DRAFT FOR DISCUSSION BY INTERESTED PARTIES
This page covers how PDOC could be constituted and structured, ideas for PDOC’s code of conduct, and how PDOC collateral could be developed and published.
These are all early ideas to be further developed and finessed during 2024 (see Plan).
PDOC constitution
Advice from industry colleagues who have previously set up independent, not-for profit, consumer-focused, industry coalitions is that it can be a lot of work.
But another idea is that PDOC could become part of an existing industry body*, enabling PDOC to benefit from the existing body’s constitution, governance and funding structures.
See the Plan page for a suggested timescale for discussing options for, and agreeing, how PDOC should be constituted and officially launched.
* Many potential PDOC members are members of, or are represented by, the Association of British Insurers (ABI) and the Pensions and Lifetime Savings Association (PLSA). The PLSA, in particular, has precedent component “sub-organisations”, such as PQM and RLS.
There are also other existing industry bodies which might be a good “fit” for PDOC:
- the Financial Data and Technology Association (FDATA) Europe
- the Investment & Life Assurance Group (ILAG)
- The Investing and Saving Alliance (TISA)
In PDOC’s setup phase (see Plan), we can agree which is/are the most appropriate body/ies to “parent” PDOC, or alternatively establish PDOC as a new standalone body.
PDOC structure
One advantage of linking to an existing body is that we could leverage existing governance structures and documentation. For example, the PLSA’s Pension Quality Mark has a Standards Committee chaired by Andy Cheseldine.
PDOC could be similarly independently chaired, with the PDOC Committee directing PDOC’s activities, centred around regular (monthly?) meetings of PDOC members, and meetings with Government and Regulators on specific topics.
PDOC will likely have low costs, with the majority of resource effort being provided on a voluntary basis by PDOC member organisations.
There may be some costs for central co-ordination and production of materials, as described under “Collateral” below. If PDOC became part of an existing body, these central costs could potentially be covered by an small incremental increase to the membership fee for those organisations who want to be PDOC members as well.
As with PDOC’s overall constitution, PDOC’s optimal structure, governance and funding will be discussed, agreed and launched in the setup phase (see the Plan page).
PDOC code of conduct
It shouldn’t be onerous to commit to being a member of PDOC. Key requirements are that PDOC members should:
- Actively contribute to PDOC’s activities, acting ethically in the best interests of both consumers and all PDOC member organisations who serve those consumers via their pensions dashboards
- Share feedback for the benefit of all consumers and PDOC members, for example sharing the results of their user testing of the core Find and View user journey**
- Respect confidentiality of any non-public domain information shared with PDOC.
A full “values based” PDOC Code of Conduct will be developed for the launch of PDOC.
PDOC’s values will reflect its ambition to be a force for the greater good of consumers. All dashboards must comply with DWP Dashboards Regulations, FCA Conduct Rules and PDP Standards, so it’s in consumers’ interests for QPDS firms to collaborate together, and with Government and Regulators, to optimise the practical application of all these rules.
This is analogous to PASA’s vision of bringing together commercial pensions admin firms for the greater good of improving the overall quality of pensions admin services in the UK.
** There’s no commercial risk in sharing this consumer feedback as core Find & View (F&V) services are strictly regulated by Regulations, Rules & Standards meaning there will be little differentiation between different dashboards’ core F&V users journeys (see the Topics page for more details on this).
PDOC collateral development and publication
This website (pdoc.org.uk) has been created (currently on a voluntary basis) as a central public domain repository of PDOC ideas and collateral.
Over time, this domain will be professionally managed and maintained, covering the following collateral, which would be agreed by PDOC members prior to publication (not an exhaustive list):
- Governance: PDOC governance documentation
- Research: summarised feedback from PDOC members on all in-scope topics (see Aims page for a summary list, and the Topics page for more details)
- Policy positions: evidence-based PDOC policy positions on specific topics for discussion with Government and Regulators
- Best practice: guidance on what works best for consumers in terms of using core Find and View dashboard services.
Over time we can also consider if there might be additional value in having a “members only” area of the PDOC website.