Pensions Dashboards Delay: Less risk in rollout

09 Mar 2023

The day one reaction to pension minister Laura Trott’s announcement about the delays for pensions dashboards was understandably one of frustration. But on calmer reflection, it is a decision that will bring us some benefits and had probably become inevitable. It will give more time for us to build good systems, and more time for pension schemes to choose an intermediary ISP to connect through.

The political pressure to deliver this summer’s deadline for large schemes and personal pensions to be connected up was just too great. The right to left planning had led to a number of project stages that should have run sequentially instead being stacked up and run in parallel. It had become like a building site with too many of the trades working on the same piece at the same time, and the member experience was suffering.

An example of the sort of problem that the designers were encountering is what happens downstream after a member gets told that they are a potential match, that they might have a pension at scheme B and need to contact them to discuss further. Many of these matches will turn out to be 'false positives', but there was only a strictly time limited patch in place to remove these people from the system. They would soon find, on a return visit to a dashboard, that they were again told they might have a pension at scheme B. That’s a bad consumer journey, and would discredit the dashboard and create tension and loss of trust with pension savers.

Dashboards are too important a part of the drive to greater member engagement to jeopardise them like this. The whole ecosystem is also an enormous data security risk, and in an age of increasingly frequent cyber attacks we must ensure all data aspects are rock solid before we let the enquiries commence.

We certainly do not want lists of pension member details appearing in the Moscow Times, as that would really embarrass our country.

National Insurance numbers are key

I am hoping that the reset will give an opportunity for the Dashboards Programme to grasp what an integral part of UK pensions national insurance numbers are. I think that everywhere I have worked in pensions, national insurance numbers have been a key part of a customer’s record. But the enquiry system was being built with national insurance numbers as an optional field that the customer might include if they felt like it, and even if they did include it, this would only be self-declared and not confirmed by the verification systems that dashboard users will go through.

And schemes were getting no help from HMRC either – it really should be possible for a pension scheme with some missing national insurance numbers to have help from HMRC filling those important gaps in their database.

It is not all doom and gloom. As an integrated services provider, Dunstan Thomas has had privileged access to the Money and Pensions Services' dashboard team and we have found that they have many talented and genuinely helpful people on the programme. Dashboards will eventually emerge from this elongated pupal stage as an even more beautiful butterfly than we had hoped.

In re-setting the dates, the minister must accept that some questions will only be answerable in live running. The volumes of dashboard enquiries is one of those unknowns, and we will only hit peak volumes some time after launch when a popular TV programme encourages consumers to give them a go. In the meantime all we can do is to build in a scalable modular fashion, so that we ensure schemes meet their statutory duties even in the face of an avalanche of enquiries.

Delays or no delays, one of the things I like about large projects is the way they develop their own language. I can stand next to an engineer in the office kitchen and find them enthusing about their cocoa testing. But of course that's not a hot chocolate beverage, it’s the conformance and compliance testing they must go through before the Pensions Dashboards programme will allow them to connect to the live environment.

Dunstan Thomas launched its new Pensions Dashboards ISP solution called Imago Connect in October 2022. The first Qualifying Pensions Dashboard Service (QPDS) should be authorised by FCA and connected to the Pensions Dashboard Programme central digital architecture to begin end-to-end testing with real pensions data, by the end of this year. Imago Connect has been designed and built to enable all types of pension providers to meet their pension dashboard obligations in a straight forward and cost effective manner, whilst remaining fully compliant.

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