By John Dale, Pensions Dashboards Lead
The Local Government Association (LGA) released their draft Pensions Dashboards Connection Guide for LGPS Administering Authorities on 6 November 2023.
It’s an excellent summary of the steps you need to take when you embark upon your dashboard connection journey, from engaging with stakeholders to selecting an Integrated Service Provider (ISP), like Heywood.
The guidance provided by the LGA has been targeted specifically at Local Government Pension Scheme administering authorities to help you create a project plan – though the messaging should resonate across all pension providers.
It includes details of the actions and decisions you will need to take, cross-referenced against your statutory obligations, with helpful timing information where appropriate.
In the article, we've broken down the Guide and highlighted the key areas where Heywood can support you in your Dashboards preparations.
Click to jump to section:
- Keeping you and your stakeholders up to date
- Accuracy and accessibility of data
- Internal controls and record-keeping
- Connecting to Dashboards
- Connecting to the ecosystem
- Matching criteria
- View data - process, accuracy & accessibility
- Additional Voluntary Contributions (AVCs)
- View Data in detail
- Timing to provide all View Data
- Operational information and reporting
- What should I do next?
Why should I read it?
The Pensions Regulator launched a campaign in October urging the industry to continue with their preparations for dashboards, with a key call to action to download TPR’s checklist to keep track of progress.
The core messages of the campaign are:
- Preparing for dashboards will take time
There is a significant amount of work you need to do. Don’t down tools while you wait for your target connection date.
- Work with those who are supporting you to develop a practical delivery plan
Understand what you’ll need to do, when, and where to go for help and support. Use TPR’s checklist to keep track of your progress, and make sure that you maintain records of key decisions made.
- Get to grips with the data that’s needed for dashboards
Accurate data is at the heart of dashboards but it also has significant benefits beyond. Understand the steps you can take today to make the most difference.
Don’t worry, we’ve got all bases covered for you
We have summarised the key messages from the LGA’s draft Pensions Dashboards Connection Guide for LGPS Administering Authorities below (the key messages from the draft Pensions Dashboards Connection Guide are summarised in italics.):
Keeping you and your stakeholders up to date
As part of your day-to-day governance of implementing dashboards you should keep up to date with the latest guidance and developments.
You should also discuss dashboards with your relevant stakeholders to make sure they are up to date with the latest developments. Relevant stakeholders are, though not limited to, your software provider, actuary, legal adviser, employers, AVC provider(s) – including those providers who maintain closed AVC policies, and if your administration is handled by a third party, your third-party administrator.
To support pension providers in their preparations, we launched our Pensions Dashboards Hub in spring 2023, our one-stop resource to keep customers updated on the Pensions Dashboards Programme (PDP).
Accuracy and accessibility of data
You must digitally hold your pension records so they can be digitally matched and returned for display, on whichever dashboard your members choose to use.
Consequently, all value data must be accurate and digitally accessible. This includes your AVC data.
You should already be complying with TPR’s Common and Scheme-specific data record keeping and regularly reporting your data quality measures, as part of your TPR scheme return. You should incorporate dashboards data requirements into your wider data management plan including your approach to cleansing and matching your AVC data.
Heywood can provide you with a free Dashboard Readiness Report to assess the quality of your find and view data, so you can:
- Obtain a clear view on how accurate your member data is
- Formulate a plan for cleansing and updating your data to get it dashboards ready
- Locate and reach more members, increasing engagement
Internal controls and record-keeping
You are expected to operate internal controls in line with TPRs general code. The consultation on the new general code closed in May 2021. TPR published an interim response in August 2021 and is expected to publish the final version in 2023 / early 2024.
The internal controls are, though not limited to:
- reviewing and assessing the quality of both your main scheme data and AVC data and putting in adequate controls for continuous improvement
- having appropriate controls when selecting, appointing and managing service providers
- having risk management processes in place, including processes for monitoring the resolution of issues between the scheme and any relevant third parties
- having processes in place to identify breaches of the law and, if necessary, report them to TPR.
You must also keep:
- clear audit trails of how you took steps to prepare to comply with your dashboard duties
- a record of compliance as set out in MaPS reporting standards, and a record of steps taken to resolve any issues that arose, such as communications with third parties
- records of your main scheme matching policy and AVC matching policy
- records of the steps taken to improve your main scheme data and AVC data.
Our team will seamlessly handle your PDP reporting duties, adhering to the highest standards set by the PDP Reporting Standards. The complementary Insights PDP Dashboards will provide you with detailed activity summaries, possible match statistics and view data failures. We will store your matching configuration history for a minimum of six years in line with legislation and if you sign up for our full data cleansing service, you will have all the data improvement evidence you need from your regular data cleansing reports.
