Dashboards are an innovative, consumer-focused project. This can be seen from the original Department for Work and Pensions (DWP)’s consultation on pensions dashboards, which listed a number of policy objectives for pensions dashboards. Principally, this included connecting people to their pensions and enabling them to access their pensions information all in one place, and re-connecting them with lost pension pots. In addition, the DWP’s consultation highlighted the aim for pensions dashboards to:
- increase awareness and enable people to understand their pension information
- increase consumers’ sense of ownership and control
- increase consumers’ confidence
- increase consumer engagement, and increase take-up of advice and guidance
- empower people to make more informed choices by making it easier to access the information on which to base decisions
We believe these consumer-focused aims coalesce into the overall benefit of enabling individuals to access their pensions information online, securely, and in one place. This will support better planning for retirement, and grow consumers’ financial wellbeing.
All of which makes consumer protection fundamental to the programme. Consumers must be able to trust that the system itself is secure, before accessing potentially sensitive personal information. Failing to ensure adequate consumer protection, within the pensions dashboards ecosystem, would endanger consumers’ trust in the entire project.
As such, we have frequently referenced the importance of consumer protection to the programme in earlier publications. This content aims to draw together an overview of where consumer protection informs and influences our activity across the programme, in order to deliver a trustworthy service for consumers. We also touch upon some of the consumer protection activity beyond the programme and indicate where it falls under the remit of other dashboard delivery partners.
What is consumer protection?
In the context of pension dashboards, we define consumer protection as action to minimise consumer detriment, including both prevention and remediation/redress for consumers if things do go wrong, which therefore fosters consumer confidence in dashboards. It covers the design and operation of the ecosystem itself, compliance with existing and new regulations, rules and standards, as well as the context within which consumers will use dashboards.
PDP aims to deliver a service, in line with the DWP’s consultation response, where the dashboards ecosystem puts:
“… the interests of consumers first so that the risk of any poor outcomes is minimised”
At PDP, we work within the boundaries set by existing legislation, including the UK General Data Protection Regulation (UK GDPR), which regulates how personal information may be processed and shared.
PDP is directly responsible for providing the digital architecture, ie the central elements that make dashboards work, such as the pensions finder service, consent and authorisation service, identity service and the governance register. PDP is also responsible for the overall ecosystem design and associated standards. We will follow the design principles set out in DWP’s consultation to:
- put the consumer at the heart of the process by giving people access to clear information online
- ensure consumers’ data is secure, accurate and simple to understand – minimising the risks to the consumer and the potential for confusion
- ensure that the consumer is always in control over who has access to their data
PDP sits at a nexus between government, the regulators and industry and our work to protect consumers takes place in concert with our delivery partners. We will communicate directly with consumers about the protections woven into dashboards in the future, as the programme matures and we gain further insight from our own research. Currently, we’re focusing on learning from our counterparts in the pensions industry, with their existing understanding of their customer base.
While we can do everything possible to minimise any risk to consumers within the pensions dashboards ecosystem itself, we cannot control what consumers do following receipt of information about their pension(s). However, our colleagues in the Money and Pensions Service (MaPS) are putting significant efforts into designing onward journeys towards further guidance for dashboard users around managing their pensions. There is more information on MaPS activity in our page on organisations responsible for consumer protection.
For further information on the potential consumer harms and the action that PDP and others are taking to mitigate those risks, access the pages below.