Pensions dashboards progress insights – April 2022
Chris Curry, PDP Principal, discusses some of the areas of programme progress that the PDP progress update webinar panel elaborated on, following the publication of the April 2022 progress update report.
The Pensions Dashboards Programme published its fifth progress update report on 27 April, which covers the programme’s progress over the previous six months. On the same day, I hosted a webinar to elaborate on the contents of the report, alongside Richard James, PDP Programme Director and Lucy Stone, Business Lead at The Pensions Regulator (TPR). We had some great questions, following our presentation, so I’ve picked out some of the themes that emerged in this blog.
Advice on preparation for connection to pension providers and schemes
The overall message from the panel was that pensions dashboards are coming – and soon. The digital build is almost complete, with the first volunteer providers on the verge of connection as part of the extensive testing of the digital ecosystem. This means that pension providers and schemes need to move fast, if their preparations are not already underway.
There is a lot of information already available about how to prepare for dashboards. PDP has published information on its data providers hub and dashboard providers hub on the steps to connection. DWP’s consultation detailed the proposed connection (staging) deadlines. These will be confirmed later in the year but they give a good idea of when providers need to be ready.
While the work to produce final standards is ongoing, a lot of the material is fairly mature, so there is a clear indication of what work will be necessary prior to connection. In particular, we’d advise providers to focus on getting their data into shape and examining their own IT development and building that into business planning cycles, so the necessary resources will be available at the right time.
Timelines: DWP consultation, staging deadlines and consultation on standards
The Department for Work and Pensions (DWP) is due to publish its response to the consultation on Regulations this summer. PDP is not in a position to anticipate what their response will be to questions around the timings of connection (staging) deadlines and requests for additional preparation time. If the DWP consultation leads to any big changes in the proposed Regulations, we’d expect to see that change reflected in their response, in order to allow providers sufficient time to prepare.
PDP will issue a consultation on the draft standards for dashboards following DWP’s response to the consultation.
The standards themselves will supply detailed technical guidance about what data will be on dashboards. We’ve already published early versions of these standards, which supply pension providers with a lot of information to prepare for connection.
We’d advise all pension providers and schemes to familiarise themselves with the proposed staging deadlines in the original consultation and start to prepare for these connection (staging) deadlines now. If they subsequently move further out – you lose nothing by being prepared for the earlier date.
ISP market development
TPR’s Lucy Stone confirmed that ISPs will play a crucial role in connecting smaller and medium-sized providers to dashboards, so the regulator is actively monitoring the emergence of the market.
Altus-ITM has announced its offering and we’re in conversation with a good number of organisations that are planning to enter the market. We can’t anticipate the announcements that are likely to come from these organisations but we anticipate that there will be sufficient capacity within the market to support connection to the pensions dashboards ecosystem.
Providers and schemes will receive multiple fields of data from the dashboards ecosystem and will match across multiple fields – PDP’s data usage guide provides more detail on this. Individual providers and schemes will be able to decide which fields to use for matching – so, if they are not confident in the data quality of a particular field, they can choose to use alternatives.
Richard James explained that checks performed by the identity service, within the pensions dashboards ecosystem, will verify the identity of the savers using pensions dashboards. Providers can be confident that the information that comes into them from the pensions dashboards ecosystem is correct. The savers really are who they say they are.
However, it is the responsibility of pension providers and schemes to maintain accurate records, which will give rise to accurate matches with the data received from the pensions dashboards ecosystem. Lucy Stone reminded the webinar audience that TPR set out its expectations with regard to record keeping and data quality in 2010.
There are existing tools to support with improving data: TPR provides guides on how to measure and improve data quality. PASA also provides a guide on how to improve data quality and identify issues with key areas, such as date of birth, NI numbers and so on.
PASA has also produced a guide on matching conventions, which provides further information.
A partial match is when a data provider (ie a pension provider or scheme) reviews the data they receive from the pensions dashboards ecosystem and thinks they may have a matching pension on their system without being sure. An example of this could be that the forename, surname and date of birth match but the address provided is different, potentially because the saver hadn’t updated their address details with the provider.
In this instance, the digital architecture supports the provider to return a partial match to the saver’s dashboard, which supplies the provider’s contact information. That way the saver can call up and establish, whether or not they are the pension owner.
Over time, this should reduce the number of partial matches. Pension providers can update their data following confirmed matches, as well as re-establishing contact with lost savers.
Building the algorithms that identify partial vs full matches
The digital architecture will support the return of both full and partial matches. But the question of how to design the algorithms that will find those matches and give providers maximum confidence that they have achieved a match will rest at the data provider level (ie either the ISP or individual provider or scheme).
Storage of data within the pensions dashboards ecosystem
Personal data relating to savers will not persist within the pensions dashboards ecosystem. The data relating to requests will be anonymised in a pensions identifier, so that none of that data stays within the system itself.
However, PDP recognises there is a use case for onward journeys that will allow consumers to act on the information that they receive via dashboards. Work on onward journeys is ongoing and the FCA will consult on this, later this year.