Vulnerable Customer Policy
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Vulnerable Customer Policy
Overview
At some point in their lives, everyone has the potential to become vulnerable. Therefore, it is inevitable that during the course of our work, we will deal with clients who are going through difficult times.
Since we are a company that the FCA has authorized and regulated for our credit broking activities, it is critical that we have an appropriate policy in place, that our employees know how to spot vulnerability, and that they know how to modify their interactions with vulnerable clients to suit their needs and produce just results.
When applying for financing, vulnerable consumers are likely to require extra help at some point to prevent harm (financial or psychological).
This policy’s objective is to guarantee that our business practices don’t negatively affect our most vulnerable clients.
“Someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with the appropriate levels of care,” according to the FCA, is considered a vulnerable consumer.
We are dedicated to making sure that any employee engaged in the sale of goods or services when financing is available can recognize vulnerable clients and can respond to such clients with the appropriate degree of consideration, consideration, and care.
For a variety of reasons, a consumer could find it challenging to make an informed choice about their available options. The following risk characteristics are known to increase susceptibility in financial services:
> poor financial capabilities, literacy, and numeracy skills
> A physical handicap
> Serious or protracted sickness
> Issues related to mental health, such as prevalent mental illnesses
> A poor income and/or debt
> Taking care of others (including using a power of attorney)
> ageing, however this is not a hard and fast rule (may be linked to cognitive or dexterity deterioration, sensory impairments like hearing or sight, beginning of illness, or discomfort with new technologies)
> having a young age (correlated with little experience)
> A change in circumstances, such as a divorce, job loss, or bereavement
> insufficient proficiency in the English language
> Non-standard prerequisites or credit history (e.g., new immigrants, ex-offenders, care-home leavers, members of the armed services returning from overseas, etc.).
Being disabled, unwell, or diagnosed does not automatically make one vulnerable. When it comes to financial services, an individual’s vulnerability may stem from their circumstances and obstacles to obtaining these services. A person might also be susceptible without having a disease, condition, or diagnosis if they are weak or have recently lost a loved one.
Vulnerability is not necessarily a permanent state. Vulnerability can come and go, be short-term and temporary, long term or in some cases, permanent. Each customer’s vulnerability will be unique to them and so it is important that our staff adapt their communication and actions appropriately, based on each individual customer’s needs.
Recognizing Suffering Clients
It’s critical that our employees are able to recognize vulnerable customers in order to appropriately attend to their requirements.
One or more of the risk factors mentioned above may have been mentioned by the customer, or one or more of the following signs may surface over the phone, through webchat, or in person at the store:
a)Is the consumer able to hear you clearly and comprehend what you are saying? Do they ask you to talk more loudly or more slowly? Are you certain they have heard and comprehended every important detail? Do they inform you that they don’t comprehend the terminology being used or ask you to clarify any details?
b) Is the consumer talking coherently and staying on topic, or do they seem disoriented or confused? Are the clients’ answers still pertinent, and are their inquiries representative of the topic being discussed?
c) Does the consumer respond to questions especially slowly, indicating that they are having trouble processing the information that has been given to them?
d) Does the customer’s voice, pronunciation, breathing, hearing, or comprehension of the conversation suggest that they may have a disability or impairment? Do they speak the language being utilized with fluency and coherence?
Managing Vulnerable Clients
Just because somebody is vulnerable does not automatically mean that they are unsuitable for our products and services, or that they will not be able to obtain finance. As soon we think we may be engaging with a vulnerable customer we should take care to adhere to the requirements set out in this policy.
The following guidelines must be known by personnel when interacting with vulnerable customers:
a) Show empathy and patience at all times; don’t interrupt, hurry, or show signs of impatience. Let the client make their own decisions and adequately analyze the information.
b) Make sure the client can hear and comprehend what you are saying. You may also ask them to clarify if they understand what you are saying, or you can ask them questions periodically to make sure they know what is being discussed.
c) Give the consumer time to explain everything; don’t assume you already understand their demands or expectations, and don’t conclude their sentences, which can give the impression that you’re pushing them to move the conversation forward. As you pay close attention to the customer, pay attention to any signs of confusion, lack of understanding, or forgetting previously covered material.
d) Clearly state that the consumer is at ease with the communication standard and method. Offer to send the details in a different format, such email or the mail, to ensure clarity.
In order to guarantee that all employees of the organization, both at Deko and the Lender who may interact with the client, are informed when a susceptible customer is discovered, a pertinent remark ought to be appended to their record in the Deko BackOffice system. It is crucial that we uphold a constant standard of service and that a vulnerable client gets sufficient attention regardless of the employee with whom they interact. Any such notes ought to clarify why the client was deemed vulnerable, provide factual, succinct, and reasonable justification for the assessment, and verify that consent was obtained to record the data.
texas drilling
When a customer shares information about their vulnerability, it can contain “special category” data, which means we have to apply extra GDPR safeguards. The TEXAS drill is an easy-to-implement yet efficient method for recording pertinent data, treating customers fairly, and adhering to our GDPR obligations:
> We appreciate the client providing you with the information
> Inform the client of the information’s intended use and recipients (i.e., Deko and the lender(s)).
> Obtain the customer’s express consent to record the information and use it for the purposes that were disclosed to them. You won’t be able to document specifics regarding the customer’s vulnerability without this.
> Inquire as much as three times to learn more about the customer’s vulnerability
> In what ways does your circumstance complicate money management?
> Do you have any preferences or special communication needs that we should let your lender know about so they can better serve your needs?
> Signpost the consumer to sources of free and independent help and support if appropriate, such as their local Citizens Advice Bureau, the Money Advice Service, Mind or the Samaritans.
mental aptitude
Mental capacity is the ability of a person to comprehend, retain, and assess pertinent information in order to be able to make decisions based on that information.
Staff members should try to find a caretaker or next of kin who is authorized to act on behalf of a vulnerable customer in financial matters if they think the customer is unable to make decisions about their insurance on their own. A parent or spouse will frequently speak on behalf of the vulnerable customer.
Details about Products and Financial Promotions
We recognize that, particularly when a customer uses our website to complete an online trip, there are limitations to what we can properly do to determine whether or not they are in a vulnerable circumstance.
It is advisable to provide customers with clear, succinct, and transparent information about the essential aspects of financial services while providing product information and during any financial promotion, whether it be in-store, online, or over the phone. As a responsible credit broker, we are committed to fulfilling high standards of customer communication and will always comply to the content criteria established by Deko and/or our lenders.
Our employees will only be able to speak with consumers regarding money if they have successfully finished the necessary training and verified that they have read and comprehended this policy.
Our Promises to Fairly Treat Vulnerable Clients
In order to make sure that our vulnerable consumers receive fair treatment, we’ll do the following:
> Initial training on identifying and assisting vulnerable consumers is provided to all staff members.
> To guarantee that staff members keep putting our rules into practice, all staff members will get continual training and updates.
> When feasible, our tools will make it easier to identify clients who are at risk.
> We will be able to meet the demands of our vulnerable consumers by using our systems to handle them in the most suitable way.
> The demands of our most vulnerable clients will be taken into consideration when designing our products and providing our services.
> Our rules will be obvious to customers, and to the third-party organisations we work with, including Deko and our lender(s)
> We shall routinely examine and enhance our policies and processes using management information
> When a customer gives their explicit approval, we will make sure that information is properly recorded and reported; we will notify Deko and the lender(s) of this; and
> Before the customer decides whether to apply for financing, we will make sure they have a firm understanding of the guidance and information provided to them.
