Vulnerable Customer Process

Document status: Source document for demonstration, testing and training only. This process must be aligned to approved organisational policy, regulatory requirements and system permissions before operational use.

1. Purpose
This process guides colleagues in identifying, recording and responding to customers whose personal circumstances may affect their ability to understand information, make decisions, communicate, manage payments or access a product or service. The aim is to provide fair, respectful and practical support without making assumptions or diagnosing the customer.

2. Guiding Principles
- Treat every customer with dignity, patience and respect.
- Listen for indicators; do not label, diagnose or make assumptions.
- Ask only what is necessary to understand the support need.
- Explain why information is being requested and ask permission before recording vulnerability information.
- Adapt the service to the customer's needs and confirm understanding.
- Record facts, agreed support and review requirements using neutral language.
- Escalate urgent safety, safeguarding or severe financial difficulty concerns through the approved route.

3. When to Consider Vulnerability
Indicators may be disclosed directly or noticed during the interaction. Examples include bereavement, reduced income, job loss, repeated missed payments, illness, disability-related support needs, caring responsibilities, domestic or financial abuse, low confidence with digital channels, difficulty understanding information, limited literacy or language needs, or a significant life event. An indicator is a prompt to explore support needs sensitively; it is not proof of vulnerability.

4. Operational Process
1. Recognise: Listen for a disclosure or signs that the customer may need additional support.
2. Acknowledge: Thank the customer for sharing and respond without judgement.
3. Explore: Ask how the circumstances affect the customer's ability to manage the current issue and what would help.
4. Seek permission: Explain what information would be recorded, why it is useful and who may use it to provide support. Obtain clear permission before recording it, unless an approved exception applies.
5. Record: Capture the customer's own words where practical, the functional impact, agreed adjustments, permission status and any review date. Avoid unnecessary medical or personal detail.
6. Adapt: Apply appropriate service adjustments and provide information in a manageable way.
7. Resolve or escalate: Address the immediate issue within authority. Escalate where specialist support, safeguarding review or additional approval is required.
8. Confirm: Summarise the agreement, check the customer's understanding and confirm the next action, owner and timing.
9. Review and close: Complete accurate notes, set any follow-up and remove or update temporary adjustments when no longer required.

5. Suggested Conversation Wording
- Explore: "Thank you for letting me know. How is this affecting your ability to manage the account or the issue today?"
- Permission: "With your permission, I can record the support you need so you do not have to explain it again. Are you comfortable for me to do that?"
- Preference: "What would make this easier for you today?"
- Understanding: "I have explained a few options. Would it help if I summarised them one at a time?"
- Closure: "To confirm, we have agreed the following actions. Is there anything you would like me to go over again?"

6. Permission and Recording
If permission is granted, record only information needed to provide support. Include the customer's disclosed circumstance, how it affects the interaction or account, agreed adjustments, permission status, date and any follow-up. If permission is declined, do not record the vulnerability detail; record only that support was discussed and provide any assistance that can be delivered without retaining sensitive information. Follow the approved exception route if there is an immediate safety or safeguarding concern.

7. Possible Support Adjustments
- Use plain language and provide one step at a time.
- Allow extra time, pauses or a scheduled callback.
- Offer an alternative communication channel or accessible format where available.
- Repeat or summarise key information and ask the customer to confirm understanding.
- Arrange contact through an authorised representative in line with verification requirements.
- Review affordable or flexible payment options permitted by policy.
- Pause avoidable collections or cancellation activity while an approved review is completed.
- Refer to a specialist support, financial difficulty or safeguarding team where appropriate.

8. Escalation and Safeguarding
Escalate promptly when the customer indicates immediate danger, abuse, coercion, inability to meet essential living costs, severe distress, an inability to make or communicate an informed decision, or when the requested adjustment is outside the colleague's authority. Keep the customer informed, share information only through approved channels and record the reason for escalation factually.

Quick Decision Guide
- Possible indicator only -> Ask a sensitive, open question about support needs; do not assume vulnerability.
- Customer discloses a support need -> Acknowledge, explore functional impact and agree an adjustment.
- Permission to record is granted -> Record the minimum necessary information and agreed support accurately.
- Permission to record is declined -> Do not retain vulnerability detail; provide available in-call support and explain any limitations.
- Immediate safety or safeguarding concern -> Use the urgent escalation route and follow safeguarding instructions.
- Support need affects payment or cancellation -> Review permitted payment, pause or reinstatement options and obtain approval where required.

9. Quality Checks
- Was the customer listened to and treated respectfully?
- Was the functional impact explored without unnecessary probing?
- Was clear permission obtained before recording vulnerability information?
- Was only relevant information recorded in neutral language?
- Were suitable adjustments offered and applied within authority?
- Were understanding, ownership, next steps and timing confirmed?
- Was any necessary escalation or follow-up completed?

10. Example Record
Disclosure: Customer advised that reduced working hours have caused an inconsistent monthly income and difficulty maintaining Direct Debit payments.
Functional impact: Customer cannot pay the full outstanding amount today and is concerned about cancellation.
Permission: Customer gave verbal permission to record the support need.
Adjustment agreed: Information explained one step at a time; permitted payment options reviewed; account action referred for approval.
Next step: Specialist team to contact the customer by the agreed time and confirm the outcome.
Review: Reassess the adjustment at the next substantive contact.

Version: v1.0