Project Overview
A UK occupational pension scheme provider managing £2.4B AUM for 18,000 members needed to connect their scheme...
Technology Stack
Compliance & Standards
The Challenge
A UK occupational pension scheme provider managing £2.4B AUM for 18,000 members needed to connect their scheme to the Pensions Dashboards Programme (PDP) — the UK government's initiative enabling pension savers to see all their pensions in one place. FCA and TPR (The Pensions Regulator) dual regulation, PDP ISP (Integrated Service Provider) technical standards, UK GDPR for pension member data, and Consumer Duty for pension products were the requirements. Budget: £100,000.
Our Approach
Pensions Dashboards Programme
pension providers must connect to the MoneyHelper Pensions Dashboard via a PDP-accredited ISP (Integrated Service Provider).
Technical standard
PDP API v2.0 (REST, OAuth 2.0, JSON).
Required endpoints
find pensions (POST /find — respond with matched pension details), view pensions (GET /view — return pension value, projected income, retirement date).
Data standard
PDP data model (pension type, pension arrangement, benefit type, retirement date, values).
ISP selection
Origo Interface as ClickMasters-recommended ISP.
PDP member matching
pension holder submits find request with name, date of birth, NI number, and address.
Matching algorithm
deterministic matching (exact NI number match) + fuzzy matching (name + DoB for approximate matches).
UK GDPR
NI number is a sensitive personal identifier — encrypted in transit, not stored in application logs.
False positive risk
returning a pension to the wrong person is a significant GDPR breach — matching confidence threshold set conservatively (high precision over recall).
Consumer Duty Pension Product Disclosure
FCA Consumer Duty PS22/9 applies to pension providers from July 2023.
Pension product disclosure requirements
clear statement of pension arrangement type, retirement date, estimated retirement income (Money Purchase Statement — annuity or drawdown basis), and associated charges (in £ and %).
PDP view response
all required Consumer Duty disclosures formatted to PDP data standard.
Occupational pension schemes
regulated by TPR (The Pensions Regulator) for scheme governance and FCA for any retail investment component.
Compliance mapping
- TPR Scheme Return data — pension member records match TPR registered membership.
- FCA consumer communications — pension projections comply with COBS 13 (projections for retail clients).
Data sharing
PDP requires sharing member pension data with dashboard providers — ICO DPIA required for this new data sharing activity.
The Results
PDP connection live.
TPR staging deadline met (June 2025 mandatory staging). 18,000 member records matched and verified.
Find request processing time: p95 < 400ms (PDP SLA: < 2 seconds).
View request processing time: p95 < 600ms.
FCA Consumer Duty pension disclosure: legal review confirmed compliant.
ICO DPIA accepted.
TPR compliance review: zero findings.
PDP team: scheme praised for early staging and data quality.
“TPR staging deadline met — some schemes are months late. 18,000 members now visible on the MoneyHelper dashboard. The matching algorithm getting high precision was critical — a false positive is a serious GDPR event. PDP team praised our data quality. Consumer Duty pension disclosure legally reviewed and confirmed — no remediation required." — Scheme Administrator, UK Occupational Pension Scheme (name withheld)”
Project Details
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