Doing the right thing for your customers is the best route to meeting FCA expectations and achieving sustained business success. In particular, your vulnerable customers should be given special consideration.

Never before has it been so inevitable that your customers will drift in and out of being vulnerable. Employment security is low, the economy has stalled and the lockdown and virus itself are placing extraordinary pressure on both physical and mental health. With vulnerability so widespread, are you set up to meet the needs of your vulnerable customers? Have you asked what vulnerable customers’ needs are?

Ultimately, you should think from your customers’ perspective when considering your approach to vulnerability. Here’s some actions you can take to meet the needs of vulnerable customers.

1. Understanding vulnerability

The current situation has the power to push anyone into the vulnerable category. Your customers can become vulnerable at any time and, equally, come out of a vulnerable state just as quickly. This transient nature means that your business is going to need to be flexible. Simply identifying vulnerability is not enough, you must take action to understand and meet the needs of those customers, and actively avoid causing them harm.

This means identifying those in, or potentially in, a vulnerable state as early as possible. By identifying these vulnerabilities, you’ll develop a deeper understanding of your customers’ needs. You may be able to do some of the heavy lifting using data analytics if you are regularly collecting usable data, but your best detection methods are in those early interactions with your front line customer facing staff. Help these staff to understand what causes a customer to become vulnerable and susceptible to harm. Take a look at your systems. Are they set up to enable staff to record types of vulnerability and actions taken to support them better?

The current situation has the power to push anyone into the vulnerable category

2. Skills and capability of staff

Staff play an important role in delivering good outcomes for vulnerable customers. Empower your staff to embed vulnerability in their work to get the best outcome for each and every customer. Senior staff and boards can avoid a policy/practice gap by ensuring that policies are embedded into the culture and processes of the entire business.

Much of this is down to having the right customer services and systems in place to enable staff to respond flexibly to the needs of vulnerable customers. Your current training is likely to need updating to help staff understand the common types of vulnerability they are likely to be seeing in these circumstances. Financial vulnerability will be on the rise, for sure, but your customers are likely to be facing multiple compounding issues such as bereavement, mental health problems and caring responsibilities too.

Larger businesses with significant customer services operations may already have specialist teams to handle vulnerable customers. But with the volumes of vulnerable customers likely to increase in the near future, you may need to augment these teams or upskill all your customer facing staff to be able handle the load appropriately.

3. Taking practical action (through product and service design, communications, customer service)

Be a beacon of stability in your customers’ cluttered lives. This means making it easy for your customers to find the products and services that meet their needs and making them aware of changes to your service levels or products.

Think about how your vulnerable customers might access this information. In the current climate, reduction in face-to-face services has meant that a lot of information is only available online and customers experience long wait times on phone lines. Yet many customers in vulnerable categories may struggle with access and usability of these channels. You’ll need to provide tailored options for these customers, such as exception policies that allow a nominated third party to call on a customer’s behalf. Don’t forget to make both your customers and your staff aware of them.

4. Monitoring and evaluation

The actions we’ve described are not a one-off exercise – embed your vulnerability approach into every aspect of your business including monitoring and evaluating the impacts of any action you take through testing and feedback. By having appropriate processes in place to assess where things have gone well and where they have not, you will be able to identify key gaps in your own service for vulnerable customers and make improvements.

If you don’t have a vulnerability strategy, you’ll certainly need one now.

It should be led and championed by senior management through effective communication and embedded in your firms’ culture, processes and practices.

That's where we can help you:

Create a vulnerable consumer strategy

Assess your current practices and behaviours to understand the impact on vulnerable customers

Provide a gap analysis

Provide vulnerability training to senior managers and front line staff

Carry out a vulnerability audit

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