There is an acknowledgement in the call for compulsion on providers to release data they hold on you and me, that some providers will be reluctant to play.
We are told why.
- Firstly – and most importantly – providers are not comfortable with the quality of the data they hold and sense that exposing their data to requests which they cannot intercept and deal with manually, could mean they unwittingly deceive their customers as to their pension entitlements. This is the same for those offering pensions (DB) as those offering pots that can buy pensions (DC).
- There is also a fear that the data held by legacy providers cannot be provided in real time in machine readable format. The data may be held on systems not designed to produce the outputs that dashboards can read, some data is still held on microfiche (we are told).
- There may be a third reason, fear of change – though I haven’t heard this articulated. The adoption of 21st century data technologies scares the living daylights out of some people, especially those who have not been updating their systems since the last century. The fear of change is natural, it is unknown unknowns that drive it.
But it’s always someone else…
Yesterday I was in the audience at an Asset TV IFA event which I assume will be broadcast soon. There were some good people on the panel representing the views of the hubbies and the fintechs but all professing that their (modern) systems could link to dashboards via APIs without any great trouble.
As usual, the problem was outside the room.
The people outside the room seem to operate their own dark-web. I assume they congregate in darkened rooms and weep secretly that their cosy world of non-disclosure will be brought to an end by a crazed Government intent on getting them to display what they hold on their clients (as required by DPA 18) soon to be reinforced by the 2019 Pensions Bill.
No – I don’t subscribe to that fantasy either – I made it up because I don’t know who is telling Government that their data is too dirty, their systems too archaic and their mindset too 20th century – to play with a dashboard.
Whoever these people are – they were not in the TV Studio I was in, nor have they been in the dashboard meeting I have been in – nor are they represented by the insurers I talk to day to day.
I suspect that there are a lot less people who will need to be compelled to supply data than is thought.
Nudging things along
While I suspect that there are relatively few pension providers who do not want to play, I suspect that most providers, when auditing their multiple systems recognise that some parts of their estate will be dashboard ready sooner than others.
The question for these providers, as was explicitly mentioned at yesterday’s session, is what will nudge providers toward dashboard readiness faster.
Here I have a positive suggestion. I suggest that the Internal Governance Committees and GAAs and Trustee Boards of pension providers take it upon themselves to oversee the project plans of their providers to ensure that policyholders and members get the data they need – in as clean a form as possible – in real time- and soon.
I am not into prescribing when, I would much rather that compulsion was an unused backstop – voluntary compliance with a service that is already demanded by the Data Protection Act, shouldn’t need compulsion at all.
The IGCs have already proved once that they can nudge insurers into good sense. The IPB project has meant that us consumers – so long as we are 55, need not pay more than 1% of our fund to transfer away from a legacy product. IGC’s are now looking for a new challenge and this could and should be it.
If data is the new currency- why can’t we see ours?
We know that data is valuable – we know that everyone from banks to supermarkets relies on information about us to help them sell their wares. In many ways we give our data away too cheaply.
But the lack of information available to us in real time about our pensions really is something else. It seems almost impossible to understand how organisations that are paid millions of pounds to look after our money , continue to extract fees without updating their systems so that we can see what’s going on as the Data Protection Act demands.
The basic consumer rights to information on us are denied, not because of any secrecy laws but because of the incompetence and under-investment of pension providers over the years.
A call upon the IGCs and Trustees
The IGCs know this above everyone else. And they are in place to put the consumer back in charge. How can consumers know they are getting value for money when it is such a palaver to even know what they own?
We have the 2019 IGC statements coming up, most are being written right now. I wonder how many will focus on the rights of people to their data?
At yesterday’s meeting, I didn’t hear one IFA or platform provider talk of the consumer fiduciaries. They are not even in the equation. They are hardly mentioned in the Pension Dashboard consultation. Yet they are the chosen instrument for change for tPR and FCA when it comes to disclosure to members. The IGC and Trustee Chair statements are the only documents that have to be made available to DC savers – relating to the running of their schemes.
So I call on IGC and Trustee chairs to pay attention to Data Protection Act 2018 and to read the Pension Dashboard Consultation and to ensure that what is in law and about to be in law, is reflected in the goals of the IGCs and Trustee boards in coming years.
They are our champions, let’s make sure we know what we expect from them.