Data requests are a key measure of “quality of service”.
This is a sister piece to my blog for pension consumers published here. Under GDPR, consumers are entitled to their pension data in a timely fashion. In a test last summer we were able to see the service standards which various providers operated to. At the top of the list was Royal London who supplied what we wanted almost online. At the bottom of the list was USS who’s pension administrators would not acknowledge their customer’s request for information. But the sample size was too small for us to draw general conclusions.
In our current test we will have 500 consumers issuing letters of authority to hundreds of providers – some will receive dozens of requests. It will give us a better understanding of who is providing quality of service and who isn’t. Just as this is a chance for consumers to understand the quality of service they are getting, so it is a chance for the fiduciaries of pension providers to understand the quality of service they are giving to their savers.
We won’t be afraid to publish the information we gather on quality of service and share with relevant authorities. Transparency is the best disinfectant.
By your data shall ye be known!
Pension providers are understandably nervous about committing their pensions data for AgeWage analysis. Analysis can show that the achieved performance of members is below par and can point either to poor investment returns, high costs and charges or both. The analysis can also show up poor data quality through “outliers”, individual analysis which suggests that the data itself is faulty.
Having your data analysed by an independent firm is doubly daunting when it is being compared to an independent benchmark (the Morningstar UK Pensions index). We understand that it takes courage to submit your data to independent assessment and we understand the reluctance of many providers to share it with fiduciaries.
Nonetheless, the new consultation on Value for Money (CP20/9) issued by the FCA makes it clear that not only are IGCs and GAAs to offer those who purchase their providers products “comparables” but the comparability metrics are to be data driven. It is very difficult to argue that a traditional value for money matrix is fit for purpose. These are too reliant on subjective judgement , too inconsistent and often lacking in genuine independence. The FCA make it clear in their report on IGC behaviors that several have not been sufficiently independent of their provider.
By your data , shall ye be known. Reluctance to share data with employers running their own schemes (and by extension participating employers of master trusts) suggests problems with governance that should be sprouting red flags.
How providers can win…
For pension providers who can share data with their IGCs, GAAs, Trustees and their key customers, the large employers with their own schemes and even smaller employers, there are three big wins.
- The transparency dividend – trust between provider and fiduciary
- The dashboard dividend – confidence that the provider will be dashboard ready
- The dividend from your savers – confidence with savers that VFM can be discussed on their terms
I will not labour these points as I have been over them many times.
In the short term , blocking data requests from your stakeholders may be the easiest thing to do. But it does not solve the problem, every time a stakeholder is frustrated , pressure grows, trust reduces.
Arguments around data readiness or the strain on the system at a time of pandemic wear thin. Provided a data request is reasonable, unreasonably blocking it on the grounds of inability to share data, suggests fundamental problems with “quality of service” and value for money.
But if data is shared and shared through fiduciaries with savers, there is a transparency dividend to be had. It is to be had not just from savers but from employers, fiduciaries and ultimately Government.
A call to action
We intend to mobilise the pensions industry, though Government, through fiduciaries , through employers and (in the Sandbox) through savers, so that this data is shared and value for money is understood.
We are doing this directly, through the CIPP and through social media. We will not be stopped!
If you would like to know more about making your provider a data-winner, contact henry@agewage,com. I’d be delighted to talk things through.