Identifying VULNERABLE customers

Anyone who, due to their personal circumstances, is especially susceptible to detriment, particularly when they are not treated with an appropriate level of care and consideration.



Our policy document sets out the high-level requirements and expected standards for our dealing with vulnerable customers and for our staff to understand the importance for, the awareness of and the delivery support we provide. It is not possible to prepare a policy document that covers every permutation we can encounter. First and foremost our staff are our most important asset and our primary responsibility is to them. However, we must aspire to accommodate those issues either disclosed to us or identified in our service performances. We must equally find a demarcation between those customers who can be difficult knowingly or otherwise and a risk to us and not placing our staff in harms way.


The purpose of our policy is to ensure our businesses establish and maintain appropriate policies and strategies to identify and work with vulnerable customers. The key aims of the policy are to:

• Encourage disclosure of vulnerabilities from customers through training and good practice;
• Ensure that our staff receive appropriate training and tools to help identify and engage effectively;
• Update customer facing engagement and provide clear training and standards around the application of these policies, their potential impact and what to do if circumstances arise where vulnerability needs to be taken into account’;
• Review and update customer communications to ensure that clear and simple information is provided throughout the case lifecycle.


Our policy sets out the scope on whether we are informed by our clients or we need to make our own assessment of our customer. The need for the evalauton is at the heart of what many of our clients do as a business and one of our many tasks is to support their client in a time of crisis. We are often acting as an agent of an insurer or their intermediaries following a trauma and we are not a welcome party, despite having the skills and resources to deliver a solution that will overcome their problem. We have to take great care in how we deal with confidentiality, respect, disclosure and data Protection compliance.

Our Approach

We aim to treat customers as individuals and provide a tailored, appropriately flexible response to meet their needs. Our policy is to periodically review this policy, evaluate our performance and provide staff with the necessary ongoing training and avoid making anything unnecessarily complex.

We give customer-facing staff the authority to resolve consumer problems themselves, where possible, so that customers are not passed around. We provide clear lines of escalation so that customer-facing staff know where to go to get an answer and can resolve issues promptly.

With customer communications, where we can, we will record whether a customer has particular communication needs and tailor future communications accordingly. We will design marketing, promotional material and customer communications that are easy to understand. Through our contact methods we make it easy for customers to contact us. We aspire to maximise the use of our Customer portal technology without loosing sight of the importance of voice and face-to-face communications. As an organisation we are proud of our customer support and focus on effective and quality communication.