The Pensions Dashboards Programme (PDP) recently announced the seven major pension organisations to be successfully recruited to the initial alpha test phase. Implementation of dashboards will be like automatic enrolment i.e. in stages starting with the largest schemes in Spring 2023. Master trusts are also proposed to be the front runners in the roll out of the forthcoming legal duties.

Like an authentic risotto, it takes time for the rice to absorb all the goodness. The importance of getting the recipe just right shouldn’t be underestimated as it materially affects the end result; plump, rich rice with lots of flavour or something resembling a bad rice pudding?

The pressure is on with multiple stakeholders having to play their part to make dashboards work and enable us to view all our pensions online, for the first time - exciting!

So, what’s the recipe? Who and what’s involved?:

·      Dashboard providers: the organisations which will operate pensions dashboards

·      Data providers: including pension providers, pension schemes, integrated service providers and other agencies supplying data, such as the DWP for State Pensions data

·      Digital architecture: everything which will make dashboards work i.e. the Pension Finder Service, consent and authorisation service, identity service, and the governance register

·      The pensions dashboards ecosystem: the overarching system where multiple parties, technical services and governance connect and collaborate to deliver dashboards

·      The legislation and rules: a complex recipe in itself; comprising a blend of new secondary legislation, cross referenced to existing legislation such as UK GDPR and

Disclosure, and new FCA rules and revisions to SMPI standards

·      The new suite of standards: required to underpin legislation so industry knows the details of data provision, connectivity rules and design standards for the customer facing dashboards themselves

Every element must work for dashboards to be a success. Like with our risotto, forgetting the stock means the recipe will fail, pensions dashboards needs us to get all the elements working together properly.

We can spend all the time we want deliberating over which ingredients to add to a risotto, but you have to start with good quality rice. The same is true for dashboards, at its heart they need good quality data. The absolute bottom line to enable all the elements to work is data and what does data rely on? Top quality stock - sorry -top quality administration. The two are interdependent: quality data relies on quality administration and quality administration relies on quality data.

It’s a well-recognised challenge all the data needed to feed into the pensions dashboards ecosystem isn’t in the best shape. Pension schemes and providers have got their work cut out to cleanse and improve their data so it’s ready for when dashboards land.

Master trusts have the additional challenge of wrangling multiple sources of data into their scheme. Just because Master trusts had an additional layer of regulatory approval to go through, doesn’t necessarily make this any easier.

The dashboards challenge brings the issue of quality data front and centre in an always-on world. It also introduces new data processing into the administration practice, in the form of ‘Matching’.

Matching is the automatic process which will need to be introduced for a search request from the Pension Finder Service to be received and compared to the records your scheme holds to see if there’s a match. This will be part of the new legal duties. Of course, existing legal duties under UK GDPR are still binding too.

Schemes need to work with their data controllers to understand their data quality and understand the choices they need to make when deciding which of these data items they are confident on matching. Master trusts will have many stakeholders to consider here.

Thankfully, our colleagues in the PASA Pensions Dashboards Working Group have been rustling something up in their kitchen. They have worked cross-industry to deliver an initial draft of guidance for Data Matching Conventions - give it a read and start engaging with your suppliers.

So, just like any delicious risotto, dashboards have taken time and are a complex recipe involving many important ingredients, but it’ll be worth the wait. Now where’s that stock…?