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  1. Point in time
    2024-12-02

PDCOB 8.1 Purpose

PDCOB 8.1.1 G
  1. (1)

    1The purpose of the rules in this chapter in relation to the choice architecture is to enable customers to identify and understand the steps available and be in control of which steps they take in the qualifying pensions dashboard service.

  2. (2)

    The exit communications rules (at PDCOB 8.4) will ensure that customers are informed about when an action will take them outside of the qualifying pensions dashboard service. They are intended to assist customers to take appropriate care when viewing material outside of a qualifying pensions dashboard service.

PDCOB 8.2 Requirement to incorporate the choice architecture

PDCOB 8.2.1 R

1Subject to PDCOB 8.2.6R and PDCOB 8.2.9R, a firm must ensure that:

  1. (1)

    its pensions dashboard platform gives a customer choices:

    1. (a)

      in accordance with the first column of the table in PDCOB 8.2.4R;

    2. (b)

      which direct the customer in accordance with the second column in the table at PDCOB 8.2.4R; and

    3. (c)

      at the times described in PDCOB 8.3.1R; and

  2. (2)

    the customer can only progress beyond the times described in PDCOB 8.3.1R after they have made a selection from one of the choices set out in the first column of the table in PDCOB 8.2.4R or, where relevant, the first column of the table in PDCOB 8.2.5G, PDCOB 8.2.8R or PDCOB 8.2.11R.

PDCOB 8.2.2 R

1For the purposes of PDCOB, the provision of the choices as described in PDCOB 8.2.1R is referred to as the choice architecture.

PDCOB 8.2.3 G

1 PDCOB 8.5 provides rules and guidance in relation to the presentation of the choice architecture.

PDCOB 8.2.4 R

1The choice architecture is set out in the following table.

1 Choice offered to user

Where to direct the user if they select the choice offered

Does the direction take the user outside the pensions dashboard service?

In all cases

Take no further action

Redirect to:

(1) the firm’s wider digital environment outside of the qualifying pensions dashboard service from where the consumer can, if desired, take up other information, services and/or activities offered by the firm; or

(2) the digital estate of a third-party access dashboard provider, but only where a firm has agreed to this as part of the third-party dashboard arrangement that it has with that particular third-party access dashboard provider.

Yes

Obtain further information, support and impartial guidance from Money and Pensions Service MoneyHelper

Redirect to MoneyHelper.

Yes

Find an adviser (that is regulated by the FCA and has permission to make personal recommendations)

Redirect the customer to MoneyHelper to obtain impartial information about finding a financial adviser.

Yes
PDCOB 8.2.5 G

1In addition to the choices set out in PDCOB 8.2.4R, a firm may offer the additional choices set out in the table below to a customer as part of the choice architecture:

1 Choice offered to user

Where to direct the user if they select the choice offered

Does the direction take the user outside the pensions dashboard service?

Raise a question or complaint about the service or the pensions dashboard view data, where relevant

Redirect to the central complaints service for Money and Pensions Service.

Yes

Review, revoke or amend consents originally granted at the Consent and Authorisation Service.

Redirect to the Pensions Dashboard Programme Consent and Authorisation service to manage consents.

Yes

PDCOB 8.2.6 R

1Where a firm offers post-view services, the firm must, in addition to the requirements in PDCOB 8.2.1R, and PDCOB 8.2.9R where relevant, ensure that the choice architecture enables the customer to:

  1. (1)

    select the choice in accordance with the first column of the table in PDCOB 8.2.8R; and

  2. (2)

    be directed in accordance with the second column of the table in PDCOB 8.2.8R where that selection is made.

PDCOB 8.2.7 R

1A firm must ensure that a customer can only access post-view services by selecting the choice in accordance with the first column of the table in PDCOB 8.2.8R and that the choice is only offered as part of the choice architecture.

PDCOB 8.2.8 R

1The additional choice to be offered as part of the choice architecture to a customer for the purposes of PDCOB 8.2.6R is set out in the following table.

Choice offered to user

Where to direct the user if they select the choice offered

Does the direction take the user outside the pensions dashboard service?

Explore and/or use a post-view service offered by the firm

Continue to the firm’s post-view service.

No
PDCOB 8.2.9 R

1Where a firm enables a customer to obtain a copy of their pensions dashboard view data through data export to the customer, the firm must, in addition to the requirements in PDCOB 8.2.1R, and PDCOB 8.2.6R where relevant, ensure that the customer:

  1. (1)

    is able to select the choice in accordance with the first column of the table in PDCOB 8.2.11R; and

  2. (2)

    is directed in accordance with the second column of the table in PDCOB 8.2.11R where that selection is made.

PDCOB 8.2.10 R

1A firm must ensure that a customer can only obtain a copy of their pensions dashboard view data through data export to themselves by selecting the choice in accordance with the first column of the table in PDCOB 8.2.11R and that the choice is only offered as part of the choice architecture.

PDCOB 8.2.11 R

1The additional choice to be offered as part of the choice architecture to a customer for the purposes of PDCOB 8.2.9R is set out in the following table.

