline, and open communication.

Based on these principles, our execution rests on three pillars: industry-wide standards through our Global Reporting Principles (GRP), individual data integrity scores for each institutional investor, and ongoing investments in our team and internal processes. With over 30 years of experience, CEM employs custom systems and processes to identify and resolve data issues — always in close collaboration with our clients.

Our execution rests on three pillars: industry-wide standards through our Global Reporting Principles (GRP), individual data integrity scores for each institutional investor, and ongoing investments in our team and internal processes. With over 30 years of experience, CEM employs custom systems and processes to identify and resolve data issues — always in close collaboration with our clients.

01
Global Reporting Principles for the industry
 
02
Data integrity scores for individual institutional investors
 
03
Processes & experience for CEM team members
 

01. Global Reporting Principles for the industry

In 2022, CEM embarked on a multi-year initiative to develop the Global Reporting Principles for the investment industry. Launched in 2024, these principles address a critical gap: while reporting standards existed in specific countries like Australia, the Netherlands, and the UK, the global institutional industry lacked a single consistent framework spanning performance, cost, service and timing. We worked with seven leading global pension funds to create these principles.

Principles Investments Pension Administration
1. Disclose asset value on the appropriate basis for calculating costs.
2. Disclose costs that are offset against revenues.
3. Look through and include costs incurred in all investment tiers.
4. Disclose costs for the same period in which performance is delivered.
5. Include indirect taxes that are implicit in the price of a product or service in total costs.
6. Include non-recurring costs in total costs.
7. Include costs incurred by related parties in total costs.
8. Disclose costs in your local currency.
9. Disclose investment costs and performance by composite or mandate.
10. Disclose if returns are fully gross-of-fees or, if not, disclose what costs are netted from the return.
11. Disclose time-weighted returns.
12. Use appropriate benchmarks.
13. Returns for less than one year must not be annualized.
14. Disclose key member service performance metrics.
15. Use and explain estimates when alignment to these principles is neither practical nor timely.
16. Disclosures should be available for stakeholders in time to fulfill their reporting and decision-making needs.

02. Data integrity scores for institutional investors

For over 30 years, institutional investors globally have provided CEM with fund cost, performance, and structure data. We carefully assess the quality of this data through a combination of validation rules and deep subject-matter expertise.

In 2024, we began quantitatively scoring the quality, completeness and comparability of data provided by each of CEM’s defined benefit investment benchmarking pension fund clients. Each client receives a scorecard covering performance data, cost data, and timeliness — and is invited to review their results and make improvements. 

In 2026, the scoring has been expanded to CEM’s Defined Contribution Investment Benchmarking clients as well as Defined Benefit Administration Benchmarking clients. The scoring will evolve over time, based on market feedback and allowing institutional investors time to develop the systems, data, and personnel needed to act. 

03. Our team's seven-step validation process

CEM’s data principles are embedded directly into our systems, processes, and team training. Our data experts apply a seven-step process to validate all incoming data:

  1. Initial data intake and onboarding checks
  2. Application of automated validation rules and custom data tools
  3. Expert review by experienced CEM analysts
  4. Identification and flagging of anomalies and outliers
  5. Client follow-up and clarification where needed
  6. Enrichment or exclusion of data based on defined criteria
  7. Final quality sign-off before inclusion in benchmarking

In addition to these internal measures, CEM retains a leading third-party cybersecurity firm to conduct an annual information security assessment. All high and medium-risk items identified in the most recent assessment have been fully resolved.

Questions or feedback on our data integrity approach? We'd love to hear from you. Contact Us: product@explorecem.com

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