What did happen
74. Here we consider the various steps DWP took to communicate changes to State Pension age. We then go on to consider the research conducted by and on behalf of DWP and the actions it took following that research.
75. For the purposes of our investigation, we selected a sample of six complaints. The sample complaints reflect the range of issues women have complained to us about. Along with other complainants who are not part of our sample, they formed part of the target audience for DWP’s communication campaigns. It is therefore appropriate for us to consider DWP’s broader communications strategy and its adequacy.
76. DWP told us it made considerable efforts to communicate State Pension age changes and to ensure those affected could access detailed and bespoke information about their State Pension entitlement, including:
- running pensions education campaigns, which included information about State Pension age equalisation
- publishing ‘numerous’ leaflets from 1995 onwards
- making State Pension age clear in the 22 million State Pension statements issued online, by post or over the telephone since 1995
- issuing around 17.8 million automatic pension forecasts (APFs) between 2003 and 2006 with a leaflet explaining the increase in State Pension age for women
- making information about State Pension age available on its website, including an option for individuals to calculate their State Pension age
- writing to 1.2 million women affected by the Pensions Act 1995 between 2009 and 2011, and those affected by the Pensions Act 2011 between January 2012 and November 2013.
Pensions education campaigns
77. The evidence we have seen confirms DWP did make considerable efforts - across a variety of formats and using a range of media channels and stakeholders - to promote pensions awareness and planning for retirement through its pensions education campaigns. This included:
- a TUC-led ‘Pension Power for You’ campaign and helpline in 1997, and a second TUC helpline campaign in 1999 that was partly government-funded
- a ‘Monopoly’-themed pensions campaign (June 1998 to April 2000). Adverts were displayed on buses and trams, in telephone boxes, on fast food containers and on screens in Post Offices. Adverts, advertorials and inserts were placed in national and local press, magazines and catalogues. Information was shared through mailings and mailshots (based on marketing data), in pensions packs, on flyers and at exhibitions. A new series of pensions leaflets (PM1-8) and a pensions website were also introduced
- a ‘Working Dogs’-themed pensions campaign (January 2001 to March 2004). Adverts were placed in national and local press, on postcards, and shown in cinemas and on television
- various waves of issuing information about pensions, including information about State Pension age changes, direct to people who requested it, who had responded to surveys and to advisers.
78. Pensions education campaigns focused on encouraging individuals to understand their pension entitlement and plan their retirement. DWP has said these campaigns included material relating to women’s State Pension age specifically targeted at women. However, a relatively small proportion of the campaign material we have seen refers to State Pension age:
- one ‘Monopoly’ advert (‘Don’t Leave Your Pension to Chance’) in the local press from 1999 says, half-way through, that ‘all women born after 6 April 1955 will have to wait until they are 65 before they can claim their State Pension’. It does not mention that women born between April 1950 and April 1955 will also be affected by State Pension age changes
- an advertorial in two women’s magazines from 2000 says ‘from 2020, women will be getting their State Pension at 65 – the same as men’. It includes a table showing when women can claim their State Pension, depending on their birthday
- two ‘Working Dogs’ adverts in the national press from 2001 say State Pension age is ‘changing to 65 to make it the same as men’
- information sent on request during the ‘Working Dogs’ campaign included a flyer ‘What every woman needs to know about pensions’, and the PM6 ‘Pensions for Women’ leaflet
- a ‘Women’s Pensions Pack’ which was available through the Pension Service. As well as a leaflet, the pack included a cardboard ‘reckoner’, which allowed individuals to work out their State Pension age by adjusting a slider to their birthday
- information sent to respondents to lifestyle surveys during the campaigns included information about State Pension age changes and/or encouraged them to request leaflets (including PM6).
79. The need for an advertising campaign to tell women about the changes to State Pension age was considered in early 1997. The response to a ministerial submission in February 1997 said ‘Ministers do not see a pressing need at this stage to run such a campaign but would be prepared to re-consider at a later date.’
78. An internal DWP memo from September 1999 recommended that the feasibility and cost of publicising State Pension age changes should be looked into further.
