Standards webinar 1: introduction to standards and consultation

This was the first in a 3-part series of webinars to support our consultation on draft standards and guidance. This first webinar provided an overview of our standards, our consultation, and our proposed approach to governance of the standards. We introduced the consultation and provided an overview of what it is that we’re consulting on, explaining what the standards and guidance are and what they do.  We then outlined the materials we’ve published and what they cover and explained our proposed model for standards governance. 

These Q&A’s detail the questions asked by attendees and the answers given by the panel during the webinar.

Will you be publishing a response to the consultation?

Yes. It’s important the industry understands how we’ve reviewed and assessed your feedback and consultation responses.

Do we have to respond to all the questions in the consultation?

Not at all. We appreciate not all parties will be interested in all areas. It depends on the areas you are interested in.

Can I submit multiple responses if I am representing different organisations?

We’re interested in a range of responses, so this wouldn’t be a problem provided each response represented that organisation’s perspective.

Why are you running a call for input on the design standards as opposed to a consultation?

Primarily to fit around the FCA’s timetable and because we think it is important to get the industry’s feedback on such an important topic. This will also allow us more time for user testing. See webinar 3 for further details on design standards.

When will you be publishing the final standards?

We’re dependent on the regulations being approved in Parliament, formally delegating the authority to us to set these standards. Parliamentary time allowing, we expect that to be later this Autumn. We’ll then seek the Secretary of State’s approval immediately after and publish our final standards as soon as possible once we have that authority (except design standards, which should follow no later than Spring).

We’re a small pension scheme, there are a lot of standards here for us to implement – do we have to do them all?

First of all the new requirements apply to occupational schemes with 100+ members. The Government will consider the application of the requirements to the smaller schemes over the next couple of years.

In practice, we expect for most pension providers, the implementation of these standards will be undertaken by third parties who will connect to the ecosystem on their behalf, rather than the scheme connecting directly themselves. As the regulated entity to whom the standards apply the schemes will still be accountable for their compliance, but the third parties would be the ones actually implementing them.

Thanks to Chris for acknowledging that the consultation is running over the summer, and therefore not ideal timing! However, there was some criticism over the DWP regs consultation only being 6 weeks. This one is also only 6 weeks, with a call for input running concurrently. There is a huge amount of material to read through in the standards/ guidance. Was consideration given to a longer response time?

Yes we did consider the timing carefully, and would have preferred to give respondents more time. However, we think it’s important we consult in good time to allow the responses to the consultation to inform the further development of the standards. We have a narrow window within which to consult and then finalise the standards, to then publish the final standards as soon as possible once the legislation is in place. This will give industry the maximum lead-in time that we can to prepare for connection.

Also, as we acknowledge in the governance document, our standards will evolve over time in the light of experience. We’ve detailed our proposals about how we will approach any changes.

Congratulations on all these publications – great progress. The other really critical Standard, of course, is the revised Actuarial Standard TM1 from FRC. What news is there about FRC’s response to their February consultation on this? Maybe something for Tuesday’s webinar? Thanks.

Thanks. This is one for the FRC. We’re all working towards the same timetable – and that includes the FRC.

Where are all the standards documents and consultation published?

You can find all our standards consultation documents standards website pages.

Can you provide a document listing the modifications now being consulted on for data standards?

We’ve previously published data standards and have also published a summary of changes, which we hope is helpful.

DWP have recently confirmed some staging date changes. Do you know if FCA will be doing the same?

The FCA rules will reflect the DWP regulations. The Government placed a statutory duty on FCA to make rules for personal and stakeholder pension schemes, and this requires that FCA rules correspond with, and have regard to, the requirements placed on the trustees of occupational schemes by the Government’s regulations. The FCA will be publishing its final rules following the regulations being approved by Parliament.

Is there a plan in place for controlling the data quality at source (eg data providers)?

The government’s policy here is for the existing regulatory framework to apply here: that’s the oversight of the TPR/FCA and ICO. FCA and TPR will be publishing their details on their regulatory approach in the coming months.

When new documents or articles are issued is it possible to send out emails which have direct links to these items. This would save time navigating around.

You can sign up to receive our regular newsletter which always links to new content.

Thanks for a very helpful session. Is the PDP expecting to publish specific guidance on data protection? Particularly given the ICO’s comments in the DWP’s consultation response as to the requirement for a Data Protection Impact Assessment on matching criteria.

We plan to publish the relevant parts of our Data Protection Impact Assessment, for the processing of personal data by MaPS and our suppliers by the central digital architecture. We will also be updating our consumer protection pages explain how we’ve considered UK GDPR issues. The DWP will also be publishing its DPIA with the regulations. We hope these documents and publications will help participants to complete their own DPIAs. Both we and the DWP have been closely engaged with the ICO in the development of these DPIAs. We’re not planning to publish any specific data protection guidance for participants – all parties will need to ensure they comply with UK GDPR as well as the new dashboards duties.

The DWP and/or regulator may also publish guidance on matching. We’d also encourage you to read the PASA’s data matching conventions guidance.

How does one find a list of integrated service providers (ISPs)?

There isn’t a list. There is an evolving market and from what we hear there will be offers coming to market, which no doubt will be well advertised! We won’t be maintaining a central register.

You said there is a call for input on the design standards so I understand why it is called a scoping document. However the reporting standards document also says it’s a scoping document. Are the reporting standards a draft or is this still a scoping document?

The reporting standards are a set draft standards proposals. Like the other standards, except for the call for input.

Is there an accreditation scheme for those integrated service providers (ISPs)?

There’s no plans at the moment. But we know it is an area both the regulator and the DWP are keeping a close eye on.

We’ll be expecting pensions providers to carry out their own due diligence and we’ll be carrying due diligence checks to ensure ISPs meet our standards and also they have authority for their pension providers clients.

Apologies if this has already been covered, but will then be a release of changes between the draft standards and those published?

We will publish a formal formal consultation response, which will lead to the final standards with updates.