This is the vision of the dashboard we sign up to – if we accept the Government consultation
An alarming diagram that shows how a single pension finder would control all data on the dashboard pic.twitter.com/qIo3muL6cn
— Pension Plowman (@henryhtapper) December 19, 2018
Close inspection shows that the pension finder is infact the only game in town, it is the way , the truth and the life for pension savers.
The diagram is not the one that appears in the Pension Consultation to describe the dashboard architecture, that one’s sanitised.
Here the architecture does not appear so brutal but it is the same.
Because the Pension Finder incorporates the identity service, no data can flow to the dashboards from the providers (down the bottom unless the request has been verified by the identity service . This is what is meant by the interface that “authorises subsequent access”,
The biggest land grab since Lebensraum
But the grand design of the single pension finder service is seen more ambitious. According to a document I was provided by one of candidates for the pension finder service (PFS), its key features will include
- A single point of integration for Dashboards, Providers and other entities that are approved to participate in the Dashboard System
- A trust anchor for consumer and delegate authentication , (a trust anchor is an authoritative entity for which trust is assumed and not derived- Ed) in this instance the PFS authenticates who is sending messages.
- A cost effective and and effecient service for orchestrating the “Find of Pensions and authorising subsequent access to the Pension data that has been found (eg for valuations)
- A centralised consumer consent process for authorising access to their data for both Dashboards and delegates (e.g. Financial Advisers) who request access to the consumer data
- The foundation for an Industry Attribute Hub that will initially provide the “find” of Pensions and atomisation services and which would also be extended to cover other long-term savings produce and business processes where attributes need to be found and shared
Let me re-word these points to make it clear just what they imply
Those awarded the PFS contract will
- Be in control of the integration of all parties participating in the dashboard
- Control the messaging between them
- Have control of all data requests for values and other consumer information
- Control delegated authorities (note these are already defined as to Financial Advisers)
- Have rights to unlimited scope creep into ISAs and anything else that the PFS wishes to annexe.
There are many more pages of bullets outlining the Proposed Approach how the Trust Anchor would work, how delegate authorities would be controlled and how a single PFS is “robust, flexible and future-proof”. I would share the presentation but I was only handed it in paper format.
The presentation ends with a number of diagrams that show how untenable anything but a single pension finder service is. There is even a table showing feature by feature how open pensions are incompatible with open banking’s architectural features.
It is clear that as much distance must be placed between open banking and open pensions as possible. If we were to apply the experience of open banking to the pension dashboard we would not start with a single PFS but with multiple comprehensive PFS’.
Come off it!
I don’t pretend to understand all the technology at play here, but I can see a land-grab and I know what happens when you grant a licence to control everything to one organisation.
The arguments put forward to support a monopoly are all spurious – all taken from the project fear manual and none based on the evidence of Open Banking.
A single PFS would speed things up
Remember the space race? The only way you get a race is with runners, giving one organisation a monopoly wouldn’t make for a race, it would make for a CrossRail style cock-up.
A single PFS would be more secure
The presentation suggests that a single PFS would provide the “narrowest attack vector” and that increasing the numbers of PFS would “widen the attack vector”. I have no idea why this is, it simply appears to be ripped from the “Project Fear” manual.
A single PFS would be cheaper
Multiple PFS would multiply the costs , the cost of assurance would increase as there would be multiple costs of assurance, multiple consents would increase complexity and therefore cost. Again I can see no reason why any of this should be true
A single dashboard would be more complex
This is based on there being a phased approach to the introduction of dashboards, There is also an argument about consistency – where one dashboard could produce different results than another, there is another argument that proliferation of dashboards would present issues for funding . All of these arguments come from deep within the manual of project fear but don’t stand up to any scrutiny in a digital world.
Freedom from Complete Control
If you think that giving one organisation total control over all the data that flows through the dashboard you have a different view of competition and markets to me.
Doing so risks
- being held to fortune on delivery timescales
- outage of the service with no back up
- no protection over cost over-runs
- being at one organisations mercy over what data you could get
- having no say in the development of the dashboard.
In short we would be handing Complete Control to the Pension Finder Service. If you want to know what that feels like, you should watch this video from the Clash