Vulnerable customers
Vulnerable customers Policy
Who are vulnerable customers?
As stated by the FCA
“A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm – particularly when a firm is not acting with appropriate levels of care.
Our view of vulnerability is as a spectrum of risk. 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.
Our Financial Lives coronavirus panel survey, carried out in October 2020, demonstrates that more consumers find themselves in vulnerable circumstances due to the pandemic, with 53% of adults displaying a characteristic of vulnerability. This is an increase of over 3 million since February 2020, and many of these people may have multiple
characteristics of vulnerability.
Not all customers who have these characteristics will experience harm. But they may be more likely to have additional or different needs which, if firms do not meet them, could limit their ability to make decisions or represent their own interests, putting them at greater risk of harm. So, the level of care that is appropriate for these consumers may be different from that for others.
Actions firms should take to treat vulnerable customers fairly
Firms will need to use their judgment to consider what each section of the Guidance means for them and what they should do to make sure they treat customers fairly.” (https://www.fca.org.uk/publications/finalised-
guidance/guidance-firms-fair-treatment-vulnerable-customers)
We at Car Planet when dealing with vulnerable customers:
We understand the nature and scale of characteristics of vulnerability that exist in the consumer market.
We understand the impact of vulnerability on the needs of consumers and customer base, by asking what
types of harm or disadvantage customers may be vulnerable to, and how this might affect the consumer
experience and outcomes when making choices.
Skills and capability of staff
We have an ongoing toolbox talk to keep staff refreshed on fair treatment of vulnerable consumers and
staff. All staff have an understand how their role affects the fair treatment of vulnerable consumers.
Frontline staff undergoes 1-2-1 with Ops Manager to ensure their skills and capability to recognise and
respond to a range of characteristics of vulnerability.
We offer emotional support to frontline staff dealing with vulnerable consumers.
Skills and capability of staff are assess while they are dealing with vulnerable consumers.
Finance customers
We may share information about vulnerability with owe finance providers so they can act accordingly.
Product and service design:
We consider the potential positive and negative impacts of a product or service on vulnerable consumers
to avoid potential harmful impacts.
We take vulnerable consumers into account at all stages of the product and service design process,
including idea generation, development; testing, launch and review, to make sure products and services
meet their needs.
Customer service:
We will support Consumers and enable vulnerable consumers to disclose their needs. Any signs of
vulnerability which are spotted are report to finance company straight away.
We deliver customer service that responds flexibly to the needs of vulnerable consumers.
We make consumers aware of support available to them, including relevant options for third party
representation and specialist support services.
Put in place systems and processes that supports the delivery of good customer service, including systems
to note and retrieve information about a customer’s needs.
Communications:
Making sure all communications and information about products and services are understandable for
consumers in their target market and customer base.
We consider how we communicate with vulnerable consumers, taking into consideration their needs.
Where possible, firms should offer multiple channels so vulnerable consumers have a choice. Implement
appropriate processes to evaluate where they have not met the needs of vulnerable consumers, so that
they can make improvements.
