Two customer service advisers wearing headsets working at computers in an office.
During our review of consumer vulnerability, we saw how relatively simple changes can make a real difference. One payments provider serving small business customers found that some customers were struggling to set up and manage their accounts because of limited IT literacy.
The firm responded by arranging callback support to help customers set up their accounts.
As a result, customers were able to manage their accounts successfully, without needing to invest in expensive new systems or roll out elaborate new processes.
Investing in time, not in systems
Payments are woven into everyday life. They're how people receive their salary, pay bills, support family members and manage their finances.
When customers are in vulnerable circumstances, barriers to accessing or using payment services can have a significant impact on their daily lives. That's why it's important that firms understand their customers' needs and design support that helps them access and use services effectively.
Our consumer vulnerability review[2] found that firms achieving the best outcomes had invested time in understanding their customers and adapting support to meet their needs.
Under the Consumer Duty[3], firms should act to deliver good outcomes for retail customers, including those in vulnerable circumstances.
Around half of UK adults show at least one characteristic of vulnerability, so this isn't a niche issue for a handful of firms.
It's something every payments and e-money firm needs to think about.
Design, adapt, and test
We found that firms who understood their customers were better able to design support around real needs, adapt their communications, and ensure people received a consistent experience.
This helped them deliver better outcomes, reduce barriers to access and support customers to make effective use of products and services.
And they were able to do this in simple, customer-centred ways.
Almost every firm we looked at could point to policies, training materials or procedures. These are a good start.
But these alone don’t guarantee customers will get good outcomes.
The most successful firms went a step further. They asked whether those arrangements were really working in practice, and checked.
They used management information, complaints data, customer feedback and quality assurance to understand how customers in vulnerable circumstances were actually experiencing their products and services.
If something wasn't working, they changed it.
Simple changes
For smaller firms, this doesn't need to mean sophisticated reporting infrastructure.
It can be as simple as your board or senior management regularly reviewing how many customers in vulnerable circumstances you're identifying, what kinds of vulnerability you're seeing, and how that links to your complaints data.
A handful of firms did exactly this, and it helped them spot where they were doing well and where they needed to improve.
Five questions every firm should be able to answer
Firms can be flexible in how they meet their obligations under the Duty. But reflecting on what we found, I think every firm, whatever its size, should be able to answer a few simple questions:
- Do we understand the vulnerabilities most relevant to our customers?
- Are we identifying and supporting customers consistently?
- Can we demonstrate that our approach is leading to good outcomes?
- Where something isn't working, are we learning and improving?
- Does our board or senior management receive enough information to understand whether customers in vulnerable circumstances are receiving good outcomes?
The answers will look different from firm to firm, but the goal is the same for everyone: helping consumers, including those in vulnerable circumstances, receive good outcomes when using payments services.
None of this requires lots of resources or expensive systems. It requires asking the 5 questions above, and acting on the answers.
Our full findings are in our published review: Payments firms: delivering good outcomes for consumers in vulnerable circumstances[2].
If you run a smaller payments or e-money firm, the sections on considerations for smaller firms are designed with you in mind: they set out proportionate approaches that still deliver good outcomes.
I hope firms will reflect on these findings, continue the practices that are working well, and make changes where improvements are needed.