Trustees of schemes with more than 100 members (excluding pensioner members) will need to ensure that they connect to the dashboard by their statutory connection date - but there’s a lot of preparatory work needed to make that possible.
Earlier this summer the Pensions Regulator (TPR) issued a statement in which it highlighted that a majority of trustees have yet to prepare for their pensions dashboards duties. TPR’s director of regulatory policy, analysis and advice David Fairs said “Pensions dashboards are coming. Trustees will have legal duties they must be ready for. We will take a dim view of trustees who carelessly fail to prioritise their dashboard responsibilities”.
There is still much to be confirmed in the detail, but the majority of the framework for dashboards has been confirmed. In the coming months, we can expect to see the final dashboards regulations (expected in Autumn 2022) which will confirm the final connection deadlines (also known as staging dates) for schemes, depending on their type and size.
So, what can trustees be doing now to get prepared? Trustees should read on for some tips to help get them dashboard ready.
There’s a lot of talk about ‘connecting to the dashboard’ so you’d be forgiven for thinking there’s only going to be one of them but that is not the case.
There will be a number of dashboards on the market eventually, and each one will be connected to central digital architecture which allows information to be shared through them. The architecture allows that exchange of information to take place – it does not act as a central dashboard or database which holds information supplied by pension schemes or members.
The digital architecture has been designed by the Pensions Dashboard Programme (PDP), a dedicated body established by the Money and Pensions Service (MaPS). The PDP describes the architecture, dashboards and all the other software, programmes and technology needed to share pension information electronically and securely as a central digital ecosystem. It is this ‘ecosystem’ which schemes will need to connect to, in order to respond to information requests submitted by individuals through their chosen dashboard.
Your connection deadline will be based on the size of your scheme, and the proposed deadlines have been set out in draft regulations. Those deadlines are however subject to change pending the final regulations which are expected in Autumn. Once the final regulations have been published, you will be able to confirm your connection date.
Scheme size is based on the number of members (not including pensioner members) at the scheme year end date which falls between 1 April 2020 and 31 March 2021. If the number of members is 100 or less in this period, but goes up to more than 100 after, a different approach is needed to determine the connection deadline. Please contact us with this information and we can help you to determine your connection deadline.
You should speak to your administrators and other advisers to determine what services they are offering and how they can help you to connect to the dashboard ecosystem. You will either need to build your own digital interface in order to connect, or use an interface built by or provided by a third party.
It can’t be underestimated how important good quality (digital) data will be in determining the success of schemes connecting to dashboards and complying with ongoing duties. Data will need to be up to date and accurate to ensure compliance when matching people with their pensions, it will also need to be easily searchable (and stored digitally).
If your data is not reliable, you risk returning data for the wrong person or not finding a pension record when you should. This may lead to enforcement action being taken against you by the Information Commissioner’s Office or by TPR.
Once you have reached your connection deadline you will need to be ready and able to supply data to dashboards once you have successfully matched a person to their pension. This might include the accrued and projected value of a member’s pension pot and annual income, depending on the type of benefit. The data will need to be provided very quicky - within three working days for DC benefits and within 10 working days in other cases such as DB or hybrid benefits – so it is vital that accurate data is available before your connection date arrives.
If you haven’t already done so, the first step in your dashboard connection journey should be putting in place a plan to improve the accuracy of your data and to digitise any data which is not already held digitally.
Data protection laws must be complied with throughout the dashboard connection process (and beyond) so specific legal advice on data protection issues is likely to be necessary. You may need to update your data protection policies, put in place or update your Data Protection Impact Assessment and review agreements with third party service providers who are assisting you with your dashboards connection, such as your administrator.
It is important from a general trustee knowledge and understanding (TKU) perspective that the trustee board is familiar with its new duties in relation to dashboards, but it will also be vital to have one or more trustees who are fully immersed in the detail.
Trustees should make it a priority to review TPR’s initial guidance on pensions dashboards, and we can offer scheme specific training on the new dashboard duties for trustees who need some assistance in this area.
Other useful resources to help trustees stay up to date on dashboard developments include the PDP website, the government’s consultation on the draft regulations, and MaPS standards on the practical operation of dashboards and the digital ecosystem (the standards have not yet been finalised but a summary of the PDP’s approach can be found here).
So, if it is not already, put pensions dashboards on your agenda and start preparing for the challenge that lies ahead.
Please contact Suzanne Burrell or Eleanor Taylor or your usual pensions contact at Shoosmiths for further support.
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