Originally due to launch in 2019, the Pensions Dashboards programme is already a little behind schedule! However, momentum is building and everything is currently on track to land this behemoth of a programme, with staged compulsory onboarding due to commence in the spring/summer of 2023.
With 2 years to go, what can you as pension schemes & providers be doing now to prepare on getting your data fit and ready?
Having spoken to a few in the industry, some are currently taking a watching brief – it’s on their radar, they know it’s on the horizon, but they’re not actively preparing. And whilst there are still lots of questions to be answered before schemes and providers can get stuck into detailed preparations, now is the time to get the ball rolling.
It’s all about the data….
Firstly, ensure you understand the PDP Data Standards Guide published in December 2020. From there, you can establish what’s in and out of scope in terms of the ‘find’ data that you’ll need to match on and ‘view’ data you’ll need to provide, including what’s mandatory, conditional and optional.
The pension finder service will provide find data attributes to the provider. But it’s up to you as the provider to determine the matching rules that you want to apply, based on your knowledge of what data you hold and how accurate it is.
From my experience, it’s good housekeeping to audit and catalogue all of your data so you know what you’ve got where, which elements are relevant for use within Pensions Dashboards. Importantly, do they meet required data integrity standards for use or is action required to data cleanse?
To help get you started, I’d recommend you look at your data from the following angles:
- Prioritising: Concentrating first on the find data attributes that you intend to base your matching rules on, and the view data items which are mandatory.
- Off-system data: Where is your data held and how accessible is it? This is one of the key considerations as you’re likely to have to provide responses in real time.
- Data integrity: Getting your existing records cleaned up. This includes:
- Ensuring data is accurate & up to date
- Identify any missing data gaps
- Highlight business, calculation and mapping rules for deriving or defaulting response data values
- Storing responses: You may wish to consider storing the results of all view/response data in case of future queries from members around what they’ve received.
- Out of scope records: Consider how to exclude such records, perhaps by setting and maintaining an in scope or out of scope indicator on each record.
You don’t need to fix absolutely everything in order to support PDP. Prioritising the data needs mentioned above would be a positive step in the right direction. In my view, it’s important to not only consider what needs to be done to fix existing data held, but also what is required to keep that data correct and up to date on an ongoing basis.
It will be compulsory to connect to PDP and this will be enforced by the FCA (for providers of personal and stakeholder pensions) and TPR (for occupational pension schemes). This should provide sufficient justification to start actively preparing your data.
As a next step, I’d also suggest you consider what impact Pensions Dashboards may have on your business and operational processes. Usage of Pensions Dashboards may result in an increase in queries regarding members pensions, pension claims and transfer requests, that you will need to provide increased operational resources to support. Additionally, you may need a new process to deal with partial match referrals.
Yes there are still questions to be answered that may limit how far you can go at this point, for example how will partial matches be handled and who will be responsible for data breaches or inaccuracies. However, I believe the programme have shared sufficient information to enable schemes and providers to make a solid start in their preparations now.
If you need support in getting your data ready to connect to Pensions Dashboards, we’d love to speak to you to discuss how we could help, so please get in touch at email@example.com.