Recently there has been increasing emphasis on customer outcomes within financial services, particularly for individuals in vulnerable situations. The Financial Conduct Authority (FCA) performed the recent ‘Financial Lives Survey’ which concluded that up to 50% of UK adults display one or more characteristics of being potentially Vulnerable.
The purpose of this article is to give our current and potential members’ a better understanding on CS Healthcare’s commitment to providing excellent customer outcomes through fair and appropriate customer service, particularly to those who may be in a vulnerable situation.
What is Vulnerability?
Vulnerability is difficult to define. This is because we can all be vulnerable at different times, for different reasons. As our individual circumstances are unique to us, we all may respond differently to situations.
To help us define vulnerability and how we will try to treat those who may be defined as vulnerable, we had a forum to ask members what they thought. Following this exercise, and considering guidance from the Financial Conduct Authority (FCA), we have defined a vulnerable customer as:
“Someone who, due to their personal circumstances, is especially susceptible to detriment, particularly if we do not act with appropriate levels of care”
Breaking down our definitionTo help us identify ‘personal circumstances’ that may lead to an individual to be more susceptible to harm dealing with us, we have used four categories of vulnerability, suggested by the FCA within their vulnerability framework.
Adults who say their ability to carry out day-to-day activities is reduced a lot through health conditions or illness.
Adults who lack or have low financial resilience, which indicates how exposed some customers are to possible increases in interest rates and prices or small change in their circumstances.
- Life Events
These are major events happening in the last twelve months, such as divorce, redundancy or the death of a close family member.
Defined as very low knowledge of financial matters or low confidence in managing money.
If one or more of the above apply to you, you may be vulnerable in that moment. But, that doesn’t mean you always will be.
We feel the above factors may make individuals ‘susceptible to detriment’ when dealing with us. This means that rather than help these customers, we risk causing them harm.
Within our definition, we explain that harm will particularly be felt by vulnerable individuals, ‘if we do not act with appropriate levels of care’. Appropriate care will differ from person to person, based upon their circumstances.
For some customers facing a short term unexpected challenge may mean that they’re in a vulnerable circumstance for a period of time. For others, they may be coping with a long-term illness which may mean they will always require additional support from others. The final group may move in and out of vulnerable circumstances on an on-going basis. For this group they will sometimes need support, but at other times not.
Our commitment to you
CS Healthcare wish to ensure that all of our members or potential members are treated fairly and appropriately, and that our practices encourage good customer outcomes. So, we have put together a set of aspirations that we believe will help us meet our goal.
- Identification of potential vulnerability
- All our staff will receive annual training on recognising vulnerability and its potential effects on people.
- We will ensure that we have good internal policies and practices in place to handle the disclosure of personal circumstances and/or communication needs.
- We will not assume that you are vulnerable, just because you fall into one of the four categories of vulnerability, listed above.
- Making adjustments
- We will offer a choice of ways you can contact us, so that we are able to communicate with you in a way that’s clear, easy to understand, and meets your needs.
- We will be flexible in how we deal with you, considering your individual needs and being pro-active when we recognise you may be at risk.
- Our Policies and Literature
- We will ensure our policies are easy to understand, and work the way you’d expect them to.
- Our communications will be written in language that is clear, simple and easy to understand, and will be available in different formats, upon request.
- Continuous improvement
- We will review the measures we have in place to support individuals with vulnerable circumstances on an annual basis, to see if we should be doing more.
- Vulnerability will be discussed annually by the Society’s Board, and will be considered within Board decision making.
Support and Resources
The Society aims to deliver upon the above commitments to you because we feel it’s the right thing to do. However, it may also be useful for you to understand your rights and our obligations under law and industry regulation. You may find the below websites useful, to help you understand more:
If you are a current member and feel you may be vulnerable and will need support managing your policy, or have thoughts about what can do to improve what we do for our members, please:
Email us at firstname.lastname@example.org
Call us on 020 8410 0400†
Write to us at: CS Healthcare, Princess House, Horace Road, Kingston upon Thames, Surrey, KT1 2SL