Why Vulnerability Matters And Why You Should Invest In Recognising Vulnerable Customers And Making Reasonable Adjustments

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Why Vulnerability Matters

Supporting customers who find themselves in vulnerable circumstances is now a priority for many organisations and the regulators that oversee them. Regulators who have declared an interest in this area include the Financial Conduct Authority (FCA), The Fundraising Regulator, OFGEM and OFCOM as well as a concern of the Information Commissioners Office (ICO). 

In some sectors regulators have already issued guidance on their expectations and clearly stated that they will be overseeing activity whilst applying a ‘vulnerability lens’. It’s clear that the FCA is planning to go even further than the guidance published back in February 2021, as they’re now well into a consultation on Consumer Duty. In other sectors, professional membership bodies have launched charters or commitments that they want their members to sign up to. The UK’s DMA (Data and Marketing Association) even has vulnerability under its Responsible Marketing pillar and runs Masterclasses for members and non-members under the training arm of the IDM (see link below for booking details). 

This is clearly an issue that is being taken seriously with substantial fines already issued to firms who have not served their vulnerable customers fairly. In March ’22 the ICO alone issued fines totalling £405,000 to five companies for making over 750,000 unwanted marketing calls which were targeting older, vulnerable people. 

In their Financial Lives Survey issued in February 2021, the FCA noted an increase in the number of customers displaying characteristics of vulnerability throughout 2020, with 27.7m (53% of the UK adult population) recognised in this way. They also noted that the impact of Covid-19 has been “profound” and Mind the mental health charity warned us in their 2020 report “The Mental Health Emergency” that the pandemic is “taking a huge toll on our mental health and wellbeing; and will continue to have lasting effects long after lockdown is over”. 

The scale and scope of vulnerable circumstances is wide and complex and we believe every organisation will be interacting with customers with additional product or service needs across a wide range of communication channels. These contacts will be frequent and sadly many will go unrecognised. Many organisations don’t currently know the scale of customer vulnerability within their own customer bases and are failing to recognise vulnerable customers until it’s too late or fail to do so at all. By failing to recognise vulnerability, organisations are at risk of creating further vulnerable circumstances as they fail to take appropriate actions or offer support when needed. 

The Perfect Storm

The Covid-19 pandemic led to an increase in vulnerability within customers at the same time as organisations were adjusting how their services were delivered with staff being asked to work from home, under Covid secure conditions in the workplace or in a hybrid manner – creating the perfect storm.  The change in working practices also created vulnerabilities for the employees serving those customers and amplified the need to support employees as well as customers. It’s now much more common for businesses to be having conversations about the mental health and well-being of their employees, pre-2020, this was a topic we rarely found on board agendas. 

It’s Time To Act

Whilst we are conscious of many more conversations around mental health and well-being, conversations alone won’t deliver solutions. It’s time to act. 

For those organisations which have already started to consider customers with additional support requirements, now is the time to review your working practices considering the new ways of working and increased volumes of contacts to ensure that your solutions are still fit for purpose and assess whether you’re seeing the true scale of vulnerability within your customer and employee bases. For those organisations that are yet to start, it’s time to act and build an understanding of what’s required and how you can take action and deliver fair outcomes for all.

This will require some investment – both in terms of budget spend and time. Here are our top 10 reasons why we believe you should invest in recognising vulnerability and making reasonable adjustments. 

Top 10 Reasons Why You Should Invest In Recognising Vulnerable Customers And Making Reasonable Adjustments

1.  Improved profitability – better understanding your customers will lead to improved trust in your relationships driving improved retention rates, increased brand loyalty and brand advocacy, which will all deliver to the bottom line

2.  Regulatory requirement – many of the regulators are now demanding that regulated sectors deliver fair outcomes for all customers 

3.  Minimise risk of regulatory fines, poor customer retention and a PR scandal 

4.  Improved customer experience – by better understanding your customers’ needs and wants to access your products and services, you can deliver a substantially improved customer experience

5.  Customers are demanding better service – it’s not just the regulators (and the Equalities Act) who are demanding fairness for all, customers are demanding it too. If you don’t deliver, they leave and go to competitors and are very vocal about their poor experiences on social media channels!

6.  Improved staff engagement – by equipping your teams with clarity and understanding of vulnerability via training, they are better able to recognise customers who require reasonable adjustments and are empowered to make those changes. Empowered staff are engaged and will remain with the organisation longer, reducing staff attrition and the associated costs of rehiring and training replacements

7.  Clear non-conflicting policies and procedures – by understanding the customer and employee needs you will be better able to assess your policies to identify where there are conflicts or disconnects. Once identified, they can be resolved removing barriers for both staff and customers

8.  Discover supporting tools and infrastructure that you can link into – technology is developing at an amazing pace. Learn how you can use both internal and external supporting technology and services to support your employees to deliver an improved service

9.  Ensure safeguarding

10.  It’s the right thing to do!

How to invest in recognising vulnerable customers and making reasonable adjustments

Investing in recognising vulnerability delivers the best results when there is a clear plan. 

Defining vulnerability – how does your organisation define vulnerability and what vulnerable circumstances do you recognise and will act upon?

Scoping - next, we recommend understanding the scale and scope of vulnerability for your organisation – how it affects your customers and staff and how many of them could be considered to be in a vulnerable circumstance at any one time. 

Design – it’s important to spend time designing your solutions and offerings for people in vulnerable circumstances. What do you want to achieve?

Review and plan – you then need to review your current policies, processes and practices to explore how well you are addressing the needs of your customers and employees. Establish what’s available now, compare that to what you want to deliver and create a gap analysis. You can then prioritise what you will do and when to close those gaps to create an action plan.

Training – no doubt one of the actions on your list will relate to training your staff so that they can consistently recognise vulnerability and support customers in vulnerable circumstances well. (See below for training options from RBL) 

Employee support – it’s also essential to give consideration and investment towards supporting all staff engaged in supporting vulnerable customers. Handling frequent interactions with customers in vulnerable circumstances can be demanding work for your employees which can affect their mental health and well-being and even act as triggers reminding them of their own vulnerable circumstances. They will require ongoing support. 

Continuous development – your work on supporting customers and employees who find themselves in vulnerable circumstances should be an ongoing programme of continuous development. As we have clearly seen, the external world is ever evolving, and our customers will be impacted by those changes. It’s therefore essential for all vulnerability programmes to become ongoing business-as-usual activities. 

To find out how Reynolds Busby Lee can support you in this work through consultancy or bespoke training designed for your organisation please click here and get in touch. 

We also offer more general training sessions via the IDM with our training partner Jacqui Workman of KMB. To find our more or book your place please click here

Elaine Lee

Photo credit: Victor @Unsplash

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