79. Information about State Pension age changing was publicly available in the leaflets DWP published. We have reviewed almost 250 leaflets and guides published between 1993 and 2012 (various editions of 59 different leaflets and guides). The earliest (EQP1) was issued before the Pensions Act 1995 to forewarn of the proposed changes. It was updated and reissued promptly after the Act was passed in 1995 (EQP1A). Nearly seven in ten leaflets available over the following decade mention that women’s State Pension age is changing. A survey in 1999 found that 96% of respondents considered information in the leaflets was easy to understand.
80. Leaflets were available from Benefits Agency offices, by calling a helpline, by freepost, or (from around 1998) accessible online. Some were displayed in Post Offices, GP surgeries and by other stakeholders (such as Citizens Advice Bureaux). People were encouraged to request leaflets as part of the ‘Monopoly’ and ‘Working Dogs’ campaigns. And DWP sent copies of leaflets to men and women who had requested information about pensions in response to various surveys. Alongside the pensions packs, specific leaflets were enclosed with APFs (APF1 and APF2) and direct mailings from 2009 onwards (SPE01). The information in the EQP1 leaflet was also promoted on an A3-sized poster displayed in Benefits Agency offices.
State Pension statements
81. From July 1995, DWP started issuing State Pension statements (sometimes known as Individual Pension Forecasts) on request. We have seen an example of a forecast sent in 1999. The first paragraph includes the recipient’s State Pension age.
Automatic pension forecasts
82. Between May 2003 and November 2006, DWP sent unsolicited pension statements (automatic pension forecasts - APFs) to working-age people who had not received any other pension forecast during the preceding 12 months. It used a database based on National Insurance records (NIRS2) to issue APFs. DWP has told us APFs were another method of sharing State Pension information, but that communicating State Pension age changes was not the primary purpose of APFs. DWP’s Public Service Agreements from 2004 to 2006 show APFs were used as a tool to improve awareness about retirement provision, rather than to let people know when they could expect to receive their State Pension.
83. APFs do not mention that State Pension age is changing.
84. After the self-employed, the first tranche of APFs sent from December 2004 targeted women then aged 50 to 59 with a message that it was ‘especially important’ for them to think about how much money they would have in retirement because it was often less than men. Two leaflets were included with APFs (APF1 and APF2).
85. From around 2001, as well as information about State Pension age changing, an online State Pension age checker was available. By inputting their date of birth, women would have been shown their State Pension age.
86. Between April 2009 and March 2011, DWP wrote to 1.2 million people affected by the 1995 Act (including women born between 6 April 1950 and 5 April 1953). Due to proposals to increase State Pension age to 66, direct mailing was paused in March 2011. It resumed after the Pensions Act 2011 became law. DWP wrote to men and women affected by the 2011 Act between January 2012 and November 2013.
87. Examples we have seen of letters issued in April 2010 and January 2012 are headed, in bold text, ‘Important information about your State Pension age’. The date that the recipient can claim their State Pension is clearly stated on the first page. The letters say that further information is available online and include website addresses. A contact telephone number is also included.
88. Three complainants in our sample confirmed they received their letters but say they were given little time to adjust their retirement plans, in part because they say they did not know about the 1995 Act changes before they received letters about the 2011 Act changes. One complainant who turned 60 in December 2015 said she received her letter in 2013 telling her that her State Penson age had increased to 66. Another complainant turned 60 in late April 2015. She received her letter in October 2012 giving her 2.5 years notice of a six-year increase in her State Pension age. A third complainant who turned 60 in February 2019 received her letter in October 2013. This gave her 5 years and 4 months’ notice of a six-year increase to her State Pension age.
89. Three complainants from the sample group say they did not receive letters, despite being told during the complaints process that they would have been sent a letter between October 2012 and November 2013. DWP does not have a record of who it wrote to, so we are not in a position to clarify which women were sent letters. We cannot discount the possibility, though, that some letters were lost in the post, some were undeliverable due to incomplete address data, or some were received and mislaid or forgotten. We also recognise that a direct mail exercise is unlikely to achieve a 100% success rate.
Research and action taken as a result
90. DWP told us that since 1993 it has published a breadth of research reports relevant to State Pension age changes and pension reform. It also said that awareness of changes in State Pension age has been closely monitored since 1997, and action continuously taken to increase awareness. We have seen reports from the 1990s relating to pensions issues, but they say very little about the change to women’s State Pension age.
