Vulnerable Customers Policy

OUR PROCESS FOR DEALING WITH POTENTIALLY VULNERABLE CUSTOMERS

A person is unable to make a specific decision if he/she cannot understand information about the decision to be made,cannot retain that information in his/her mind, cannot use or weigh that information as part of the decision-making process, or cannot communicate his/her decision. A person with mental health problems who are in debt is particularly vulnerable due to this (potential):

• Lack of money management skills
• A reliance on benefits income
• Fluctuations in income or inability to work
• Unmet housing, care or treatment needs
• Poor communication skills
• A relationship breakdown

Assessing a person’s mental health is complex but needs to be recognised in early contact and addressed appropriately. If we believe a person may be vulnerable, we will ask 3 key questions:
1. Does your mental health affect your financial situation?
2. Does it affect your ability to deal with or communicate with us?
3. Does anyone help you to manage your finances such as a family member?

Signs we look out for when identifying vulnerability in customers:
• Do they ask you to speak up or speak more slowly?
• Do they understand what you are saying, or do they miss important bits?
• Do they appear confused about what is being offered?
• Do they ask any unrelated questions?
• Do they keep wandering off the point in the discussion and talk about irrelevant things or things that don’t make sense?
• Do they keep repeating themselves?
• Do they take a long time to answer questions or say that someone else deals with these things for them?
• Do they have a language barrier?
• Do they say they don’t understand their bank statement, a previous phone conversation or recent written correspondence?

Steps we take if we believe a customer may be vulnerable:
• We speak slowly, clearly and explain fully.
• We are patient and empathise where appropriate.
• We don’t rush as it may sometimes take the customer time to get relevant information together such as account details.
• We keep on the subject under discussion.
• We do not make assumptions about a customer’s needs.
• We clarify understanding at every point and always ask if there is anything else he or she would like to explain.
• We ask the consumer to explain to us what he or she understands the agreement to be.
• We offer alternative types of communication-phones, post, email, in person.
• We do not make assumptions that the person we are dealing with is sighted as he or she may be unable to read or understand serial numbers or account numbers.
• We do not make assumptions that the customer we are talking to can hear everything we say as he or she may have a hearing impairment.
• We always remember that the customer we are speaking to may sometimes be forgetful or overly trusting and believe that a sales representative is always acting in his best interest.
• We understand that some customers may be lonely and welcome the opportunity just to talk to someone.
• We give the customer time to explain his circumstances fully and don’t interrupt or appear impatient.
• We also listen for what is NOT being said, for example, lack of questions about prices, lack of commitment, the timing of responses, and extended silences.