Back to Home

  1. Home
  2. Vulnerable Customers Policy

Vulnerable Customers Policy

Vulnerable Customers Policy

Introduction

ContractCars are committed to following recognised guidelines to establish best practice for handling Vulnerable Customers. Regardless of the type of vulnerability, ContractCars want to ensure that such customers are handled and supported appropriately, thereby highlighting our business integrity. A customer can be classed as vulnerable for a number of reasons and this policy aims to help all our staff identify and support such individuals correctly.

Definition

A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.

Customers in vulnerable circumstances may be significantly less able to represent their own interests than the average customer, and more likely to suffer harm. Any customer can become vulnerable at any time in their life, for example through serious illness, bereavement or loss of income. The Financial Conduct Authority (FCA) expects firms to pay attention to possible indicators of vulnerability and have policies in place to deal with customers where those indicators suggest they may be at greater risk of harm.

Mental illness affects thoughts, mood and/or behaviour and can affect people of all ages and walks of life. It can be triggered by physical, social, environmental or/and genetic factors. According to the FCA, 50% of people are vulnerable or potentially vulnerable ant any given time.

Examples of Potentially Vulnerable Customers

The below list provides indicators that a customer may be vulnerable., It does not automatically mean a customer is vulnerable and you should use your judgement to determine if the customer is in fact a vulnerable customer.

  • Young Customers – First time with finance;
  • Elderly Customers;
  • English not a first language;
  • Recent bereavement;
  • Recent separation from spouse / partner;
  • Financial distress/difficulties;
  • Recently unemployed;
  • Homeless;
  • Customers with hearing loss;
  • Customers with sight loss;
  • Customers with disabilities which may affect their judgement;
  • Recently diagnosed with a serious illness;
  • Mental or Physical disabilities;
  • Short-term mental or physical illness;
  • Any life-changing event; or
  • Customers under duress.

This list is not exhaustive and there are many more indicators which you should be remaining vigilant to identify.

How to Identify a Vulnerable Customer

Most vulnerabilities are hidden, and they can be difficult to identify. Therefore, it is vital that you are vigilantly listening and observing for any identifiers of vulnerability. The below list provides examples of what a customer may say or do which should make you suspect that they could be vulnerable:

  • “I can’t do that day as I’m at a family members funeral” – Bereavement;
  • A customer simply responding “yes” to every question you ask – demonstrates they may not understand;
  • A customer not answering when you ask a question – may have hearing difficulties or may not understand the question;
  • “I’m back at the hospital that day” – the customer may have a serious illness or a family member with a serious illness;
  • “I don’t have a permanent address at the moment” – the customer may be homeless;
  • “I just really need this money” – the customer may be in financial difficulties;
  • Customer is 18 years old – this may be the customers first experience with consumer credit;
  • A customer who sounds foreign – where English is not the customers first language they may not understand;
  • “This should help me get some work” – the customer may be unemployed; or
  • “I’ve had to move in with my friend for a while so can you send the paperwork there?” – may have separated from a spouse or partner.

This is not an exhaustive list and there are more types of identifiers, particularly if you conduct a face-to-face sale.

How to Support a Vulnerable Customer

We must take all reasonable steps to satisfy ourselves that the customer has understood the decision they are making before approving finance for a vulnerable customer. Where we have significant doubts that a customer has understood we will refer them to someone who may be able to help. If we believe the customer is being used as a proxy for someone else to gain access to the finance, then we will refuse the application and consider informing the Police or Action Fraud.

Once the customer has disclosed an identifier you should conduct some open questioning to establish if you believe it make the customer vulnerable. The questions you should ask will depend on the suspected vulnerability. You should use TEXAS:

  • THANK THEM - “Thank you for letting us know. I’m sorry to hear things have not been easy for you. It is important to us that we manage your account in the most appropriate way.”
  • EXPLAIN HOW THEIR INFORMATION WILL BE USED (This is a legal requirement) - “Let me just explain how we’ll use that information, so you know.”
  • EXPLICIT CONSENT (This is a legal requirement) - “Is it okay if I note this information as it will help us deal with your account in the best possible way?”
  • ASK THREE KEY QUESTIONS (To help you understand their situation) –
    • “Do your circumstances make it difficult for you to repay your debt?”
    • “Does your situation affect your ability to deal or communicate with us?”
    • “Does anyone need to help you manage your finances such as a carer or relative?”
  • SIGNPOSTS TO INTERNAL OR EXTERNAL HELP (if appropriate) - Internal referrals should be to your vulnerable customer champion. You can signpost externally by providing a useful phone number or website.

If, after completing questioning, you do not believe the customer to be vulnerable you should continue the usual sales process, noting the steps that you took to establish the customer was not vulnerable.

