Vulnerable Customer Policy
We are committed to identifying, assessing and managing vulnerable customers in accordance with our own defined objectives and policy, as well as any regulations and guidelines set out by our regulators. We aim to treat all customers, who we define as being vulnerable, in a fair, clear and respectful manner.
We have implemented several identification and assessment tools within the procedure section of this document, aimed to identifying, assessing and dealing with all Vulnerable Customer situations and to consistently ensure that our staff are aware of and knowledgeable about Vulnerable Customers, including how to handle certain situations. Our policy content states our intent and obligations with regards to handling customers with vulnerabilities and includes external guidance in our procedures and information as provided by the Money Advice Liaison Group (MALG).
The purpose of this policy and procedure document is to identify and support vulnerable customers and to promote transparency and openness in all the business practices and processes that we and our staff create and engage in. It also defines the steps to be taken by all staff when dealing with a Vulnerable Customer situation.
We and our staff are committed to ensuring that all customers are treated in a fair and consistent manner, but also understand that some circumstances require additional interactions and/or steps to ensure that the customer is getting a product/service that is suitable and ethical.
Our staff are provided with training on what makes a customer vulnerable and how to identify, assess and deal with any vulnerability. We are committed to ensuring that any customer who has a relationship with our company, is treated in a fair, reasonable and supportive manner.
This policy and procedure document relates to all staff(meaning permanent, fixed term, and temporary staff, any third-party representatives or sub-contractors, agency workers, volunteers, interns and agents engaged withthe Companyin the UK or overseas) within the organisation and has been created to ensure that staff deal with the area that this policy relates to in accordance with legal, regulatory, contractual and business expectations and requirements.
The 2 main definitions of a vulnerable customers as used by the Company are:
The FCA defines a Vulnerable Customer as: -
“Someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”
We are committed to providing the highest level of due diligence and ethical treatment with regards to any customer or potential customer who is identified as being vulnerable or being at risk from a vulnerable situation. To this end, we have developed the below objectives which are used to create our internal procedures for dealing with vulnerable customers.
We aim to: -
Mental health is one of the most common issues that can result in a customer being vulnerable. We provide thorough staff training and support to identify and deal with customers who have declared or meet the criteria for having mental health problems.
We follow the Codes of Practice relating to the collection of medical evidence about mental health conditions and always aims to: -
Where we have identified that a customer is considered vulnerable, we always encourage them to disclose any potential mental capacity limitation and actively look out for indicators of a potential mental health capacity limitation.
Any information collected regarding a mental health problem is kept secure and encrypted always and is only retained for as long as necessary under the DPA regulations.
When dealing with any potential mental capacity, we always ensure that: -
We understand that the term‘Vulnerable Customer’ applies to numerous and varied situations and circumstances, therefore we have outlined the procedures in this document for each Vulnerable Customer type as identified in our Vulnerable Customer Policy.
This procedure document contains specific vulnerable circumstances and the steps that we take to manage each situation, however we also have generic procedures as laid out below which are applicable to every Vulnerable Customer situation and have been developed to meet the regulatory standards as well as taking into consideration the needs of those with additional vulnerabilities.
Where a customer has been identified and/or declared as being vulnerable,the Companyalways ensures that the below steps/processes are followed in every instance: -
Where possible, we aim to prevent an account from entering into arrears in the first instance. Where previous arrears have occurred or the customer has already notified us of a financial difficulty situation, the account is to be flagged and monitored and close communication kept with the customer for a specified period.
Offering options such as missing a payment and making a double payment the next month or accepting lower instalments for a set period and then increasing the payments to make up the shortfall can often prevent an arrears situation from developing.
We use assessment questions to assess the customer’s affordability.
6.2.3 Ongoing Monitoring
We assess all accounts and credit agreements on an annual basis to identify if any customer has developed financial difficulties during their contract period. This ongoing monitoring includes: -
Contacting any customer who has missed or delayed one or more payments and completing an affordability assessment and new credit check
Flagging accounts where a customer has made one or more late payment (even if all payments are up-to-date) and monitoring that account on a monthly basis. Where more than 3 payments are made after the due date, the customer is contacted to discuss the reasons for late payment and the due date is either changed(i.e. if the customer’s pay day has been moved) or an affordability assessment is completed.
Despite a customer being identified as having mental health issues(including stress, depression, anxiety or other diagnosed conditions), the Company understands that financial/credit products and services are still required (e.g. car insurance, debt collection activities, home insurance etc).
We therefore do not exclude a customer from using/purchasing our products/services on the basis that they have been identified as vulnerable. We do however, follow the below procedures to ensure a fair, consistent and ethical approach.
Any information collected regarding a mental health problem is kept secure and encrypted at all times and is only retained for as long as necessary under the DPA regulations.
When dealing with any potential mental capacity case, we always ensure that: -
We understand that elderly customers and those with circumstantial vulnerabilities may still need the products/services that we offer, however, we aim to give more time, consideration and options to this group of vulnerabilities due to their possible inability to process information as quickly as others may.
With this in mind, where possible and/or applicable, we always ensure that: -
We consider those with language barriers or hearing difficulties to be vulnerable as they can be at a disadvantage hearing or understanding the product/services being offered. With this in mind, where possible and/or applicable, we always ensure that: -
It is not common to see young people as vulnerable, however we are committed to ensuring that any person who may have difficulties understanding the products/services that we offer, are provided with extra support.
Where we offer any products and/or services that can be utilised by young and/or inexperienced people, we ensure, as with all customers that: -
We carry out regular internal audits and gap analysis monitoring in all business practices and procedures to ensure that our Vulnerable Customers ethos and objectives are being met.
Regular reviews of the audit results are held with senior management and an ongoing record of gaps, actions and improvements is maintained. Vulnerable Customer compliance as well as providing gap analysis reporting used for MI and regulator evidence.
We are committed to ongoing professional development and 1:1 training sessions and workshops around the ideas and ethos of Vulnerable Customers and to ensure feedback is given at all times.
We will ensure that all staff are provided with the time, resources and support to learn, understand and implement the Vulnerable Customers procedures and associated policy into their business practices. Senior Management are responsible for a top down approach and in ensuring that all staff are included.
Senior Management are responsible for Vulnerable Customer audits and gap analysis monitoring and their subsequent reviews and action follow ups. There is a continuous audit trail of all Vulnerable Customer audits and feedback to ensure continuity through each process and task.