Consumer Vulnerability

How to achieve the best outcome in treating vulnerable customers fairly
Tom Horne
Chief Operating Officer
Wednesday, September 1, 2021
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Vulnerability and treating vulnerable customers fairly is one of the most stringent topics, which is high on the FCA’s agenda because almost half of the UK’s adult population displays one or more traits of vulnerability or potential vulnerability according to recent research conducted by the FCA (Financial Lives, The experiences of vulnerable consumers, page 9). And this should not be surprising. The FCA’s ‘vulnerable customer’ definition captures anyone who “due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care“ (FCA Guidance for firms on the fair treatment of vulnerable customers, page 59).  

For a long time, the consumer protection legislation was focused around ordinary customers. Still, the statistics following the FCA’s research in 2017 and 2020 shows that 25.6 million and correspondingly 24.1 million adult people in the UK display one or more characteristic of vulnerability such as an illness that impacts the capacity to carry out daily tasks, adverse major life events such as job loss, bereavement or divorce, low emotional or financial resilience, or low financial literacy or knowledge. The vulnerability can be temporary, sporadic, or permanent in nature. In the current COVID-19 pandemic context, the consumer vulnerability drivers deepen the vulnerability of many people as many of them have been furloughed, experience a cut in working hours and drop of income or even worse lost their income. Many people who were not in vulnerable situations at the beginning of this year might find themselves as ‘vulnerable’ currently.

It is clear that consumer vulnerability is a widespread issue, and everyone has the potential to become vulnerable. Most of us, perhaps, experienced some sort of vulnerability at some point in our lifetimes. I myself experienced vulnerability a long time ago, but thankfully it was only temporary.

Starting with 2015 the FCA started to stimulate interest and debate around vulnerability, and in 2017 formalised the fair treatment of vulnerable customers into its guidance and seeking to achieve better outcomes for those who find themselves in vulnerable circumstances. In its recent 2020 guidance for firms on the fair treatment of vulnerable customers, the FCA wants to see the fair treatment of vulnerable customers deeply embedded into the culture of firms throughout the whole consumer journey through adjusting the scope of consumer protection to customer’s specific circumstances and ensuring an adequate level of care.

In the current environment, firms need to ensure all customers are adequately protected, including those considered to be vulnerable. With this in mind, firms need to consider what protections, in line with the FCA’s expectation, for vulnerable customers they can offer.

At TieTa we know how to manage vulnerability and mitigate the vulnerability risks. We use a high-level policy on consumer vulnerability and treating the vulnerable customer fairly that ensures a consistent approach embedded across all Contact Centre operations to dealing with vulnerable customers. We have a trained team of agents who know how to identify and manage vulnerable customers in order to treat them fairly and with empathy. We conduct an ongoing evaluation of consumer vulnerability management, and we use a range of Key Performance Indicators and metrics to ensure that we are delivering the very best customer experience.

We believe the vulnerable customers need to trust that they will experience certain outcomes when they are dealing with a firm, which will make them feel they have received good service and were treated as an individual. If you want to know how TieTa can help you get the best outcome in Contact Centre Support, get in touch with us at contact@TieTa.co.uk  

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