In this article, Heywood Chief Strategy Officer Chris Connelly explores how accurate and well-maintained data, coupled with a good ISP can help pension schemes get in shape to safely arrive at the start-line of open pensions – the Pensions Dashboards.
It’s time to change the way we think about data. It’s no longer something that sits in a cupboard gathering dust, or even in a database gathering… er… e-dust? It’s time to let it go out and mingle. It needs to leave the nest and head out into new territories to spread its message to your members and communicate with them where they want to see it. Your data is about to go and mix with others on holiday in shiny new Apps and Websites.
This means we need to think about the data going on a journey, safely. From your storage to your member’s understanding.
In principle, dashboards are a way to answer our members’ questions in a place of their choosing. Helpfully, we already know what the big questions are because user research at the very start of the pensions dashboards programme told us that members want to know “What have I got?” and “What will that be worth when I retire?” They want to know if they can afford to live in a land of hope and dreams.
Others in the PMI's Dashboard Industry Guide will focus on the data and ensure that it has packed its little suitcase for its travels.
We’ll talk about the journey.
The programme’s Central Digital Architecture (CDA) carries out a lot of functions. It is handling security, identity verification, distributed search functions, compliance reporting, permission management and consent capture.
Schemes have a legislative obligation to connect. The points of connection are where data gets exchanged between the dashboards, and the systems where you hold member data. You could work your way through the legislation and the seven different sets of standards and guidance. Or you could outsource that work.
Most Pension schemes, and their TPAs if outsourced, are expected to rely on an Integration Service Provider (ISP) to connect. Consider them your travel agent, your airline, and tour guide all rolled into one.
There is help out there already; advice from TPR, FCA, PASA, PLSA and others. They all urge that getting your data “dashboard ready” should be a high priority task and not left until late in the run up to dashboards going live. Importantly, “getting data ready” should also include how you are planning to connect it to dashboards. You can solve these two key elements of a successful and stress-free onboarding journey by engaging with your ISP provider as early as possible.
Big wheels roll through fields where sunlight streams
A good ISP will be able to shield you from the many technical aspects of connection to the CDA and guide you through the areas of decision and preparation required and ensure that the choices made are the right ones for your scheme. An ISP should also be able to show you your data readiness and compliance information in real time.
As well as providing secure, performant connectivity, there are two main exchanges of data that the ISP will facilitate for you. The first is the Find Request and the second is the View Request.
The find request is simply the CDA asking every scheme,
"Do you have any pensions for Chris Connelly? – Here’s his identifying data"
The ISP will interrogate the underlying data it holds for schemes and apply a set of scheme rules, called “matching criteria” to see which member records match the incoming data in the find request.
The answer to the find request is going to be Yes, No or Maybe. Or in legislation, a full match, no match, or a possible match. If it’s a Yes or a Maybe, A response message is submitted with an associated Pensions Indicator (a PeI).
A find request will be submitted for every member who uses a dashboard and it will be sent to every scheme. This could be millions of requests. ISPs will shield you from this excessive traffic.
The requesting dashboard will receive a PeI for each pension located. It will then submit a View Request. The view request is simply,
“You’ve sent me this PeI –
please can you send me the member’s pension information now?”
For a possible match, the ISP will send back the contact information for the scheme administrator so that the member can get in touch to see if there really is a pension for them. Schemes will need to resolve these possible matches outside of the dashboard when the member contacts them. However, schemes will need to have a way to update the ISP when the match is resolved. ISPs will be able to help you with the choices you need to make around possible matches.
For full matches, the ISP will submit all of the pension information required in the data standards, including where appropriate, the pensions already accrued by the member and estimates of pension income at retirement.
As well as the main interaction with members, there are other audit and reporting activities that the ISP will carry out on schemes’ behalf.
Working with your ISP from an early stage is vital. It is easy to under-estimate the amount of time and effort that is involved in getting ready for dashboard.
There may be a selection process, contract negotiations, data security, GDPR, compliance, audit, reporting, matching rules, system configuration, data formats and data flows to be agreed and implemented. Additionally, there will be testing, pre-staging and go live steps that will need to be worked through. Some ISPs will additionally offer automated connections directly into and out of your underlying record keeping systems. This will give you another layer of IT activities to work through.
Many would also be able to carry out the data preparation and ongoing data quality for you. Some also offer to fill in your calculation gaps for you should you not have the ability or time to do so in your underlying systems.
Ideally your ISP engagement should start at least 12-18 months before your connection date. Sooner if you have any concerns about your data readiness.
It’s also important to consider that there is so much left to be completed in the core programme. Therefore, many of the standards are still likely to change and this is where having an expert partner will help navigate that and insulate you where possible.
Once you are live on dashboard, you are always live. Not only is it vital to get your data dashboard ready, but you will need to always keep it ready. Without an ongoing ‘business as usual’ approach to data cleanse, it is inevitable that data will degrade over time. This can lead to increased matching failures, more possible match workload, more risk of GDPR breaches.
A regular monthly data cleanse and value data refresh will avoid all these issues and help deliver a reliable, consistent, and positive member experience.
The amount of preparation and work to get to a live dashboard position could seem daunting, but the key to success is early preparation and working with your suppliers from the outset. There will be capacity issues as we get closer to the final connection deadline and leaving it too late will mean we all fail.
…but don’t forget: connection deadlines are not the finish line. They are the start line for a new world of “Open Pensions” A land of hope and dreams where our members get to choose where they receive their pensions information.
© With full credit and apologies to Bruce Springsteen and Curtis Mayfield