FCA Handbook - PDCOB 8.2 Requirement to incorporate the choice architecture

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PDCOB 8.2 Requirement to incorporate the choice architecture

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

(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)
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.

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

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

The choice architecture 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?
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

In 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:

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

Where 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)
select the choice in accordance with the first column of the table in PDCOB 8.2.8R; and
(2)
be directed in accordance with the second column of the table in PDCOB 8.2.8R where that selection is made.

A 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.

The 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

Where 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)
is able to select the choice in accordance with the first column of the table in PDCOB 8.2.11R; and
(2)
is directed in accordance with the second column of the table in PDCOB 8.2.11R where that selection is made.

A 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.

The 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.

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

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

Where 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.

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.