PDP consultation on the draft design standards

Background

The Pensions Dashboards Programme (“PDP”) has issued a consultation on its draft design standards.

In this response

• Responses to specific consultation questions

Responses to specific consultation questions

We welcome the opportunity to respond to this consultation. We have not sought to answer every question in the consultation but have limited our responses to those areas which are pertinent to our practice.

Question (b).  We have tried in our design standards to strike the right balance between ensuring consumer protection while also allowing dashboards the flexibility to tailor their communications and designs to their own audiences. Do you agree our approach strikes the right balance? Do you have suggestions about what more we could do to strike the right balance?

We understand it is a tricky balancing act and appreciate that you need to offer some flexibility to dashboard providers.

Where dashboard providers decide to use non-text format, eg a video, we think it is important that a text alternative is also available.  This is to ensure the information is available without needing to use large amounts of data when accessing the dashboard on a mobile phone, and that someone can see the information if they are unable for whatever reason to hear it or to turn up the volume to the desired level on their device.

We welcome the requirement for user research in paragraph 26.  We would suggest that this is expanded to expressly refer to “testing” (rather than just qualitative research) and to require dashboard providers to update their offering where research indicates this is necessary and then to perform further testing on the revised offering.  We would also suggest that any “enhancements” referred to in paragraph 26(d) should also be tested and subject to a “member clarity” requirement, to ensure any enhancement doesn’t confuse any terminology / information being used or provided.

Question (c).  We have not replicated the terms from the regulations or the FCA’s regulatory framework in the design standards, as we do not consider we need to duplicate these and also given that QPDS must familiarise themselves with those terms in any event. Do you agree with our approach that design standards should be read consistently with the regulations and the FCA’s regulatory framework (see paragraph 16 of the draft standards).

Yes we agree.

Question (f).  We have not defined the terminology to be used by QPDS when presenting pensions information (see paragraph 25(c) of the draft standards), as we believe dashboards will be best placed to determine the most appropriate way of communicating to their customer base, and imposing uniform requirements on language could be counter-productive. Do you think this is the right approach? If you do not agree with our approach, then how do suggest we should approach defining terminology?

We appreciate that this is another difficult area and we can see the advantages of dashboard providers explaining terminology for their particular customers.  However, we have concerns with this approach, in particular:

• the terminology that the dashboard providers use may not be consistent with the terminology used by the individuals’ various pension schemes
• we expect dashboard providers will have limited DB experience and may not be best placed to accurately explain DB concepts.

There are no easy answers here but we wonder if the design standards could include a glossary of key terms with (i) suggested definitions for key concepts and all DB terminology and (ii) the key points that must be covered in the various definitions, ie expanding on the two examples that you give in paragraph 25(c) on pages 14 and 15.  On the DC side, this would give dashboard providers more guidance in what needs to be explained whilst also giving them some flexibility.  On the DB side, this would minimise the risk of poor explanations, where the dashboard providers are less familiar with the terminology.

Question (g).  In a number of places, we have referred to the QPDS presentation of information in a ‘neutral and logical manner’? Are you clear what this means in the light of the explanation in paragraph 39 of the draft design standards? How do you think we could clearer in explaining what we mean?

Yes but we feel that this is an area where user testing should be used, to ensure there is a common view as to what “neutral and logical” means in practice when presenting the data.  We also feel there is no harm in making clear that this means, among other things, that the QPDS cannot give priority to pensions information that is in any way related to it, ie a pension scheme run by a party in its wider group.

Question (h).  In relation to the summary of pensions information on the QPDS:

1. do you agree with the approach of a summary of all of the pensions information provided the user can click through to the detailed pensions information in respect of each benefit? If you disagree, please explain what approach you would prefer.
   
   Yes agreed.
2. do you consider we are requiring the right amount of information to be displayed in the pensions summary? If you do not agree with our proposals, what information do you think we are missing or what information do you consider to be superfluous?                                                                                                                                                                                                                        Yes but we think the summary should also specify whether the benefit is DB or DC.
3. do you agree with the rules we are proposing for how the summary is constructed? If you do not agree, then can you explain why not and highlight any omissions you consider we have made.
   

In respect of the table on page 18:

• we suggest a further one is added for individuals who have left a scheme, ie so they are a deferred member, but the value data being pulled through (ie from the most recent annual benefit statement) was calculated when they were an active member
• for options (e) and (f), it would be helpful if the “link to detailed pension information” included the relevant user action, eg to contact the scheme directly.

Question (i).  Do you think we should allow graphical representations of all the found pensions on QPDS (see paragraph 46 of the draft standards)? If you do not agree, could you explain why?

Yes but see our response to (j) below.

Question (j).  Do you think the mandated explanation mitigations we have put in place for graphical representations are adequate? Please explain what you would consider to be adequate mitigations.

We think that they should be expanded to cover DC and DB separately, given the different risks and uncertainties of each benefit.  For example, the assumptions and methodology used to produce the annualised DC figures are key points which mean the actual figure at retirement will differ.  Whereas a key point in DB benefits, for example, will be inflation assumptions.

Question (k).  Are we right to require QPDS to have prominent links to the CDA displayed on each page (see paragraph 45a) of the draft standards)?

Yes.

Question (l).  We have not required QPDS to communicate information around delegated access (to a MaPS guider or, in specific circumstances to a Financial Adviser) as this takes place at the consent and authorisation service. Do you think we should require QPDS to explain the possibility of delegated access earlier, even if the QPDS is not providing a delegated access functionality (which would be in respect of the Financial Adviser only)?

Yes, we think it should be included at an earlier stage.  If an individual wishes to delegate access they may be confused on arriving at the dashboard provider’s page and not being able to delegate access immediately, so there needs to be an explanation that this happens further on in the process.

Please also feel free to submit any other comments you wish to make in respect of our proposed design standards.

The consultation notes that the MaPS dashboard is not required to follow the design standards as it is not a QPDS and will only be adopting the framework “as far as it can”.  Therefore, it would be helpful to understand whether, over time, there will be a process of explaining any divergences by MaPS from the design standards and the rationale for those.  This would help trustees to understand any differences between what their members are being presented with on the MaPS dashboard compared with any commercial dashboards.

We understand from the consultation that the standards do not to apply to a dashboard’s display where the user is a financial adviser to whom the user has delegated access.  This is inconsistent with the FCA’s proposal (in paragraph 5.7 of their consultation) that all of their rules and guidance will apply regardless of whether the user is a customer or “delegate”.  We support the FCA’s approach of treating all users the same, as this ensures consistency for all.