“Your pension data could be taken down and used against you”

The last two weeks has seen Professional Pensions going data barmy with not one, not two but three stories extolling the use of personal data to manage pension scheme risks.

The first is a gentle and sympathetic article by Michelle Cracknell that won her the PMI student essay competition. I congratulate Michelle for the award and for qualifying as a student.

The second is the scarily title “Introducing the Maslow-style hierarchy of data-enabled communication” by Karen Quinn and Rhys Williams which calls on schemes to “reap the rewards of personalisation” by “targeting people based on their behaviour”. As these headings suggest, this is not a gentle article.

The third article is an interview with the BA’s Fraser Smart which takes the use of data to another level

“The most important priority of all the things we’re working on this year is about member experience,” Smart explains. “We’re trying to introduce a mobile application for members to increase their access to us. Every single member – whether they are a pensioner, deferred, or active member – will be able to see information about the schemes, about the benefits they have, when the next increase is, and who to contact if they’ve got any queries. Essentially, we want to give them a sense of trust that the right information is there.”

Shortly before the publication of this article, BA announced 12,000 job cuts, which made the article’s next paragraph a little sinister

For deferred members, the aim is to also provide indicative transfer values instantly available to look at, speeding up the process for those members who wish to take advantage of the facility.

The language of Trust

Michelle Cracknell’s argument is that “life moments”, the birthdays, marriages and moments of moving house and jobs are “teachable moments” and that schemes, who know about these life moments can use what they know to teach what they know.

This of course assumes that schemes are trusted and their teachings credible, if this isn’t the case then this messaging can become creepy and invasive. I remember NEST’s Tim Jones telling me he’d taken all his personal information off his linked-in profile to avoid being congratulated on life moments  by “people like Henry Tapper.”

Which is why we  need to be very careful about using words like “targeting” .”reaping” and loaded phrases like “take advantage”.  Taking advantage of a DB transfer at a “life moment” like redundancy,  does indeed require a “teaching moment”. I wonder how many of the 12,000 soon to be redundant members of the BA pension scheme will find advisers willing to teach them how to use this advantageous data.

The protection of GDPR

The General Data Protection Regulation means that we have to give our consent for our data to be used to help us. We generally have to opt-in to messaging from social media or our pension schemes. Tim Jones won’t have any of it while I – a born sharer, spend half an hour a day weeding my inboxes of unsolicited offers of help. We all have different tolerances for “privacy”.

But I wonder about the pedagogic aspects of all three articles. For Fraser, Rhys , Karen and Michelle there are “teachings” to be “targeted”.  There’s no doubt people want to be taught, look at the popularity of the Martin Lewis Money Show. But people choose their content, whether on TV, youtube or through their choice of apps.

Getting people to listen to you

Smart communication is of course personalised. Rhys and Karen cite Swiss Re’s research which suggested car insurance renewal letter “open rates”, improved from 33 to 81% by putting the insured’s registration number on the outside of the envelope.

But getting people to open a personalised message only to get a depersonalised call to action like “increase your monthly contribution” or “use our drawdown service” is not so smart. You might get people listening to you , but to keep them listening to you, you are going to have to tell them something that doesn’t come accross as “junk”.

Repeating the dose

Michelle argues that great information is repeat information. There can be few better examples than the work of TPAS which hammered out the same messages for years and did so with grace and good will. Michelle is now a non-exec at Pension Bee who are doing much the same thing with their messaging.

The “Nirvana for BA pension members” envisioned by Fraser Smart, is a two way communication with members that does what Fraser did to a “ditch-digger” who once walked into his office looking for an explanation of his pension.

The person that walked in was kind of fearful about the future. The person that walked out was confident about their future.

Rhys and Karen’s pyramid involves getting data right, organising it  and using it to deliver insights.

In all three articles, there is an essential similarity of view, that communication is a conversation, not something delivered from on high.

This is quite the opposite of the pedagogic communications that have failed trustees in recent years. In a classic example – the top down approach of the BSPS trustees, failed to get to the steel-men, while the Facebook pages put out by expert BSPS pensioners worked brilliantly. Eventually BSPS discovered that using the medium chosen by their members was more effective than teaching through a website no-one visited.

The Facebook pages are still there and still used on a daily basis. The reason everyone remembers TPAS is because Michelle got TPAS onto everyone’s social media feeds. Quietroom and ITM get read not just because of Professional Pensions but because they use their own sites effectively.

Using Social Media is (for many)  an activity of daily living, visiting a pensions website isn’t.

Using our data against us

The dialectic of this argument has swung between my admiration of Karen, Michelle , Fraser and Rhys and my concern that what starts out as engaging is seen to be boring (Michelle), scheming (Karen and Rhys) and downright dangerous (Fraser).

And before you accuse me of being a pedagogue myself, let me explain that there are simple rules that can be followed that stop us feeling we are being bored into submission, that we’re caught up in Maslow’s spider-web or that we are part of a grand de-risking program designed to keep BA and its pension scheme out of the PPF.

These are the rules of GDPR and they can be summed up in its bill of rights

  • the right to be informed,
  • the right of access,
  • the right to rectification,
  • the right to erasure,
  • the right to restrict processing,
  • the right to data portability,
  • the right to object
  • and rights around automated decision making and profiling.

Keeping these rights to the front of mind, makes it clear that unless you keep the communications “clear, vivid and real” people will use GDPR to turn you off. Unless you stick by the rules on automated decision making and profiling members (and regulators) will object and if you overstep the mark and move from “nudge to tell” you put yourself on the hook for the outcome of your advice,

Our pension data is precious, powerful and awesomely dangerous! “Tread softly , because you tread on our dreams“.

Screenshot 2020-05-21 at 07.07.49

Rhys, Fraser, Karen and Michelle

About henry tapper

Founder of the Pension PlayPen,, partner of Stella, father of Olly . I am the Pension Plowman
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