91. Various research has been done by different organisations over time (for example, the English Longitudinal Study of Ageing and research by Age UK). We focus here on research done by DWP or on its behalf.
92. The earliest DWP research about awareness of State Pension age we have found reference to was from 2000/2001. DWP has been unable to give us a copy of the findings, but they are discussed in a report produced in 2004. It says the research found that less than one third of women aged 18 to 55 in 2000/2001 knew their State Pension age was going to increase in future and only 35% of women knew their own State Pension age. The report says the 2000/2001 research concluded that action was needed to ‘… improve awareness of the age at which individual women will become eligible to start receiving their State Pension’. We have seen no further information about what more the researchers considered was needed at the time.
93. The first phase of the ‘Working Dogs’ campaign ran from January 2001 to March 2001 with TV, press and cinema advertising. The campaign continued after the research in 2000/2001 through to 2004. Waves of the campaign from March 2002 onwards included direct marketing as well as press and TV adverts.
94. DWP evaluated reaction to the first wave of its ‘Working Dogs’ campaign in March/April 2001. The evaluation focused on how the campaign materials were received and people’s intended actions, rather than awareness of State Pension age. Respondents were shown TV and press adverts used in the campaign. A quarter of respondents said they recognised at least one of the five press adverts. The press advert about equalisation was the most recognised. Despite this, respondents did not identify change to women’s State Pension age as a key message of the advertising.
95. Further evaluation of the ‘Working dogs’ campaign in 2002 does not appear to have looked at awareness of the changes to women’s State Pension age. Following this evaluation, DWP made proposals to the Secretary of State about continuing the pensions education campaign into autumn 2002. Those proposals included that women would be a particular target audience. The submission notes the campaign aimed to change people’s attitudes towards retirement saving, and that understanding pensions was part of that.
96. Research done the same year into attitudes to pensions and savings for retirement found that 70% of women whose State Pension age had increased to 65 still expected to retire before they reached that age. 40% expected to retire at 60. Respondents were not asked if they knew their State Pension age. This research was done in 2002 but reported in 2003. The ‘Working Dogs’ campaign, including direct marketing, continued after the research was done.
97. DWP research in 2003/2004 looked specifically at public awareness of State Pension age equalisation, and was reported in October 2004. 62% of working age women knew State Pension age was going to rise. This increased to 73% amongst all respondents aged 45 to 54 (women born in the 1950s would have been aged 45 to 54 in 2004). But only 43% of all women affected by the changes knew their State Pension age was 65, or between 60 and 65 years.
98. Research done the same year into attitudes to pensions and savings for retirement found that 70% of women whose State Pension age had increased to 65 still expected to retire before they reached that age. 40% expected to retire at 60. Respondents were not asked if they knew their State Pension age. This research was done in 2002 but reported in 2003. The ‘Working Dogs’ campaign, including direct marketing, continued after the research was done.
99. DWP research in 2003/2004 looked specifically at public awareness of State Pension age equalisation, and was reported in October 2004. 62% of working age women knew State Pension age was going to rise. This increased to 73% amongst all respondents aged 45 to 54 (women born in the 1950s would have been aged 45 to 54 in 2004). But only 43% of all women affected by the changes knew their State Pension age was 65, or between 60 and 65 years.
100. The research report says the findings were a cause for concern, as they showed that information about increasing State Pension age was not reaching ‘the group of individuals who arguably have the greatest need to be informed’. It recommended particular groups, including women who would be affected by the changes, should be ‘appropriately targeted with accessible information on the equalisation of [State Pension age]’. The research report also says the findings would contribute to DWP’s marketing campaign about equalisation of State Pension age.
101. We have seen copies of internal DWP emails from early 2005 discussing proposals for further marketing activity about State Pension age equalisation. A range of options was being considered, including ‘wider direct mailing activity’ to men and women (and buying mailing lists to enable direct mailing), and whether more individual information could be provided with pensions forecasts (including APFs).
