Conversation techniques for supporting vulnerable customers
The FCA’s focus on vulnerable customers is continuing apace in 2020, with the regulator announcing on 6 February that it will launch a second consultation on Guidance on vulnerable customers within the “next few weeks”. It is expected that this consultation will aim to offer further guidance to firms to work towards more consistent treatment for vulnerable individuals across the industry, with progress already made being maintained and improved upon.
The FCA’s Director of Consumer and Retail Policy highlighted the ‘critical role’ of staff in the treatment of vulnerable customers, adding that “vulnerability has to be something which is embedded right across the organisation, from top to bottom”. Filling in the policy-practice gap is one of the key matters for all firms when it comes to dealing with vulnerable customers and this is made all the more important given the increased focus by the FCA.
The FCA recognises that, currently, there is a huge difference in practice across the industry. Creating a policy that is carefully designed, that takes into account the range of likely vulnerabilities of the customer base, and that ensures that these customers receive appropriate support and the same high levels of service as other customers is one thing. Training and maintaining staff skills so that they are able to actually put the theory into practice and identify and support vulnerable customers is another.
And it isn’t hard to understand why. The term ‘vulnerable’ encompasses an extremely wide range of conditions, including everything from long term health conditions to life events to language issues. Even the most experienced staff can find it difficult, or lack the confidence, to address the topic of potential vulnerabilities with customers. For many staff, there is simply little understanding of how to identify vulnerability, and if they do, they’re often not sure how to handle the situation, or are concerned they might say the wrong thing, cause offence, or make matters worse.
Fear of saying the wrong thing or causing offence means that opportunities to support vulnerable customers are being missed. And this is where training comes in. Equipping staff with tried and tested techniques – and showing them what good looks like in practice – makes consistent treatment of customers more likely, and it provides valuable assurance to staff that when an issue comes up, they’ll know how to deal with it and how to gather the information they need about the customer’s unique circumstances.
And this is a critical step in the practice of support. Because vulnerabilities are so diverse, and because the same set of circumstances can affect two different people in different ways, gathering accurate and relevant information about what’s going on and how it affects the individual is needed for staff to be able to properly consider all the available support options, match them to the customer’s individual needs and to decide on the best course of action.
There are a number of conversation techniques that staff can use to good effect.
Focussing on speech and language is a great first step. Where the circumstances warrant it, staff should be conscious about the speed of their speech, bearing in mind that someone experiencing confusion or other conditions that might lead to difficulties in understanding might be missing significant parts of the conversation if they are unable to keep up. Clearly enunciating words and keeping speech at a relaxed pace will also help. Similarly, language use should be kept simple and clear, avoiding terms which are too technical, and which might not be understood by the customer.
It’s also worthwhile knowing that, in general, it's best to avoid the use of the term ‘vulnerable’ when speaking with customers. It should be viewed as a technical term that incorporates those who might be harmed or taken advantage of due to ill health, age, life events or minority status. Some might simply refuse to engage if they think they will be defined as vulnerable, seeing it as a description of their character, rather than a term used to ensure they receive any support they might need. Staff should instead focus on the unique issues affecting the customer.
There are also a number of ‘protocols’ that help to provide a framework to staff in identifying and gathering information from customers. The ‘TEXAS’ protocol is widely used for managing disclosures where the customer’s explicit consent is needed to be able to process the data. Less well known is the ‘IDEA’ protocol, which can be used to guide staff to ask questions to find out how the customer’s situation ‘Impacts’ them, it’s likely ‘Duration’, the customer’s personal ‘Experience’ and whether they are receiving any ‘Assistance’ that might affect the support options they are offered. These are just two of a number of protocols – others such as the ‘CARE’ and ‘BRUCE’ protocols can be used to help staff identify vulnerability and to establish capacity, and each provides the security of a tried and tested framework, and removes the sense of the ‘unknown’ that can be intimidating for less experienced staff.
The FCA are keen to work with firms across the industry when it comes to the treatment of vulnerable customers. With the second phase of the consultation underway shortly, an audit of current practices where firms have not already done so is excellent preparation. The guidance as it stands takes into account the differing sizes and natures of business but sets out in simple terms how products and services should be organised and best practice in fair treatment. Our online guidance brings together published guidance, from Occasional Paper No. 8, and from the proposed guidance, as well as guidance within the Consumer Credit Sourcebook.