Customer Vulnerability: Ensuring Fair and Equitable Complaint Outcomes

The recent news that some energy suppliers have been failing their vulnerable customers served as a reminder that businesses have a duty of care to look after the most vulnerable in society. With the UK Financial Conduct Authority’s (FCA) new Consumer Duty coming into effect in July 2023, financial services businesses in particular are under pressure to ensure the fair treatment of vulnerable customers, demonstrating and evidencing how fair and equitable outcomes are being achieved when it comes to complaint handling.

The Importance of Treating Vulnerable Customers Fairly

While undoubtedly regulatory compliance is a major factor in ensuring you treat vulnerable customers fairly, that shouldn’t be your sole motivation. While the prospect of hefty fines for non-compliance really should be enough of a deterrent, you have a moral obligation to protect vulnerable customers by putting in place the right checkpoints and fail-safes to make sure these customers are treated fairly and in accordance with their needs.

Think about the brand damage that can occur if you are found to be lacking with regards to vulnerable customers: at a time when businesses are doing all they can to retain an increasingly transient customer base, brand protection is high on the priority list and the unfair treatment of vulnerable customers certainly is not conducive to this.

How to Identify Vulnerable Customers

The first step in ensuring the fair treatment of vulnerable customers is identifying customer vulnerability. Vulnerability is not a "one-size-fits-all" concept. It can take many different forms: financial hardship, physical disability, learning difficulties, bereavement. The list is long. There is also the issue of transient vulnerability, which can be hard to identify. The key is to ensure your frontline team is not constrained by a limited definition of vulnerability, and that they are trained to recognize the signs of vulnerability, whatever form these signs may take.

Certain verbal cues might signal vulnerability, or the customer might disclose information that would suggest there is a vulnerability to be considered. Empathy training is key; perhaps something might not initially seem to be a vulnerability, but in conjunction with other factors, a customer could well be experiencing hardship. For those customers who perhaps do not want to disclose their vulnerability or are loath to admit they are vulnerable, a simple change in wording could help. Instead of referring to "vulnerable" customers, perhaps talk about customers requiring "additional support"?

Although training is key, it can be augmented with technology. By collecting comprehensive customer information in a single location, it is possible to build-up a picture of the customer. The more information available, the easier it is to spot any vulnerability. Vulnerability detection technology is available too, supplementing a highly trained frontline to help your business ensure no customers slip through the gaps.

How to Ensure Good Outcomes for Vulnerable Customers

Once vulnerability has been identified, how do you ensure good and fair outcomes for these customers? Again, training is key, ensuring your frontline teams know the appropriate courses of action dependent on the vulnerability or vulnerabilities that apply. As mentioned above, not all vulnerabilities are the same and they certainly do not all warrant the same treatment. It is this ability to differentiate between vulnerabilities and to treat each customer according to their individual needs that is crucial, and training needs to reflect this.

As with the initial identification of vulnerability, empathy and understanding come into play. Rather than stating "This is what we can do for you", better outcomes can be achieved by asking: "What can we do to help?" Where possible, taking a steer from the customer will help ensure your processes are meeting their specific needs.

Making Full Use of the Technology Available

Technology has a key role here too: smart suggestions and intelligent workflows can help signpost the correct next steps for complaint handling for vulnerable customers. For example, smart suggestion functionality can help guide complaint handlers as to the optimum next steps to take when dealing with a vulnerable customer. This might be a reminder to escalate or prioritize complaints from certain customers, or to send out a specific type of communication to suit the needs of that customer, or even alerts to proactively check-in on vulnerable customers.

Integrated systems are crucial. Once a vulnerability or specific need is flagged, this indicator should accompany the customer throughout the rest of the complaint journey. Managing vulnerability through disparate systems or spreadsheets is far from ideal, making it all too easy for customer issues to be forgotten or overlooked in between interactions with your business. It is this ability to keep vulnerability considerations alive that can make all the difference, ensuring customers are treated according to their needs at every step of the way. At the same time, it is important to be able to remove vulnerability markers too, or at least to review customer circumstances. This is particularly relevant when it comes to transient vulnerability where needs can change rapidly.

Crucially for regulatory compliance, the right systems enable you to evidence how you are treating vulnerable customers. With a central repository to capture all interactions across the complaint journey, you can demonstrate to regulators the exact processes you use and the outcomes achieved for your customers. For the FCA’s Consumer Duty in particular, this ability to evidence exactly what you are doing, how you are doing it and the impact it has is vital.

As financial services continue to improve how they ensure fair outcomes for vulnerable customers, the right combination of skills, knowledge and tools is imperative. It is only by striking the right balance between technology and training that you can confidently identify vulnerability in all its guises, going on to follow the appropriate courses of action to suit individual customer circumstances. It is this approach that underpins fair and equitable outcomes for the most vulnerable in society for even the most complex and challenging of complaints.

For more information on how Aptean Respond can help your complaints function ensure fair outcomes for your vulnerable customers, contact us today.