1 Choice offered to user

Where to direct the consumer if they select the choice offered

Does the direction take the user outside the pensions dashboard service?

Obtain a copy of their pensions dashboard view data

Customer taken through data export process to themselves.

No
PDCOB 8.2.12 G

1A firm may offer a single choice for all post-view services or one choice for each post-view service that it offers.

PDCOB 8.2.13 G

1Where a customer elects to export their data to populate a post-view service, the firm should enable the customer to move to the relevant part of the qualifying pensions dashboard service, to ensure compliance with PDCOB 11.5.

PDCOB 8.2.14 G

1 Firms are reminded of their obligations under DISP 1.3, in particular, to establish effective and transparent procedures for the reasonable and prompt handling of complaints.

PDCOB 8.4 Exit communications requirements

PDCOB 8.4.1 R

1Where a customer makes a choice from the choice architecture that would cause them to exit the qualifying pensions dashboard service, the firm must communicate to the customer:

  1. (1)

    that they are exiting the qualifying pensions dashboard service;

  2. (2)

    that their pensions dashboard view data will not be visible outside the qualifying pensions dashboard service;

  3. (3)

    where they are being directed to; and

  4. (4)

    that information seen by them after they have exited the qualifying pensions dashboard service will not be customised to them, or their pensions dashboard view data.

PDCOB 8.4.2 G

1 Firms should determine the design, form, language and delivery of the exit communications in PDCOB 8.4.1R and are reminded of their obligations under Principle 12 and the retail customer outcome on consumer understanding in PRIN 2A.5.

PDCOB 8.4.3 G

1 Firms are reminded of their obligations in PDCOB 4 in relation to communications. In particular, firms are reminded of the requirement that any communication it makes must be clear, fair and not misleading.

PDCOB 8.4.4 R

1Where a customer is provided with a link in circumstances other than those in PDCOB 8.4.1R that would cause them to exit the qualifying pensions dashboard service, a firm:

  1. (1)

    (subject to (2)) must comply with the exit communication requirements in PDCOB 8.4.1R(1), (2) and (4); and

  2. (2)

    must comply with the requirement in PDCOB 8.4.1R(3) unless it would be reasonable to conclude that it would be clear to a customer to where they are being directed, in which case, the firm may comply with that requirement if it wishes to do so.

PDCOB 8.4.5 G

1An example of where it would be clear to a customer to where they are being directed would be where a customer is provided with a link to the website of a particular pension scheme administrator in their pensions dashboard view data which would cause them to exit the qualifying pensions dashboard service, which makes it clear to the customer that they will be directed to that particular pension scheme administrator’s website.

PDCOB 8.4.6 G

1For the avoidance of doubt, PDCOB 8.4.4R applies where a firm places an advertisement on its pensions dashboard platform with a link to a website outside of the pensions dashboard service, which may or not be a website belonging to the firm.

PDCOB 8.5 Presentation of the choice architecture

PDCOB 8.5.1 R

1A firm must ensure that the choice architecture is designed such that the presentation of the choices is:

  1. (1)

    accessible to the customer from the point at which they access their pensions dashboard view data onwards;

  2. (2)

    impartial, so that the customer is able to easily identify all of the choices available to them; and

  3. (3)

    designed in a way that enables the customer to understand all the choices available to them and to make choices based on this understanding.

PDCOB 8.5.2 G

1A firm may choose the design, form, language and delivery for the presentation of the choices.

PDCOB 8.5.3 G

1The following are examples of factors which may be relevant to a firm when designing the choice architecture:

  1. (1)

    whether each choice should be presented in the same way (this does not necessarily mean that the choices must be presented together as a whole); and

  2. (2)

    the use of pop-ups, layering, or drop-down functionality to present the choices. The choices may be grouped in common themes, but a firm should ensure that all choices remain easy to locate and that certain choices are not hidden or obscured.

PDCOB 8.5.4 G

1 Firms are reminded of their obligations under Principle 12 in relation to the consumer understanding outcome and communications to retail customers, in particular:

  1. (1)

    PRIN 2A.5.3R, which requires firms to support retail customer understanding and to communicate information to retail customers in a way which is clear, fair and not misleading; and

  2. (2)

    PRIN 2A.5.10R, which requires firms, where appropriate, to test and monitor communications to identify whether they are supporting good outcomes for retail customers and correct any deficiencies identified.

PDCOB 8.5.5 G

1 Firms are reminded they must comply with the requirements of Principle 12 and PRIN 2A on product design and product testing. In particular, firms are reminded of the requirements in PRIN 2A.3.4R, PRIN 2A.3.9R and PRIN 2A.3.10R, and should assess whether the presentation of the choice architecture:

  1. (1)

    is designed to meet the needs, characteristics and objectives of the target market;

  2. (2)

    does not adversely affect groups of consumers in the target market including groups with characteristics of vulnerability; and

  3. (3)

    avoids causing foreseeable harm to the target market.

PDCOB 8.5.6 G

1 Firms should make changes to improve their communications if common areas of consumer misunderstanding are identified through a firm’s testing or monitoring.