Connecting to the Dashboards
Unless you are able to defer your connection, you must connect to the ecosystem by 31 October 2026. This applies to both your main scheme benefits and your A V C arrangement(s). Both arrangements must connect at the same time – even where the A V C provider has a different connection date.
You should also have regard to the staging guidance, published by the Secretary of State for Work and Pensions and MaPS. The staging guidance will contain a timeline indicating when you are scheduled to connect. This will be significantly earlier than 31 October 2026. We will update this guide with your staging timeline when the guidance is published. The staging guidance might provide for connecting before your staging timeline. If this is the case, we will update this guide with the details.
From the outset of connection you must be able to:
- meet the required standards (connection, security and technical)
- be able to respond to find requests, complete matching and provide administrative data, value data and contextual information on request, to members accessing dashboards.
Heywood is fully compliant with the PDP’s Data, Reporting, Code of Connection and Technical standards, which means you don’t have to worry about meeting the required standards or responding to find and view requests within the strict SLAs. Our implementation team will work with you throughout the ISP project to ensure you connect in line with your expected connection date.
There are two aspects to your budget to consider. A connection budget and an ongoing business as usual (BAU) budget.
The connection budget includes your operational and system start-up costs, to connect to the ecosystem.
Your BAU budget takes into account your operational and system costs for maintaining a connection to the ecosystem.
Our comprehensive ISP service and optional value-added features can handle it all for you. We have utilised Amazon Web Services (AWS), to construct and deploy our ISP. AWS is a serverless and cost-effective model, giving the scalability and flexibility required for the Dashboards.
Remember, once you're connected, you need to remain connected.
Connecting to the ecosystem
You must connect to the dashboards ecosystem by 31 October 2026 (unless you are able to defer connection). You should also have regard to the staging guidance that will be published by the Secretary of State for Work and Pensions and MaPS. The staging guidance will contain a timeline indicating when you are scheduled to connect.
You need to decide how you are going to connect to the dashboards ecosystem.
You can connect directly or via a third party - an integrated service provider (ISP).
Whichever approach you take, you remain responsible for ensuring you are connected to dashboards ecosystem on time and that your connection remains compliant. You should ensure robust processes are in place for the selection, appointment, management, and replacement of any suppliers.
Selecting an ISP is the most efficient and cost-effective way to connected to the PDP ecosystem. At Heywood, our implementation team will work closely with you throughout the project to ensure you connect in line with your expected connection date. It’s worth noting that the later you leave it, the more likely it is that you encounter bottlenecks in the process.
You need to understand what personal data and contact information you will receive from the pensions finder service to help you match members to their pension records – this is called ‘find data’.
From the find data, having regard to guidance issued by MaPS, it’s your decision what you use to match members on your pensions administration software system. You will find it helpful to chat to your ISP in deciding. If you have agreed with your AVC provider for them to send your AVC view data directly to dashboards on your behalf, you should establish a consistent approach to matching.
You need to decide on your matching criteria for a:
- maybe match.
Effective data-matching criteria is essential for the success of the pensions dashboards. We have developed flexible, scheme-specific matching criteria, in line with the guidance provided by PASA. We are also developing an intuitive user interface to allow customers to set, change and test their data-matching convention individually or in bulk. Once a member has been fully matched, you will be able to see a summary of the view data that would have been sent to the dashboards if the service was live.
View data - process, accuracy & accessibility
Following a successful find request, you must return view data by way of your ISP to your member’s choice of dashboard within the legal timescales. The timescales are explained in section 17.
If a find request raises a ‘maybe match’, you must return limited administrative data within legal timescales.
Although your ISP will retrieve view data from your pensions administration software system, you need to understand what view data you will need to return to members who access dashboards and in what timescale.
Our ISP service is fully compliant with the PDP regulatory framework and will operate within the SLAs detailed within the PDP Reporting, Technical and Code of Connection standards.
Additional Voluntary Contributions (AVCs)
Regardless of the approach taken by your AVC provider(s) you are responsible for the accuracy and provision of AVC view data to dashboards. You should discuss with your AVC provider(s) how they intend to provide AVC value data.
Approach 1 – AVC value data sent direct to dashboards by AVC providers
Following a successful find request, the AVC provider will send the AVC value data directly to dashboards. There will be a pension code to link the member’s main scheme benefits with their AVC benefits.
Approach 1A – AVC value data sent direct to dashboards by AVC providers
Potentially there is another approach where AVC value data is sent direct to dashboards by AVC providers. This is where the pension code to link the member’s defined benefits with their AVC benefits is not used. The National LGPS Technical Group is looking at this area in more detail.
