How you say it

While the Swedish ‘orange envelope’ for pensions communications hasn’t yet been adopted here, the concept gives us food for thought: simple, attention grabbing and informative.

The Pensions Regulator’s (TPR’s) issued draft single code reminds us of some sensible principles to apply. It expects communications to:

• be “accurate, clear, concise, relevant and in plain English”
• make use of technology appropriate for their scheme’s membership, and that a variety of methods should be considered
• be accessible, both in terms of format (e.g. audio, Braille, large font), and languages (other than English) used
• communications should also be regularly reviewed, taking account of any member feedback.

What you say

A good website (ideally one that works well across mobile formats) can be a powerful communication tool. But schemes mustn’t forget the data protection angles here. If a website allows members to access or upload any personal data (e.g. a new address, or change to death benefit nominations), trustees must ensure that data protection requirements are being met. If, for example, engagement is monitored, with data collected to track usage of the website, the data policy must permit that, and that purpose must be reflected in the privacy notice. This could be covered off in any campaign to launch or refresh the site or to encourage members to log in.

And what if schemes want to offer financial education?

Trustees and employers have had a recent reminder to reassess the focus of member communications. In March, the Financial Conduct Authority (FCA) and TPR launched updated guidance for schemes on “providing support with financial matters without needing to be subject to FCA regulation”.

The commentary and examples clarify behaviours which could stray across the line to ‘arranging or advising’ on transactions, and which would then require FCA authorisation. In particular, this includes providing members with benefit illustrations (unless with context and caveats, and without encouragement), or examples of the decisions someone should make regarding their benefit options. All member communications need to strike the right balance between giving factual information, and signposting independent advice and information services like The Pensions Advisory Service (TPAS) and Pension Wise (both shortly to be rebranded as MoneyHelper).

This seems like a useful point in time to consider communications afresh and to check that ‘how you say it’ is powerful without being problematic.