I ask the question in the title because an assertion was made at last night’s Pensions Network Session that pension providers had a choice as to whether to be dashboard ready or not. This is currently the case. However, it we have it mandated in the Pension Schemes Bill that the providers of all pension schemes in the UK need to make data available to the pensions dashboard, investment in technology to achieve compliance ceases to be an investment choice and becomes a matter of compliance.
I had hoped that I could write with some assurance that the dashboard clauses of the Pension Schemes Bill had been read in committee by the Commons but I can’t – because yesterday’s proceedings have yet to get to them. When they are through the Commons they will still have the hurdle of the Committee stage of the Lords who are keen to apply a belt a and braces approach to dashboard security that may push the dashboard availability point out so far that the impulsion on providers to sort out technology recedes over the current planning horizon.
There is an alarming lack of urgency in all this. As another speaker at the same event made clear, locking down data and preventing access either to information or the means to do things with it, creates new risks. Shake a bottle of pop with the lid on and you store up an explosion when the cap is taken off, you may even lose the lot if the bottle bursts. People who are frustrated by not getting the information they need are prone to listen to people who give them what they want to hear – poor service is the scammer’s friend.
“Investment in technology” is a phrase that suggests that there is a choice not to invest in technology. But this is simply not an option with the dashboard legislation of a Pension Scheme Act and any trustee, IGC or GAA with oversight over a pension scheme that will be reporting to the pensions dashboard will have to have a plan that ensures a clear path for data to flow to dashboards digitally. This means the creation of APIs, the adoption of processes that recognize the identity of data requests and the provision of data that is fit to view.
These processes should not be seen as investment choices but as the business as usual of running a pension and trustees , IGCs and GAAs should make it clear that there is no choice but to spend the money needing to make data readily available.
This paradigm shift has been made by open banking and in particular by PSD2. It did not take so long for banks to comply because the Competition and Markets Authority made it happen in quick time. Open pensions will take longer as we go the legislative route and manage matters through MAPS .
Investment in open pensions is not a choice
It can and is argued by Chris Curry and the Pension Dashboard Programme that the dashboard needs to delivered through Government because of the breadth and complexity of pension provision. The timeline for compliance with the mandation of the pensions Bill (business as usual for the dashboard), looks like 2024 at the very earliest. The preference to have the dashboard availability point close to the point of 100% provider inclusion means that providers who do not want to get compliant can drag their feet
This should not be an excuse for the private sector to consider providing people with ready access to their data is a matter of their choices to invest in technology to make it happen. And this I fear is the mindset that the Pension Dashboard Programme has got itself into.
On the same bill as those arguing about data provision to help people find their pensions and the value of their pensions was a spokesperson for Tumelo, explaining how technology can help us find out what our pensions invest into , how those investments are managed and even how we as savers can influence the behaviour of the organisations into which are money is deployed.
The voluntary adoption of Tumelo technology by L&G and Aviva is to be applauded and I have no doubt that these forward thinking organizations will be at the forefront of adoption of the dashboard protocols. But what of the rest?
And while giving us access to the E, S and G of our investments is at the sexy end of the pension marketing agenda, data cleansing with the aim of giving people a transparent view of what their pension can buy them- is not!
It is critical that the technology agenda moves on to make data transparency – business as usual . Investment to create easy access to personal information should be seen not as a business decision but a right for the business’s customers. We should not have to wait for a dashboard to have open pensions.
Addendum -that OECD report…
The report featured at the top of this article was published more than three years ago, I was proud that my fintech (Pension PlayPen) was featured in it. You can read it here.
The co-operation of large providers with young start-ups in the delivery of technology solutions is the subject of another blog!