Author: William Archer
The industry-wide approach to dealing with customers with a vulnerability has traditionally been black and white. Either you’re vulnerable or you’re not.
This approach is now consigned to the past. Regulation has evolved and higher levels of standards are now required. So how do businesses manage this expectation and how should they effectively approach the complexities of identifying vulnerable people?
A good philosophy for approaching customer vulnerability comes from an unlikely source: the late martial artist and movie icon, Bruce Lee.
Bruce Lee trained in multiple forms of martial arts, much to the disapproval of traditionalists at the time who believed it would dilute the purity of their revered craft.
Yet Lee was an innovator. He believed that by limiting himself to only one form, he would be denying himself the opportunity for further knowledge and further adaption and evolution. Lee was, if nothing else, a master of adapting to the situation in front of him. He believed in the philosophy of ‘be like water.’
“Be like water making its way through cracks. Do not be assertive, but adjust to the object, and you shall find a way around or through it. If nothing within you stays rigid, outward things will disclose themselves.”
The ideology being to employ an adaptable approach, not to be ridged, and to be situationally aware. Then the truth will present itself.
When you think of a vulnerable person - specifically a vulnerable consumer - what image comes to mind? A visually impaired person struggling to navigate their way through online banking. Or perhaps a frail pensioner without heating in winter due to a power outage? These would have been traditional examples.
You might be surprised to discover that 50% of adults in the UK (25.6 million people) display one or more characteristics of being potentially vulnerable according to the Financial Lives Survey conducted by the Financial Conduct Authority (FCA).
Vulnerability isn’t always obvious and neatly labelled.
Whilst ‘actual’ vulnerability can be permanent and therefore easier to identify, the majority of the population are at risk of transient vulnerability due to constantly changing circumstances.
Transient vulnerability can often be a permanent or long-term state of risk. And whilst this transient state may not develop into an actual vulnerability for everyone, these individuals’ issues are non-the-less important to be flagged up.
With customer vulnerability increasingly a subject under the microscope, the FCA recently published a guidance consultation titled Guidance for Firms on the Fair Treatment of Vulnerable Customers to help support businesses and regulators in their approach to this subject.
The FCA define a vulnerable consumer as ‘someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.’
The total UK consumer spend within the regulated markets of water, energy, telecoms and financial services in 2017 was £140bn (source: National Audit Office). So, when you consider that up to 50% of that spend came from consumers at risk of a vulnerability, the scale of the potential impact becomes apparent.
The FCA have received feedback from firms highlighting the challenges they are facing in dealing with vulnerability. Some even went as far as stating they would like to improve industry practices but are unclear how to.
The biggest challenge firms face with vulnerability, according to feedback, is the issue with transient vulnerability. The report highlighted:
A big issue here is the fact that most people do not wish to openly disclose the fact they have a vulnerability such as depression, autism, anxiety or another mental health issue. This is often due to embarrassment or fear the condition could go against them.
Firms are being encouraged to take a proactive stance either through scripts or face to face questioning to help identify customers with transient vulnerabilities. Yet this is still reliant on the consumer disclosing information.
Consumer rights expert, Martyn James, has been following developments in customer vulnerability closely.
“All of the research conducted around vulnerability, disability and people who may require extra assistance suggests that between a third to half of all people who fall in to this category do not want or do not request extra help. Of course, this doesn’t mean that people don’t need assistance.
“Simply being able to identify someone who might need assistance – no matter whether they ask for it or not – can make a huge difference to the individual.”
If we are to apply the philosophy of ‘be like water’, to be adaptive to the scenario to help identify transient vulnerabilities, businesses need to ensure their staff are best equipped and supported to fulfil this task through empowerment and insight.
The FCA guideline agree with this adaptive approach. It states:
“Frontline staff should feel supported and empowered to take decisions about how they adapt their customer service approach and be enabled to depart from standard customer service provision where necessary and appropriate.”
Consumer vulnerability expert, Helen Pettifer, wholeheartedly agrees with the above statement published by the FCA and its transformative impact.
“In my opinion, the guidelines in this publication all lead to this statement being the primary goal in treating vulnerable customers fairly.
“Organisations should be putting processes and systems in place and training their staff to deliver a personalised service to every one of their customers, without exception.”
The FCA state they want to see firms doing the right thing for vulnerable people and embedding this as part of their corporate culture.
Yet how can businesses apply a unique and objective service to identify people with vulnerabilities when the problem often stems from consumers themselves not wishing to disclose the relevant key information?
The answer may well be found in advancements in predictive technology and keyword/sentiment extrapolation. This allows businesses to quickly flag up individuals with a transient vulnerability in real-time.
Platforms such as consumer complaint website Resolver.co.uk allow consumers to construct a complaint in their own words detailing the situation from their perspective. Martyn James highlights the effectiveness of this approach in helping to identify vulnerable customers.
“Being able to identify people in real difficulties by analysing how they write, and construct complaints can help businesses to prioritise cases where people are on the brink of severe financial difficulties or bankruptcy, allowing them to be prioritised.
“Businesses need to constantly evolve their approach to dealing with vulnerable people. As technology evolves, the potential for huge numbers of people to be shut out increases. Many businesses need to invest in ways to allow the details of a person’s disclosed needs to be instantly available to their front-line staff, rather than buried in old account notes.”
Applying adaptable, situation-led solutions (straight from Bruce Lee’s playbook) is key to supporting vulnerable people promptly before situations escalate. And advances in technology are helping to make the difference.
Egeria Insights have developed an Insights as a Service (IaaS) solution to help support businesses in this task.
With access to over 4 million complaint cases and over 100 million data points to apply comparative analytics, Egeria’s predictive modelling and natural language processing can objectively identify triggers for transient vulnerability that is expressed subjectively by the individual.
By identifying categories of situational vulnerability and the associated triggers (where applicable) early warnings can be raised and predictions of potential concern can alert front-line staff.
Examples of these categories and their associated triggers include:
Front-line staff of the relevant organisations can then utilise this insight promptly and action an appropriate response according to the severity of the situation.
Caroline Wells, a customer vulnerability expert and consultant, was appointed as a commissioner to Energy UK’s Commission for Consumers in Vulnerable Circumstances in 2018. Her view supports the need for businesses to react to transient issues as they arise.
“As human beings, our vulnerabilities are as unique as we are. They can come and they can go - and they can come back again. Life is like that. Things change. We change. That’s why it’s so important for businesses to identify customers with transient vulnerabilities. People shouldn’t need to be in a crisis situation all of the time to get the help and support they need - it’s often a moment in time for most and that’s when the support from a business can really make a difference.”
Whether it’s an actual vulnerability or a transient vulnerability, these individuals are proportionately more susceptible to issues such as financial exclusion, scams, exposure to mis-selling, inability to manage a product, stress and inappropriate purchases.
It’s the responsibility of businesses and regulators to ensure high standards are met and maintained to help prevent these scenarios impacting their customers, which accounts for half the adult population.
So as a business, you could do worse than to take a cue from Bruce Lee himself and avoid being ridged, employ situational awareness and demonstrate quick adaption. Be like water.
For businesses looking to identify vulnerability triggers early through applied business intelligence and predictive technology, speak to Egeria Insights to arrange a consultation.