Vulnerable Consumers Policy

Who are vulnerable consumers?

A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm - particularly when an organisation is not acting with appropriate levels of care.

All customers are at risk of becoming vulnerable, but this risk is increased by having characteristics of vulnerability. These could be poor health, such as cognitive impairment, life events such as new caring responsibilities, low resilience to cope with financial or emotional shocks and low capability, such as poor literacy or numeracy skills.

Actions we will take to treat vulnerable customers fairly

Understanding the needs of vulnerable customers

• We will understand the nature and scale of characteristics of vulnerability that exist in the individuals who approach us with ADR requirements.
• We will understand the impact of vulnerability on the needs of our customers, by asking what types of harm or disadvantage they may be vulnerable to, and how this might affect the consumer ADR experience and outcomes.

Skills and capability of staff

• We will embed the fair treatment of vulnerable consumers across the workforce. All ADR staff will be trained in how their role affects the fair treatment of vulnerable consumers.
• We will ensure frontline staff have the necessary skills and capability to recognise and respond to a range of characteristics of vulnerability.
• We will offer practical and emotional support to frontline staff dealing with vulnerable consumers.

Taking practical action

Product and service design:

• We will consider the potential positive and negative impacts of all ADR services on vulnerable consumers. We will design current and future services to avoid potential harmful impacts.
• We will take vulnerable consumers into account at all stages of the service design process, including idea generation, development, testing, launch and review, to make sure products and services meet their needs.

Customer service:

• We will set up and operate all systems and processes in a way that will support and enable vulnerable consumers to disclose their needs. Staff will be trained to spot signs of vulnerability.
• We will deliver appropriate customer service that responds flexibly to the needs of vulnerable consumers.
• We will make consumers aware of support available to them, including relevant options for third party representation and specialist support services.
• We will put in place systems and processes that support the delivery of good customer service, including systems to note and retrieve information about a customer’s needs.

Communications:

• We will make sure all communications and information about ADR services are understandable for consumers in their target market and customer base.
• We will consider how we communicate with vulnerable consumers, taking into consideration their needs. Where possible, we will offer multiple channels so vulnerable consumers have a choice.

Monitoring and evaluation

• We will implement appropriate processes to evaluate where we have not met the needs of vulnerable consumers, so that we can make improvements.
• We will produce and regularly review management information, appropriate to the nature of their business, on the outcomes we are delivering for vulnerable consumers.