102. A DWP policy document appears to draw on these proposals. The document is undated, but DWP told us it dates from August 2005. The policy document notes the research findings and discusses proposed communication channels, including leaflets, departmental websites and media advertising (television, press and radio). It notes that ‘the survey showed that most people do not get their information from leaflets’ but it was important they were updated for those people who did, and explores the use of advertorials in women’s press magazines and national press supplements. It includes:
‘we do not recommend carrying out any major advertising specifically focused on State Pension age equalisation, as any activity should be part of [wider campaigns].’
103. The policy document discusses including information about State Pension age equalisation in pension forecasts, and direct mailing activity. It says:
‘We will review with colleagues the possibility of giving people who receive automatic, individual or combined pension forecasts more specific information about State Pension age. This will be dependent on timing, cost and feasibility but we think this is a key route to explore because of the specific information that forecasts give to individuals.’
104. The document proposes ‘some direct marketing activity’ to 300,000 people who had responded to surveys, which ‘would include messages on equalisation for relevant people in this group’. It notes DWP could buy lists from databases that would enable it to target people, and that it had a database of around 83,000 advisers who were ‘intermediaries for some of the people we are trying to target’. It also looks at the possibility of targeting employers.
105. Research in 2005 and 2006 evaluating APFs found that 97% of women aged over 50 knew when they would receive their State Pension. This compared to 55% of women aged under 50 (women born in the 1950s would have been aged 46 to 56 years at the time, so would have fallen into both groups). Significantly, the research also found that 38% of women aged 40 to 49 (born 1956 to 1966) thought they could draw their State Pension at 60, when their actual State Pension age was 65.
106. In 2006 DWP carried out the first of three ‘Attitudes to Pensions Surveys’. The survey found that 83% of respondents were aware women’s State Pension age was going to rise in future. This included 90% of women aged 45 to 54 (women born in the 1950s would have been aged 47 to 56 in 2006). The survey did not ask respondents about their own State Pension age, so we do not know if respondents knew whether and/or how the changes affected them.
107. An internal DWP memo from November 2006 refers to a survey that year that found 50% of women whose State Pension age was between 60 and 65 thought it was 60. The memo proposes:
‘a direct mail to this group (supplemented by a range of related planned activity) was the most appropriate way of minimising the risk of future criticism that the Department has not been sufficiently proactive in communicating to those women affected by this change [in State Pension age].’
108. The memo sets out options for how to identify and contact ‘women in the target group’, when to write and what information to include. Three options were offered for what to include in letters:
- general information about State Pension age equalisation and pension reform
- general information, plus providing each woman with her exact State Pension age
- general information, plus an APF.
109. The memo proposes letters be sent in phases starting in 2009, to give women whose State Pension age was due to increase by 3.5 years or more at least 30 months’ notice. If approval was given, DWP planned to start contacting suppliers to get detailed cost estimates. A working group was to be set up to take the work forward, and the approach was to be shared with Ministers ‘before Christmas’. A formal feasibility study would follow with a progress report planned for early 2008.
110. The memo refers to an options appraisal paper. We have seen an undated options appraisals paper that includes more detail about the issues discussed in the memo, including a possible approach to phasing. It includes:
‘Previous attempts to increase awareness of equalisation among the target group have had a limited impact. Given this, we are proposing that a targeted, personalised mail-out is the most appropriate option for providing information to these women to raise their awareness of equalisation.’
111. DWP told us it believes this options appraisal paper was created in late 2006. The content of the paper, reflecting the November 2006 memo, supports that. It appears, though, that the options appraisal paper was updated over time since it also includes reference to research not available until 2007.
112. The schedule proposed in the paper gives women increasing periods of notice depending on when they turn 60. For example, women whose State Pension age increased by between one and 12 months would receive one years’ notice. Women whose State Pension age increased by between 52 and 60 months would receive three years’ notice. The document says direct mail was considered the best way to try to ensure information about the increase reached as many women in the transitional group as possible and was the only sensible option left to increase awareness.
113. The options appraisal document notes that the option of ‘high profile’ activity, for example, advertising, had been discounted because ‘previous attempts to get the message across in highly targeted advertorials has not been effective in terms of raising women’s understanding of their own situation [sic]’. It notes that ‘experience suggests that more is needed’, and that research showed that the target audience ‘has a strong preference for printed material, being generally positive towards direct mail and particularly its presentation’.
