Just under half of UK adults display characteristics of vulnerability. That equates to more than 24m people. This is according to research carried out by the Financial Conduct Authority (FCA).
In late July, the FCA released the latest draft of its guidance to regulated firms on the fair treatment of vulnerable customers. It signals a further increase of focus on vulnerable customers and regulated firms can expect to be obliged to protect all customers, especially those considered to be vulnerable.
What is a vulnerable customer?
According to the FCA definition, a vulnerable customer is "someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care."
How do people become vulnerable?
The FCA has also offered guidance on the primary reasons that a person can typically be considered vulnerable. These come under four main categories:
- Health
- Life events
- Resilience
- Capability
Customers can sit within one or more of these categories; regardless, a customer who displays characteristics within these categories can be considered vulnerable.
A person can be vulnerable forever, or can move between not being vulnerable to becoming vulnerable and back again, depending on events and changes.
It is believed with the UK's ageing population and the effects of the COVID-19 pandemic that more people will become vulnerable over the coming months and years.
What must financial services firms do?
The guidance is still being written (at the time of writing this), however, the FCA has already provided an overview of what it expects regulated firms to do to protect vulnerable customers:
- Firms must understand the needs of all customers
- They must ensure that staff have the necessary skills and capability to protect vulnerable customers
- Products and services must be designed to protect vulnerable customers
- Customer service functions must exist to assist vulnerable customers
- Firms must continually monitor and evaluate their performance and compliance
These requirements place quite a burden on regulated firms so many will be looking to digital products and services as a means of protecting vulnerable customers.
What we believe
In order to deliver digital products and solutions that work for the entire audience, the emphasis must be on making products and solutions work for the most vulnerable members of the target audience.
This means two things about the way we work as a provider of digital services:
- We design using a 'vulnerable-first' approach - if product design is suitable for vulnerable users, it's suitable for all users
- Build digital products to WCAG standards - achieving these standards is currently the best way to make products that are accessible to all users
Download our guide to protecting vulnerable customers
As part of our commitment to assisting financial firms in protecting vulnerable customers, we've produced a guide that talks firms through the key things they need to know about preparing and managing digital products and services in this new regulatory landscape.
To download the guide, please complete the form on this page.
