Vulnerable Persons Policy

What is a Vulnerable Customer?

Any customer who is susceptible to loss or harm and whose situation or capability require us to take additional precautions (when we are selling or promoting our services) to ensure that the vulnerable customer is not disadvantaged in any way.

These vulnerabilities may include (but not limited to):

• Physical or mental disability
• Terminal illness
• Age (elderly or young inexperienced customers)
• Dementia
•  Confusion, not retaining information
• English is a second language
• Mental capacity limitations/Debt
•  Job Loss/low income
• Low literacy skills
• Induced intoxication by the use of alcohol or illegal drugs
  
  

How do we identify vulnerable customers?

Face to Face
Some signs are obvious if you can see your customer. For example, a customer could be blind or deaf, elderly young etc. They may show signs of confusion or inability to retain information by asking the same question repeatedly. Their mannerisms or gestures and facial expressions may tell you they are vulnerable.

On the telephone
They may ask repeated questions or show an inability to distinguish or understand what is being discussed. They may demonstrate difficulty in hearing what is being said or respond with inconsistent answers. Shortness of breath may indicate a physical disability.

 

What to do if you identify a vulnerable customer

Should this situation arise and it becomes obvious that the information we provide to the customer is not being understood then we should see the involvement of a trusted friend or relative. We will re-appoint and arrange for a trusted friend or relative to be present during the next meeting or before the next agreed telephone call.

It is very important that we follow this procedure before we ask for any contractual commitment from the vulnerable customers. It is much better to provide the customer with more time than it is to 'push' for a decision that may subsequently become a management issue. If in doubt always seek guidance from your manager before acting.

 

GDPR & the Data Protection Act 2018

Any information gathered will be processed in line with GDPR and the Data Protection Act 2018. Where necessary, explicit consent will be obtained from a customer to enable us to process the details of their vulnerability accordingly. Customers will also be fully informed of how we will process this information.

We will always:

• Ask for a customer’s explicit consent in order to record, store or process the details of their vulnerability, where it is necessary and appropriate to do so
• Clearly explain to the customer why we need to record, store or process the details of their vulnerability
• Clearly explain to the customer who the details of their vulnerability will be shared with

Typically, we would only look to process the details of a customer’s vulnerability where we may need to tailor our approach during our communications with them, or when we are entering their home for the purposes of a sales consultation or installation. We would therefore only share the details of the vulnerability with the relevant staff and representatives.

All staff are provided with the training and tools to identify, understand and deal with vulnerabilities and vulnerable customers, this training is delivered on commencement of employment and is refreshed annually.