Once a customer is identified as being vulnerable either during the sales process or once they are an existing customer we must consider the support we can offer them. The support offered would always be tailored to the customer’s needs.

How to handle difficult situations

It can be very distressing when a customer discloses to you that they are feeling suicidal or intend to self-harm.  If this situation arises then employees need to be sensitive and listen to what the customer is saying. It is important not to judge them, acknowledge what they have said and let them know you understand that they are feeling distressed.  Employees need to explain to the customer that they are unable to offer the support the customer needs and suggest that they contact a suitable advisory service or charity. Contact details are appended to this policy.

If an employee feels upset after taking a call it is important for them to talk about their feelings with a manager or another member of staff.  They must understand that they have done everything possible to help the customer.

When communicating with customers

The table below includes some do’s and don’ts when supporting our vulnerable customers.

Do Don't
  • Approach each customer situation on a case by case basis.
  • Keep calm when talking to a customer.
  • Listen carefully to what the customer is telling you. Listening and repeating back key points to the customer can help focus their thoughts.
  • If a customer is finding it difficult to speak to a specific member of staff or holding a conversation on the phone offer to pass the call to another member of staff, suggest written correspondence or appointing an authorised representative to act on the customer’s behalf.
  • Make sure you set clear boundaries and explain what we can and can’t do to help.
  • Request evidence of a mental health problem if it will assist ContractCars in making a decision. This could be in the form of a letter from the customer or the completion of a Debt & Mental Health Evidence Form (DMHEF). A decision to request this will ONLY be made by the Directors.
Offer a varied list of organisations that the customer may be able to contact for advice or support.
  • Use raised voices or unnecessarily agitate the customer.
  • Use humour when talking to a customer.
  • Sympathise with the customer.
  • Link personal experience with what the customer is telling you.
  • Make unrealistic agreements of payment.
   

Training

All members of staff receive appropriate training on vulnerable customers to ensure that we adequately identify and support them.  The training comprises an E-learning modules to be completed on an annual basis. Staff will also read and accept this policy.

Appendix 1

Signposting Organisations

Mental Health & Emotional Support

NHS Choices: for health advice and reassurance 24 hours a day

http://www.nhs.uk/NHSEngland/AboutNHSservices/Emergencyandurgentcareservices/Pages/NHS-111.aspx  Call 111

Rethink Mental Illness: provides phone advice & information from 10am-1pm www.rethink.org / www.mentalhealthshop.org (Rethink’s factsheets) 0845 456 0455 or 0207 840 3188 Email: advice@rethink.org

Mind: information on mental distress & where & how to get help from 9am-6pm www.mind.org.uk  0300 123 3393

Email: info@mind.org.uk 

Samaritans: 24-hour emotional support line for suicidal or despairing customers www.samaritans.org 08457 90 90 90

Email: jo@samaritans.org  

Saneline: emotional support line for people in mental distress www.sane.org.uk  0845 767 8000

Free Debt Advice

A debt adviser will help your customer complete a budget, maximise their income and consider their options for repaying their debts.

Business Debtline: provides free and confidential advice to small businesses www.bdl.org.uk 0800 197 6027

Citizens Advice: free advice on debt, benefits, employment, housing etc. www.citizensadvice.org.uk/cabdir.ihtml 0844 477 2020 (Wales); 08444 111 444 (Eng)

Consumer Credit Counselling Service: offers debt advice & debt solutions www.cccs.co.uk 0800 138 1111

National Debtline: offers free, impartial and confidential debt advice www.nationaldebtline.co.uk 0808 808 4000

Payplan: offers debt advice & debt solutions www.payplan.com 0800 280 2816

Money Advice Services-Ireland: if customer lives in Ireland and needs local advice www.adviceni.net 028 9064 5919

Money Advice Services-Scotland: if customer lives in Scotland and needs local advice www.moneyadvicescotland.org.uk 0141 572 0237

Other Help

Turn2us: benefits & grants search, information & resources on income maximisation www.turn2us.org.uk  0808 802 2000

Housing: Shelter are housing specialists http://england.shelter.org.uk 0808 800 4444

Alzheimer’s Society: Support and advice for people with dementia and their families http://alzheimers.org.uk  0845 300 0336

AgeUK: information, advice and support for older people www.ageuk.org.uk 0800 169 6565

Macmillan Cancer Support: information and advice for people suffering from the effects of cancer: www.macmillan.org.uk 0808 808 0000

Vulnerability Registration Service: Is a platform providing vulnerable consumers with a single reference point for recording their personal circumstances at a given point in time when they are looking to protect themselves against further debt or related financial problems. https://www.vulnerabilityregistrationservice.co.uk/ 024 7767 3992