Pensions Dashboards consultations submissions published by PLSA
15 February 2023
The PLSA has today published its submissions to the Pensions Dashboards Programme Design Standards consultation and the FCA Proposed Regulatory Framework for Pensions Dashboards Service Firms consultation.
Nigel Peaple, Director of Policy and Advocacy at the PLSA said: “We are glad that the regulatory proposals and design standards put forward by the PDP and the FCA prioritise the reliability and security of data displayed on pensions dashboards, as well as the importance that savers understand the information being presented to them. Saver protection is paramount and the PLSA welcomes the high bar for authorisation of pensions dashboards firms proposed by the FCA.
“It is vital that the information savers see on dashboards is presented clearly and objectively and does not influence their decision-making in a harmful way. The standards proposed by the PDP and are a very good start, but they will need to remain flexible as real-world experience from extensive testing informs communication approaches.”
Key points – PDP Design Standards consultation
- Testing – while we think many of the proposals for the display of data are sensible and prioritise user needs, until they are thoroughly user tested, the standards will need to remain flexible, as real-world experience informs communication approaches.
- MoneyHelper – the MaPS dashboard is currently the only one connected to the Central Digital Architecture (CDA), so more information sharing on the testing progress MoneyHelper is making would benefit the entire dashboard ecosystem, for instance on areas such as standardised terminology.
- Security & safety – of users and their data. Dashboards must present information in a completely neutral manner, without seeking to influence user behaviour in any harmful way.
- Coordination between all parties – we have called for quarterly reporting before the Dashboards Available Point from the PDP, MaPS, industry, government and regulators. Each element of the programme is interdependent, so full clarity is required on progress.
- Flexibility of presentation within defined standards – certain key concepts and data must be consistent across dashboards, including the display of pensions as an income, and certain terminology where there is potential for misunderstanding (with mandated explanations). However, dashboards need to retain the ability to tailor their communication approach to specific demographics.
- Warnings and limitations – dashboards need to be completely up front in terms of their limitations, including where certain pensions are not displayed, and that users should not act based solely on the indicative data presented on a dashboard.
Key Points – FCA Proposed Regulatory Framework for Pensions Dashboards Service Firms consultation
- The purpose of the FCA’s regime to regulate Pensions Dashboard Services (PDS) firms is primarily to ensure that users’ savings are not put at any risk through the use of dashboards, and as such, the harms outlined in paragraph 2.16 are the right ones. Security of data, reliability of PDS firms, and messaging to ensure consumers understand the service they are using, are all paramount to ensure they act on the information in the right way, and do not take irreversible decisions that could lead to long term poorer outcomes. It is therefore clear that only authorised firms should be able to provide a PDS; the starting point needs to be quality, with a focus on saver protection, and on the whole, we welcome that the bar to authorisation has been set high. Naturally, however, there is a balance to be struck between prescribing a safe and secure market, and allowing firms the flexibility to innovate with their dashboard propositions and engage with their users in a more tailored manner.
- We are in favour of the restrictive controls placed around data export. We flagged in our submission on dashboard standards in 2022 that our members were concerned about the security of exported data, and we are confident that restricting this to firms within the same group as the PDS firm will go a long way to providing confidence over such concerns.
Mark Smith, Head of Media Relations
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