Approach 2 – AVC value data periodically sent to for you to send to dashboards
The AVC provider will send you the AVC value data periodically. The AVC view data will need to be stored in a digitally accessible mode. You will need to agree the frequency of the periodic data provision with your AVC provider(s). Following a successful find request, you will send the AVC value data directly to dashboards.
We are working closely with the PDP, LGA and AVC providers to ensure that we can support all three methods of returning AVC data to the dashboards, so you have the flexibility to choose the most appropriate solution for your fund.
We are developing a new data view and interface in Altair to store the AVC data to support approach 2 and further work is being scheduled to store the pensions link referred to in approach 1.
Non-Altair customers can provide all the necessary data in their ISP file extract.
View Data in detail
View data comprises of administrative data, signpost data, value data and contextual information. This is in respect of both the member’s main scheme benefits and AVCs.
This is broken down into three subcategories:
- Pension arrangement data
Information about the pension arrangement within which the individual has a pension, or a right to claim a benefit.
- Administrator data
Information about the organisation which the individual should get in touch with, to find out more about their pension benefits.
- Employer data where available
Information about the employment that gave rise to the pension. If the pensionable service relates to more than one employer you can choose to name either the most recent employer or confirm there are multiple employers within the same record.
We do not believe signpost data applies to the LGPS. This is because it includes costs, charges, an implementation statement and an annual report. If this understanding changes, we will update this guide.
Value data – main scheme benefits
Value data is information about the value of the member’s main scheme pension benefits. It does not include the value of any survivor benefits.
Value data is taken from either:
- an annual benefit statement (ABS) provided to the member within the last 13 months, even if the value in the ABS was calculated more than 13 months ago, or
- a calculation performed for the member within the last 12 months, whether or not the calculation was done in response to an earlier view request.
Value data represents the value of the member’s pension benefits calculated without regard to possible increases in earnings:
- on the illustration date - calculated as if the member had reached their normal pension age, and
- for active members only, projected to the member’s normal pension age.
Value data – AVCs
AVC value data is information about the value of the member’s AVC pot.
From 1 October 2023 and after a pension illustration has been provided, value data represents:
- an annualised accrued value calculated as if the individual had reached their retirement date on the illustration date
- if held, a projected pot value, and
- an annualised projected value.
The AVC illustration dates, both for accrued value data and estimated retirement income must be the same as what you use for the main scheme benefits.
The AVC payable date can be different to the main scheme. PDP have advised it is for each scheme to decide these dates based on the scheme’s structure and design.
An effective ISP will automate the transfer of all find and view data, and the data refresh frequency can be specified by each customer (daily, weekly, etc.).
Storing find and view data in the ISP ensures compliance with CoCo2.1.5 of the PDP’s Code of Connection Standard, which states that pension providers and schemes must be available for 99.5%, 24/7, measured monthly.
Timings to provide all View Data
More information can be found in:
- TPR dashboards initial guidance: https://www.thepensionsregulator.gov.uk/en/trustees/contributions-data-and-transfers/dashboards-guidance
- PDPs dashboards view data page: https://www.pensionsdashboardsprogramme.org.uk/data-providers/view-data/.
This section sets out the timings by when you must provide all view data following a member’s request via a dashboard. It reflects our understanding of the intention of the regulations. If your AVC provider(s) adopts approach 2 and sends AVC value data directly to you to send to dashboards, the timescales in this section apply equally to AVC value data.
Your ISP should be able to alert you if it has been unable to fully respond to a view request because of missing value data. This will provide a trigger for your administration team to ensure the missing value data is available within 10 working days as per the Pensions Dashboards Regulations 2022.
Operational information and reporting
You must provide operational information to MaPS, TPR and FCA upon request. This is provided in accordance with the reporting standards. The reporting standards set out the requirements you must meet for generating, recording and reporting data.
All pension provider or scheme operational reporting, as detailed in the PDP Reporting Standards, is performed by the ISP automatically using APIs. Reporting data is sent to MaPS in either near real-time, every 60 seconds or daily, depending on the reporting standard frequency.
What should I do next?
If you haven’t started your Pensions Dashboard Project already, you should do so as soon as possible. Data readiness should be one of your first priorities and don’t forget to select an Integrated Service Provider (ISP) to take the sting out of connecting to the Pensions Dashboards Programme’s ecosystem.
Data solutions to get you ready for Dashboard and more
Our data solutions and services will help you get ready to connect to the Pensions Dashboards and more, providing you with improved data quality for all your administration requirements.
Our ISP solution will ensure you have a robust, secure, compliant and fully integrated solution for connecting to the Pensions Dashboards ecosystem. The Heywood ISP has been designed to be compliant with the requirements proposed by the DWP regulations, FCA consultation paper (CP22/3), TPR requirements and MaPS codes and standards.