Vulnerable Customers Policy
We know just how important it is for our customers to receive the right information about the products and services that we offer and that they understand what is involved as taking out an agreement for a vehicle and an ancillary product such as a Service, Maintenance and Repair package is a long-term financial commitment.
Some customers who, due to their particular circumstances, may be vulnerable and therefore especially susceptible to harm.
Being a responsible business, with responsible people who have our customers’ interests at heart, we’ll always consider the circumstances of each of our customers and where we think that someone might be vulnerable, we’ll always tailor our approach, removing any barriers that restrict the customer accessing our products and services so that they too can achieve the outcome that they want.
Recognising consumer vulnerability
We know that things happen in life, and sometimes when we least expect them to. We do
understand that some of our customers prefer to keep things private, but we will always
encourage our customers to talk to us about any difficulties, just so that we can make sure
that we adapt our approach or provide information in a different way.
Vulnerability can fall into four categories
1. Health,
2. Life Events
3. Resilience
4. Capability
Whilst we do like to think that we are great at active listening and ask the right kind of
questions to help us spot if someone is vulnerable, sometimes it is not easy to recognise.
Colleagues are trained on and use the BRUCE protocol to identify and spot customers who
may be vulnerable: and then should act on knowledge or suspicion of vulnerability:
Behaviour
Think about your own behaviour:
• Know your products, arrangements, and offers to ensure explanations given to the
customer are clear.
• Use simple language and break down explanations into easy-to-understand chunks –
check customer understanding then move on to the next feature.
• Never make decisions for a customer.
Remembering
Think about how to overcome any problems with memory by:
• Repeating key information or simplifying information.
• Using alternative ways of giving information (e.g. rephrasing or using a written
summary if an oral explanation has been given).
• Asking whether a friend or family member can help them.
• Asking if there is anything else that could be done to help.
Understanding
Understanding is key – support can be provided to customers by:
• Asking the customer to summarise what they have been told (to identify what they
might not have understood).
• Repeating information to customers in different ways.
• Summarising and simplifying information where possible (but continuing to provide
any regulatory or legal detail that is required).
Communication
The following could also be considered:
• Offering the involvement of a third party to assist.
• Allowing more time for the customer to communicate.
• Discuss each option available to the customer individually.
Evaluation (weighing-up)
Is the customer able to weigh-up the different options and are they able to communicate their decisions.
What happens if a customer is identified as being vulnerable?
If you tell us that you are vulnerable or if we think that you may be vulnerable, it will not stop us from helping you to achieve your objectives.
As the factors that can contribute to the level of customer vulnerability are diverse, there is not one approach that can be adopted to fit each circumstance, so we need to adapt to suit the situation.
For example, we might communicate with you in a different way as you might prefer text over voice so that you can digest information at your own pace, we might ask you more questions, we’ll take more time to go over things, and we may suggest that another family member is party to our discussions. What matters most to us when dealing with our customers who are
or may be vulnerable is that they get what they need from us to come to a decision and that if they choose to go ahead that they get the outcome that they want.
We always put our customers’ interests first and treat everyone with the same respect, integrity and dignity as we would expect to be treated ourselves.
Organisations which may be able to help
If you are feeling vulnerable and need some help, the following organisations may be able to assist you:
Citizens Advice
Citizens Advice is an independent organisation specialising in confidential information and
advice to assist people with legal, debt, consumer, housing and other problems. They aim to
provide the advice people need for the problems they face. Tel: 0800 144848 www.citizensadvice.org.uk
Help for Households
A Government website which provides information about support that may be available if you
are disabled or have a health condition and useful tips on how to save money on energy
bills. https://helpforhouseholds.campaign.gov.uk
Money Helper
Offer guides, tools and calculators to help you keep track of your finances and plan ahead.
Tel: 0800 138 7777
Money Advice Trust
Help tackle debt and manage your money with confidence. They offer advice and help with
debt management plans, debt relief orders and individual voluntary arrangements. www.moneyadvicetrust.org
StepChange
They give advice on personal budgeting, the wise use of credit and, where appropriate,
managing achievable plans to repay debts. National telephone service and online debt help
tool, via our eight regional centres. Tel: 0800 138 1111 www.stepchange.org
Alzheimer’s Society
Help for those who affected by dementia including family members and carers. Tel: 0333 150
3456 www.alzheimers.org.uk
Macmillan Cancer Support
They will do whatever it takes to support people affected by cancer physically, emotionally
and financially. Tel: 0808 808 0000 www.macmillan.org.uk
Marie Curie
Supporting people with terminal illness and their families. Tel: 0800 090
2309 www.mariecurie.org.uk
Mind
Information and support to anybody experiencing a mental health problem through their
website, their Infoline and their peer support platform Side by Side. Tel: 0300 123
3393 www.mind.org.uk
Age UK
Age UK offer support to older people with cost of living, a benefits calculator and pension
advice. Tel: 0800 055 6112 www.ageuk.org.uk
Relay UK
Relay UK is a free service that helps people with hearing and speech difficulties to
communicate with anyone over the phone. A Relay UK assistant can speak with us on your
behalf by converting your speech into text and vice versa. You can use Relay UK with a
textphone or by downloading the app to your smartphone, tablet or PC. www.relayuk.bt.com
Samaritans
The Samaritans will help you if you are struggling to cope, feeling suicidal or need support if
you are bereaved by suicide. Tel: 116 123 www.samaritans.org
Scope
Scope is the disability equality charity in England and Wales. They provide practical
information and emotional support and campaign to create a fairer society. Tel: 0808 800
3333 www.scope.org.uk