114. The proposed schedule for issuing letters included women who turned 60 between April 2010 and May 2015. We have seen no evidence of what – if anything – DWP proposed to do to tell women who turned 60 after May 2015 (whose State Pension age had increased to 65 under the 1995 Act) at this stage.
115. Unpublished DWP research from 2007 found 85% of women aged 48 to 59 knew State Pension age was going to be equalised, but many women did not know when it would happen. The research also found that 50% of women whose State Pension age had risen to between 60 and 65, and 36% of women whose State Pension age had risen to 65, still thought that it was 60. DWP told us that if people are aware of the changes, they can find out their own State Pension age.
116. An internal DWP memo from April 2007 described the 2007 research findings as ‘depressing reading’. The memo reflects on the lack of progress since 2004 and the prospect of future complaints from women. It states:
‘You floated the idea of contacting the Ombudsman to get a feel for how she would react to claims from women saying they had never been told or were not aware that state pension age is increasing. In the light of the lack of upward movement from our 43% base figure from 3 years ago, we suggest putting this off until we can explain our strategy from here to get the message over. If we go now, we face being painted into a corner. Despite a really strong defensive brief, we still have 50% “ignorance levels” with three years to go. [The Ombudsman’s] first question will be what are you proposing to do about it?’
117. A ministerial submission from December 2007 shows DWP knew people did not understand the impact of the changes for them. It says: ‘One of the key issues is that whilst some women do in fact have an awareness of the impending change, they do not understand how this relates specifically to them’.
118. The submission notes that steps taken to communicate the changes, including ‘leaflets, pensions forecasts and other communication channels’, had not succeeded in raising awareness of the effect of the changes among a significant proportion of affected women.
119. DWP told us it cannot now be confident that the 2007 research results are nationally representative and it does not know how the research assessed knowledge of State Pension age. It told us there are different ways of assessing people’s knowledge of State Pension age, and the methodology used will affect accuracy of the findings. It says this research has to be treated with caution. It also questions the robustness of earlier research.
120. It is not our role to assess the validity of the research but to consider what information DWP had available to it when making decisions. The ministerial submission indicated that a recommendation for direct mail was based on the 2007 survey findings ‘to be sure of addressing this lack of awareness’. The ministerial submission goes on to specifically note the problem of women being aware of the impending change, but not understanding how it relates to them. We have seen no evidence DWP had concerns about the research methodology, or questioned the research findings, at the time. DWP identified at the time that more needed to be done. In fact, it had recognised this a year earlier when direct mailing was proposed in November 2006.
121. The December 2007 ministerial submission includes that writing to women would ‘give [DWP] the opportunity to provide the clarity needed by including each individual's actual state pension age’. Direct mail was scheduled to start in 2009, and to take place in phases in order to ‘… minimise operational burden, and reach women at the optimal time …’. It is not clear how DWP decided what ‘the optimal time’ was.
122. The submission includes that a working group was being set up ‘to scope this work out in the new year’. The working group developed proposals for delivering the direct mailing from 2009. The group’s terms of reference included how to identify women (using the available databases), what should be included in the letters, and how the mailing would be phased, taking account of other activity likely to take place. The two main purposes of direct mailing were to:
- ‘increase women’s awareness of how State Pension equalisation affects them personally (which should be achieved by providing each woman with her exact [State Pension age] date)’, and
- ‘ensure that the Department is in the best possible position to avoid any criticism that it has failed to take sufficient action to inform women in the affected group of the increase in their [State Pension age].’
123. DWP has told us that direct mailing required planning and 2009 was the earliest possible start date. It explained it needed to engage with suppliers to get detailed costings on the preferred option, which involved working with private companies and ‘relatively new’ IT systems. It also says due diligence was needed because of the significant sums of public money involved. Even now, with modern IT, DWP says, a mailing would have a lead in time of months rather than weeks.
124. DWP used its CIS database to identify women to write to. It told us CIS went live in March 2005, was piloted for the first year, and enhancements were made between April 2005 and June 2008 to make it a more comprehensive source of customer data. It said that citizen data was not robust before the introduction of CIS, and this only gradually changed once CIS was introduced. It told us that, given CIS was continually improving, ‘it would have been strongly preferable not to conduct a mail-out at least prior to 2008’.