Read TPR’s warning here; https://www.thepensionsregulator.gov.uk/en/media-hub/press-releases/2022-press-releases/trustees-warned-be-prepared-your-pensions-dashboards-deadline-is-coming?dm_i=6TA,7WXAT,MZFLLF,WCP24,1

Thanks Paul McGlone for reminding the good people of Linked-in that “dashboard denial” is futile.

He ends a pithy argument with an admission that while dashboards are coming , we don’t know quite when.

Of course, none of that is connected to when members might get access. That is still an unknown, and will depend on how staging goes. I can see how that may end up being a little later than we would like, but I’d rather have a later successful launch than an earlier disastrous one.

The comparison with the staging of auto-enrolment is obvious. With auto-enrolment, the staging date for an employer was either hit or missed, if missed, fines ensued, escalating very quickly. Although tPR is given powers to fine data providers (eg the administrators of our private pensions) with fines, it is not clear whether non-compliance will lead to a pushback in the data availability point, or a weakened dashboard and sanctions against the administrator.

Personally, I would like to see administrators having to contact those members it knows the whereabout to , explaining that it holds records for them which it cannot share on the dashboard but which are available on request. I’d also like to see naming and shaming of schemes that haven’t complied on a website accessible to journalists (and bloggers).

As for the dashboard availability point, I do not see why poor practice from data administrators should lead to a pushback in the dashboard availability point. Here are three reasons why

1. As a general principle, it stops schemes sabotaging a public project by non-co-operation  (theoretically a few schemes could hold the public to ransome, though I suspect it will be a large number of small DC schemes which will be a bigger problem)
2. Where a large scheme does not feel it can participate for fear of giving inaccurate data (say schemes subject to the McCloud ruling), it is better to flag the issue than to hide the record. A pragmatic approach to projections is required.
3. Many of the 40,000 DC schemes tPR knows of , have no significance to the dashboard, they are paying benefits to beneficiaries who set them up, they are not truly workplace, but are SSAS and similar and belonging to super-engaged entrepreneurs. In any event , a carve out for the smallest schemes is likely to happen as they are not scheduled to stage till the second half of the decade.

If the Government is serious, and Paul McGlone’s article gives good reason to suggest it is, then the public will be serious too. If dashboards are available as downloadable apps which require no more than minimal data inputs, they will be used by most people over the age of 50 and a fair few enthusiasts in younger years.

There is nothing so likely to crystallise memories of past employment and pension deductions, of visits from sales-fired financial advisers and of valiant but failed attempts to save for retirement than a screen of pension entitlements. The “I’m sure I have more” question , followed by a search of non-cooperating schemes and insurers , will ignite the avid curiosity of a good section of the saving public.

And what if the data is wrong?

We know a lot of data held by schemes is wrong, we know that the state pension entitlements of maybe a million of more, may be “out”, but we have tolerances for error and if we don’t , some of us have the persistence to ask for contribution histories and query errors. Our work at AgeWage shows for instance, that errors in records typically surround manual interventions, the transfer in of benefits from another scheme, a partial withdrawal, maybe the failure to include a contribution stream (from contracting out for instance).

It only takes one sharp eyed member to spot a problem for a review to occur by scheme administrators which may result in the rectification of a systemic error. This is how problems get resolved. There is infinitely more scope for a bottom up reconciliation of the “I’m sure I remember…” type, than schemes trying to second-guess where they went wrong.

Dashboards test quality of service.

Like regularly  going to the dentist, regular scrutiny of data ensures problems don’t build up. Many visits to the dashboard will be like my recent visit to the dentist, a cause of much pain to both the dashboard user and the people who have to put right the problems that come to light.

But we can’t have a system that tells people they can’t see their data because it is feared it is untrustworthy. Pension administrators and the people who fund their activities , need to have contingencies in their accounts for the increased strain that will be created by dashboards and they cannot assume that this can simply be passed on to savers and sponsors of DB schemes in higher fees. People pay for data to be presented “right first time” and don’t expect to pay again when it isn’t.

So I would go further than Paul, and suggest that not only is the dashboard coming, but it is coming with a whole load of extra work which should be recognised in a scheme’s and it’s administrators financial projections. Well administered schemes will look forward to the dashboard as an opportunity to gain competitive advantage, an advantage that has been earned – rather than promise. The dashboard will be a true test of quality of service, an element of value for money.

How to get ready.

If you are feeling a little queasy after reading this article, it is probably because you are a pension data administrator (or have responsibility for one). Here are the actions that the Pensions Dashboard Program , suggests you take, to get the dashboard off your risk register and onto your marketing team’s agenda!