Vulnerable Customer Policy
Purpose of Policy
Femaura is a small Social Enterprise with one staff member fulfilling the roles of CEO, Director, Teacher, and Translator. Resources are limited, but demand is high, particularly from vulnerable customers
Femaura is passionate about equality and works hard to bridge the gap between the hearing and deaf world. Vulnerable customers are encouraged to approach Femaura, knowing they will be treated with equality, respect, and dignity. In recent years the number of vulnerable customers has increased, and it has become clear that a Vulnerable Customer Policy is necessary.
Femaura’s customers may be accessing interpretation and translation services or participating in one of our courses as a student. They could be approaching Femaura for consultancy or one-to-one tuition to support their learning. Femaura regularly works with freelance teachers, translators, notetakers and BSL interpreters. This important policy applies to all customers and stakeholders.
Femaura must be honest about its capabilities and limitations to protect vulnerable customers. Before agreeing to support them long term, the CEO must consider whether Femaura has the skills, expertise, and capacity to fulfil the customer’s needs. For this reason, Femaura may take the decision to inform the customer that they unable to provide a service that meets a customer’s ongoing needs. If customers require a service above and beyond what Femaura can do, they will be signposted to the most appropriate organisation.
Identification of Vulnerable Customers
The Financial Conduct Authority (FCA) define a vulnerable customer as:
Someone who due to their personal circumstances is especially susceptible to harm, particularly when a firm in not acting with appropriate level of care
It is vital that vulnerable customers are treated fairly and consistently, ensuring that they experience outcomes as good as other consumers.
Vulnerability can affect anyone at any time. It is important that all businesses consider whether their customers are vulnerable and then whether this vulnerability is temporary or permanent. As vulnerability characteristics affect consumers differently, it is vital that each customer is assessed individually and treated as such.Customers may not like to be labelled as ‘vulnerable’. Therefore, although this Policy refers to vulnerable customers, Femaura will not use this label in their customer interactions. Instead, Femaura will look at how a customer could be vulnerable and potentially disadvantaged and respond appropriately to ensure they are treated fairly.
All at Femaura should understand that characteristics of vulnerability are likely to be complex and overlapping. Femaura staff, whether employed or freelance should be alert to factors that may make a customer vulnerable and bear this in mind during all their interactions. A customer may not realise that they are vulnerable or that in the past they have been taken advantage of. Patience and empathy are therefore crucial qualities.
The table below, based on the guidance provided by the FCA (2021) gives a good indication of the characteristics associated with what they consider to be the 4 drivers of vulnerability: Health, Life Events, Resilience and Capability.
|Physical disability||Retirement||Inadequate or erratic income||Low knowledge or confidence in managing finances|
|Severe or long-term illness||Bereavement||Over-indebtedness||Poor literacy or numeracy skills|
|Hearing or visual impairment||Income Shock||Low savings||Poor English language skills|
|Mental health condition or disability||Relationship Breakdown||Low emotional resilience||Poor or non-existent digital skills|
|Addiction||Domestic abuse||Becoming unduly anxious, hostile, or upset||Learning Difficulties|
|Low mental capacity or cognitive disability||Caring responsibilities||No or low access to help and support|
|Leaving care, migration, seeking asylum, convictions, modern slavery|
How to Match the Needs of a Vulnerable Customer
When dealing with a vulnerable customer it is vital to be flexible and patient in your approach and response. The person may not realise that they are vulnerable. Therefore, patience and empathy are needed.
If a customer does not realise that they are vulnerable, explain why you have concerns in a calm and clear way. Do not attach a label to a customer, as this may cause offence. Instead assess their needs and try to match these requirements in your service.
It is important to be always respectful and preserve the customer’s dignity, rather than suggesting that they need help or charity.
View each customer as an individual and assess their unique needs, responding accordingly.
When a customer does not know what they need, work with them to decide the best course of action. Ask questions to help them reach this conclusion rather than telling them what to do.
Do not put more barriers in the vulnerable customer’s way. Instead, focus on what they can do and how you can support them to achieve their goals.
No customer should feel rushed. Instead, it is important to take time to get to know them and build rapport.
When issues arise, do not walk away from the situation. Instead, discuss the issue openly, seeking to understand the customer’s point of view. Aim to reach an amicable resolution.
Treat all customers with respect and do not take advantage of vulnerability by, for example, withholding information or overcharging them for services rendered.
Responsibility for the Business
It is Femaura’s responsibility to ensure that staff who work with vulnerable customers receive appropriate training. All employees, including freelance colleagues must understand that they are likely to encounter vulnerable customers and therefore need to anticipate challenges.
Femaura must ensure that the Vulnerable Customer Policy is accessible to all and translated into BSL. Additional explanation of the policy should be provided where necessary to ensure it is understood.
The business should maintain confidential records of vulnerable customers and assess their risk regularly. All records must be stored securely in accord with GDPR and Data Protection legislation.
If the business is unable to deal with the complaint, the complainant will be signposted to the appropriate organisation who are best placed to investigate. Femaura will clearly explain the reasons behind this decision so that the customer understands why they are being referred and do not feel rejected.
If a vulnerable client has been receiving regular support from the business but this becomes untenable, the business will follow the terms of the contract in terminating this support. The vulnerable client will be informed of the reasons (i.e., lack of business resource, support required falls outside Femaura’s capabilities, staff ill health etc) and will be given recommendations to source an alternative provider. The client must respect Femaura’s decision.
Bullying and harassment of Femaura’s staff is not tolerated in any form. Further information can be found in the Bullying and Harassment Policy.
Pitfalls to Avoid
If staff do not receive adequate training, they are likely to deal with vulnerable customers inappropriately. This will cause distress to all parties involved.
If a client perceives they have not been given enough time and attention, they will leave the business with a bad impression. They will likely feel disempowered and unvalued, which will impact future interactions.
It is important not to become upset or take offence at the actions or comments of vulnerable customers.
Take time to calm down during a challenging interaction rather than terminating the discussion.
If a customer is angry or frustrated, it is important not to retaliate. Becoming angry in return will only make the situation worse. Instead, it is good to anticipate challenges and consider how to respond appropriately.