DRAFT FOR DISCUSSION BY INTERESTED PARTIES
This page outlines topics where PDOC collaboration will be beneficial for Government, industry and consumers (not yet necessarily an exhaustive list of topics):
Background: The core Find & View journey controls
Finalising the initial F&V Rules & Standards
Developing dashboards connection guidance
QPDS audit scopes: pre-connection and annual
Planning user testing
Executing user testing
Feeding back results from user testing
Feeding back on the Step 2 CDA interface
Iterating PDCOB Rules & PDP Design Standards
Background: The core Find & View journey controls
The core user journey which all pensions dashboards must offer is known as “Find and View” (F&V), i.e. enabling consumers to Find their pensions and then View basic information about those found pensions.
There is relatively little flexibility in how dashboard operators can design their F&V journeys – this is so that the core journey feels the same regardless of which dashboard, or dashboards, a consumer chooses to use.
Below is how the core F&V journey was depicted at the PDP architecture & data webinar on 13 December 2023:
At a high level, there are 3 steps in this journey:
Step 1 Arrive: where the user arrives at a dashboard’s landing page
Step 2 Find: Where the user goes through the sub-steps to trigger a search to find their pensions – this includes the dashboard operator passing the user to the central Consent and Authorisation Service and the central Identity Service (which are part of the PDP Central Digital Architecture or CDA)
Step 3 View: Where the user can view basic information about each of their pensions which have been found as a result of the search, followed, as subsequent steps, by any Post-View Services (PVSs) the dashboard operator wishes to offer.
These core journey steps are highly regulated by:
both published in draft in December 2022:
The PDP Design Standards tightly control what must be shown, and how it must be shown, in Step 1 Arrive and in Step 3 View. For Step 2 Find, all dashboards must pass the user to the CDA interface, so this step will be identical, whichever dashboard a consumer uses:
In addition, the draft FCA PDCOB Rules also include certain controls on what must be shown. For example, Rule 5.4 (Disclosure information in relation to view data) prescribes the messages dashboard operators must communicate to users, just before seeing their pensions, about the limitations of view data:
However, the way in which operators must communicate these and other messages is not prescribed; rather, the FCA Rules require operators to consider the most effective and engaging way that they can convey these messages to customers.
Finalising the initial F&V Rules & Standards
HM Treasury has added “Operating a pensions dashboard service” to the list of FCA Regulated Activities, with the draft legislation coming into force from 11 March 2024:
By approving this legislation in March 2024, Parliament opens the door for the FCA and the PDP to publish finalised initial PDCOB Rules and Design Standards respectively (see Plan for more on this).
However, FCA and PDP may have further questions for nascent QPDS operators before they publish finalised initial PDCOB Rules and Design Standards.
PDOC can act as a helpful route for FCA and PDP to direct pre-publication questions, providing rapid and detailed responses, thus helping FCA and PDP publish finalised initial Rules & Standards as soon as possible.
Developing dashboards connection guidance
On the supply of data to pensions dashboards, PDP is already collaborating with industry to develop connection materials:
This is being achieved by PDP collaborating with various pensions industry groups and 20 volunteer data providers:
In the same way, on the display of data, PDP has said it will collaboratively develop connection guidance for dashboards operators:
PDOC will be an efficient new industry group to support the collaborative development of this dashboard operators connection guidance.
QPDS audit scopes: pre-connection and annual
Under Dashboards Regulation 13, all QPDS operators must appoint an independent expert auditor to audit their QPDS’s compliance with PDP Standards, both pre-connection and annually thereafter.
PDOC is well placed to convene discussions with nascent QPDS providers, nascent QPDS auditors, and Government / Regulators to help determine the appropriate scope of the pre-connection and annual audits of QPDSs.
Planning user testing
PDP is establishing a collaborative User Testing and Planning Group (UT&PG) with industry to develop plans for user testing:
PDOC is very well placed to support the PDP UT&PG garnering together the perspectives of its member dashboard operators.
Executing user testing
A very considerable volume of user testing will need to be executed, and multiple connected dashboards can help speed up that process.
PDOC can support the co-ordination of user testing through dashboards operated by multiple providers, generating rich, diverse and rapid user testing feedback.
Feeding back results from user testing
There will need to be a rigorous process in place to rapidly co-ordinate and feed back numerous user testing results from multiple dashboard operators. This will support the Secretary of State’s early assessment of when the statutory Dashboards Available Point (DAP) notice should be made.
PDOC can co-ordinate the rapid feeding back of user testing results from multiple dashboard operators, supporting progress towards the DAP notice as soon as possible.
Feeding back on the Step 2 CDA interface
User testing, by multiple dashboard operators, will also generate considerable feedback on the Central Digital Architecture (CDA) steps of the Find & View user journey, such as the central Consent and Authorisation Service and the central Identity Service.
PDOC can co-ordinate the rapid feeding back of user testing of the CDA interface, enabling those steps in the user journey to be optimised prior to public launch of dashboards at the DAP.
Iterating PDCOB Rules & PDP Design Standards
PDP has said its Design (and other) Standards could change indefinitely every 6 months (for minor changes) and every 12 months (for major changes), with notification periods of the same durations:
PDOC is very well placed to collaborate with FCA and PDP on the sequencing, planning and iteration of Rules and Standards changes, given the extensive live usage of different dashboards following the DAP.