“Consumers aren’t fools,” – Romi Savova (Pension Bee )
Reading the responses to the Pension Dashboard Programme’s consultation on the data standards employed to give us a view of our pensions, you might think otherwise.
People are so dumb…
Whilst some respondents felt it is important for dashboards to prioritise information about DC charges and investments, a significant proportion felt that initial dashboards should be launched with just basic information, and the subsequent inclusion of any additional data should be informed by detailed user research about what individuals want to see and can understand…..
“The significant proportion” appear to be a lobby
The overriding and strong suggestion from 20 respondents, however, was that any supply, and display, of additional data on pensions dashboards should be informed by extensive user research, potentially once Level 1/2 dashboards are up and running, and channels for detailed real user feedback are flowing freely.
So how are we defining “user”? If you replaced it by “fool” would these statements sound any more condescending and ridiculous?
We ask “users” to work out how to work out universal credit, navigate “patient access”, deal with “test and trace” – with confidence that users will manage – and they do.
We give people information on their health and their rights to benefits (including pension credit and the state pension ) but when it comes to their pension savings it’s another matter.
We are not planning for something that will happen in four or five years time, there are 700,000 people reaching that tipping point when they need to start spending their retirement savings and our best idea of helping them – the pensions dashboard is given a timetable that at best- at very best – will deliver information four years late.
Note that decisions on meaningful data such as how much we pay for our pensions – will not be taken until we have dashboards available – at earliest in 2023.
Assuming the current pace of consultations , that suggests a transition to business as usual won’t be till 2024 (at earliest) – a full five years later than we were given to believe when the Treasury kicked this off in 2016.
This is not Crossrail or HS2, it is not even the new Super Sewer, (though it has similarities). This is a simple manifestation of GDPR which offers people the rights to their data in machine readable format. It is a manifestation of the rights of portability in GDPR which enable an agent (the dashboard) to give them that information in a way that is meaningful to them. These rights have been given consumers in law and are supported by wider Government initiatives such as open finance, these rights are further supported by the Law Commission’s dictats on open access including clarity that e-signatures are illegal.
Despite all this , the Pension Dashboard Programme is prepared to listen to a handful of submissions from the usual suspects and agree data standards which will presumably provide the “real user feedback” which is so clearly not in evidence in this consultation.
So where does this leave us?
There is nothing surprising about the PDP’s timeline. It represents the worst of both worlds. This is a lose-lose approach
If , as the consultation makes clear is possible today, the dashboard was just a pension finder service, then it could and should be up and running in 2021. If that were in plan then we could at least feel comfortable that less pension money (the PPI estimate £20bn) would be lost to its owners. But the dashboard’s availability point won’t , it seems, be reached till we have 75% participation in the use of the data templates (which means delivery could depend on the mandatory powers in the Pension Schemes Bill)
If – after a delay of five years for the right to see on a dashboard what GDPR entitled us to in 2018 – we are allowed a peek, then it will be on the terms of a hardcore lobby of 20 or so organizations dedicated to protecting us from our foolish selves.
We lose again because we will have to then wait for a “vaccination period” where testers will be exposed to potentially noxious information like how much they are paying for their pension.
Lose – Lose
No early access to pension finding as we need inclusive data, no inclusive data – because it might harm us.
A Loser’s dashboard
The Government is creating a dashboard for losers. But users aren’t losers, they are not going to hang around to find their information. Instead they are going to be trying to get information on what they have from providers and they are going to do so however they can. This will mean a lot of screen scraping (a lot less secure than the API technology that the dashboard could accelerate). It’s going to mean a lot more frustration (which plays into scammers hands) and a lot of people cashing out their pensions for want of a simple source of information that can help them turn their retirement pots into a wage in retirement.
We have given people pension freedom but deny them the information to use it.
We have adopted the GDPR but deny people the right to their data in digitally and portable to meaningful portals
We have entrusted the dashboard project to MaPS who in the two years they have had it, have done no more than set up the PDP and deliver this consultation. We are told we will have the data standard in place by the end of 2020, this is not a very shallow win.
A shot in the arm is needed
The dashboard project is in need of reinvigoration and I do not see that coming from MaPS. It needs a shot in the arm from the Competition and Markets Authority who need to intervene for open pensions as they intervened for open banking.
It needs the combined weight of the CMA, BEIS, the Treasury and the DWP behind it as MaPS is clearly unable to take this project forwards in a timely fashion.
My shot in the arm is coming
Readers will be pleased to know that in the time it took for the PDP to consult on a data standard for the dashboard, a vaccine has been created and will be put into clinical trial, I am very proud that I will be one of 10,000 in that trial and I very much hope that NOVAVAX will be helping us out of our current problems early next year.
If you want a shot in the arm, you need the drive and energy of a public private partnership and I’m delighted to be doing my bit with St Thomas’ NHS hospital , a 10 minute cycle from where I live.
Let’s be positive, let’s live a little – we’re no fools!