Project Overview
A UK regulated pension provider with £8.4B AUM, 280,000 pension scheme members, and obligations under the Pens...
Technology Stack
Compliance & Standards
The Challenge
A UK regulated pension provider with £8.4B AUM, 280,000 pension scheme members, and obligations under the Pensions (Extension of Automatic Enrolment) Act 2023 needed to implement Pension Dashboards connectivity — allowing members to view their pension data on the Pension Dashboards Programme (PDP) ecosystem via MaPS (Money and Pensions Service). PDP technical standards (ISP — Integrated Service Provider), UK GDPR, FCA COBS (personal pension schemes), TPR (The Pensions Regulator) requirements, and WCAG 2.1 AA were mandatory. Budget: £120,000.
Our Approach
ISP Connection
Pension Dashboards Programme (PDP): national infrastructure for UK pension data aggregation.
Architecture
pension provider → ISP (Integrated Service Provider — PDP-authorised middleware) → MaPS Pension Dashboards ecosystem → consumer dashboard (various dashboards — MoneyHelper, commercial).
ClickMasters integration role
build pension provider's ISP connection layer.
ISP APIs
- 1Find (consumer queries for pension data — find matching pension record by consumer demographics),
- 2View (return pension data for matched record — benefit statement, accrued rights, projected pension),
- 3Confirm (member confirms pension record is theirs).
PDP technical standards
- PDP ISP API specification (JSON over HTTPS, OAuth 2.0, PDP-specific data schemas).
- Pension Data Schema Mapping —
PDP data schema
accrued rights (defined benefit — current accrued benefit in today's money), projected pension (defined contribution — projected fund value at retirement), state pension age, retirement date, and scheme details (scheme name, type, administrator contact).
Data mapping complexity
pension provider systems (legacy AS400, Tuliip, or Oracle Pension Administration) store pension data in proprietary formats — PDP requires standardised JSON.
ETL pipeline
pension administration system → data extraction (daily batch) → data transformation (legacy schema → PDP JSON schema) → ISP API endpoint.
Data quality
- PDP rejects records with missing mandatory fields — automated data quality checks before ISP API serves PDP queries.
- Find API —
PDP Find API
consumer queries for their pension data using their identity attributes (name, date of birth, National Insurance number, address).
Pension provider find logic
query consumer identity against pension administration database (member records).
Matching sensitivity
false positive (returning another person's pension data) is a critical UK GDPR breach — zero tolerance.
ClickMasters matching algorithm
- exact match required on NI number + date of birth (deterministic — no fuzzy matching).
- Where NI number not available in legacy system (pre-1980 data gaps): date of birth + surname + first 3 digits of postcode (probabilistic match — only returned with human review flag).
Data minimisation
only the minimum data required for matching is compared — no unnecessary data processing.
PDP member notification
pension provider must notify all members that their pension data is available on Pension Dashboards.
Notification channels
email (GOV.UK Notify), letter (Royal Mail), and member portal notification.
PDP UK GDPR
pension data on dashboards is processed under UK GDPR legitimate interest (pension administration) — no new consent required for PDP data sharing.
However
member has right to object to PDP data sharing — opt-out workflow (member opts out → pension provider flags record → Find API returns no match for that member).
Member education
plain English explanation of Pension Dashboards (what it is, how it works, how to view their pension, how to opt out).
The Results
PDP connectivity confirmed by MaPS.
Platform live at 20 weeks, £112,000 — under budget. 280,000 pension records PDP-connected.
Find API accuracy: 99.84% (0.16% manual review — NI number unavailable).
False positive rate: 0.00% (zero wrong pension data returned in first 12 months).
PDP data quality: 97.8% of records pass PDP schema validation on first pass.
Member notifications: 100% notified (email + letter).
Opt-out rate: 2.4% (in line with MaPS estimate).
TPR compliance confirmed.
FCA COBS confirmed.
“280,000 members PDP-connected. Find API 99.84% accuracy. False positive 0.00% — zero wrong pension data in 12 months. PDP data quality 97.8% first-pass. Member notification 100%. MaPS connectivity confirmed. TPR and FCA confirmed. The false positive requirement — never returning the wrong person's pension data — was the non-negotiable design constraint. ClickMasters' NI number-first matching with human review for probabilistic matches was the right architecture for a zero-tolerance data protection requirement." — Head of Digital, UK Pension Provider (name withheld)”
Project Details
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