DRAFT FOR DISCUSSION BY INTERESTED PARTIES
This page sets out PDOC’s proposed aims, together with the scope and ways of working to deliver those aims.
Aims
PDOC’s aims are predicated on the international evidence that commercial dashboards will be, by far, the dashboards which most consumers choose to use (see the Norwegian evidence on the Consumers page that 95% of dashboards usage is on commercial apps*).
PDOC has three core aims, all focused on consumers:
1. Pace: Support Government, Regulators and others to enable the safe, secure and successful launch of multiple dashboards for the UK’s consumers as soon as possible
2. Effectiveness: Help ensure dashboards meet different users’ different needs as effectively as possible at launch
3. Iteration: Amass live usage evidence from all dashboard operators to support the ongoing enhancement of dashboards Regulations, Rules, Standards and best practice, so that dashboards can continually improve for the UK’s consumers post-launch**.
* This is because users want to see their pensions on apps and websites they already use and trust, such as their banking, pension or money management apps, where they can also see other assets alongside their pensions, and where they can take action.
** See the Consumers page for the strong international evidence that dashboards need to iterate post-launch to optimally meet different consumers’ needs over time. For users, rather than being the end of the dashboards programme, the DAP is actually just the beginning – see Post-launch scope below.
Scope
See the Topics page for detailed descriptions of the areas where PDOC’s work will support the delivery of its aims. In summary these include (not an exhaustive list):
Pre-launch scope
- Plan: agreeing planning assumptions for the route to become a QPDS provider
- Audit: resolving queries on the scope of statutory pre-connection QPDS audits
- Authorisation: resolving queries on FCA’s authorisation of applicant-PDS firms
- Connection: resolving queries on dashboards’ connections to the CDA
- Testing: planning and executing scale user testing as part of the UTPG plan
- Central services: providing scale user feedback on the Identity and Consent services
- Matching: feeding back user experience of matching to inform ISP enhancements
- Standards: providing rich evidence to support the pre-launch iteration of FCA PDCOB Rules / PDP Standards to maximise dashboards’ effectiveness at launch
- DAP: helping the assessment for / decision on the Dashboards Available Point
- Launch preparation: co-ordinating activities leading up to, and immediately after, launch of dashboards from the DAP.
Post-launch scope
- Audit: resolving queries on the approach and scope of statutory annual QPDS audits
- Iteration: providing ongoing rich consumer feedback to inform future iterations and enhancements to the DWP Regulations, FCA PDCOB Rules, PDP Standards and consumer best practice for pensions dashboards, in multiple areas including:
- Dataset: when we developed the initial data standards in 2020, Call for Input responses (pages 24-27) said the dataset returned by data providers should be “deepened”, for example including over time data on: contributions, DC investments, ESG, VFM, charges, dependents, beneficiaries, and other areas, which will all require changes to DWP Dashboards Regulations and PDP Data Standards
- Display: live usage by millions of users will suggest many ways the PDP Design Standards should be enhanced to make dashboard displays more and more useful for consumers over time
- Operation: users will feed back what they do and don’t like about using dashboards, requiring changes to the PDP Operational and Service Standards over time
- Security: live scale usage will test security of the ecosystem, potentially requiring enhancements to the PDP Security Standards
- Oversight: live usage will create new oversight requirements post-launch, requiring changes to both the PDP Reporting Standards and FCA’s Supervision of QPDSs
- Conduct: FCA’s Conduct of Business (COB) Rules for QPDS operators will need to change as consumers demand more and more functionality from dashboards
- New technology: new technology becoming available will need to be reflected in the dashboards ecosystem
- New pensions legislation: changes to the UK pensions system, such as VFM, small pots consolidation, retirement innovations, will need to be reflected in dashboards.
Because commercial dashboards will be, by far, the most used dashboards, live usage evidence from all of these should be amassed to inform post-launch iterations and enhancements, co-ordinated for efficiency by PDOC.
Ways of working
PDOC’s approach is defined by three core ways of working to achieve its aims:
1. Collaboration: PDOC will actively work with MaPS, the FCA and the DWP to rapidly resolve queries, drive testing, and provide feedback, ensuring consumer feedback from all dashboard operators is reflected. This will be much more efficient for Government and Regulatory bodies than having to deal with individual dashboard providers.
2. Co-ordination: All operators of dashboards will actively listen to their customers’ / members’ feedback to continually source consumer insights on live dashboards usage. PDOC will act as an efficient central point to co-ordinate the delivery of this feedback to Government and Regulators from the widest possible range of consumer voices.
3. Non-commercial: Whilst PDOC members are commercial operators (except the MaPS MoneyHelper dashboard team of course), PDOC is an independent, not for profit, coalition, run for the benefit of all consumers. Members will only share insights on the non-commercial aspects of dashboards, i.e. the highly regulated core Find and View service (see Topics), with any potential competition law implications appropriately addressed.