Stroll Vulnerable Customer Process

Overview of a Vulnerable Customer:

Our definition of a ‘vulnerable customer’ is:

“Someone who, due to their personal circumstances, is especially susceptible to harm, particularly when we have not acted with appropriate care”. This can include:

a) Customers who have the capacity to make their own decisions but who, because of individual circumstances, may require assistance to do so; and/or
b) Customers who have limited capacity to make their own decisions and who require assistance to do so.

The FCA have identified four key drivers that may increase the risk of vulnerability:

Health: health conditions or illnesses that affect the ability to carry out day to day tasks;
Capability: low knowledge of financial matters or low confidence in managing money (financial capability). Low capability in other relevant areas such as literacy or digital skills;
Resilience: low ability to withstand emotional or financial shocks;
Impact of a life event: major life events such as bereavement, job loss or relationship breakdown. Vulnerable customers may fall into two categories:

RECORD KEEPING

Where we identify a vulnerable customer, this should be recorded on the system so that the customer does not have to repeat themselves in future interactions and we will be more responsive to the customer’s needs.
Reasonable concerns can be noted, this must be in a professional manner without opinions or subjective comments. Keep all notes factual.
Where appropriate and possible, a flag is to be placed on the system to identify this clearly at the outset to assist future interactions with the customer. Explicit consent needs to be obtained from a customer prior to recording any sensitive personal data.

Vulnerable Customer Example:

Mr Smith gets into a serious car accident (life event), it leaves him injured so unable to work (health, resilience). Mr Smith worked as a self-employed fitness instructor so is only paid when he works, has no savings and no sick pay (resilience). The stress of the matters leads to him becoming depressed and anxious (health) and he finds it hard to deal with people over the phone (capability).

Zendesk Process

Help and Support Zendesk Tab

This is used to record information for the customer so that anyone helping the customer in future will be aware the relevant vulnerability. This is not a diary tool and the information will not flag to another department.

Make sure notes are factual and without opinions as the client can request to view these.

Once selected this will bring up a screen with 4 categories to select from. If a customer falls into more than one category just choose the one you feel is the most appropriate. See above overview for guidance on categories.

Complete the internal Vulnerable Customer Help and Support Macro for the client:

For guidance on what may fall into each option check the Vulnerable Customer Policy and Characteristics of Vulnerability info sheet available on the Compliance Intranet page and the intranet notice of 13^th October 2022.

You can find the full Vulnerable Customer Policy on Zendesk.

If you are unsure as to whether a customer should be noted as a vulnerable customer, please refer to your Line Manager/Senior Management Team for advice.

If you feel upset or feel that the Vulnerable customer’s circumstances have affected you personally, please raise with it with your Manager and schedule time with them for a de-brief. Always seek additional support if required. Group HR can offer advice and assistance, including Mental Health First Aid support, and details of our Employee Assistance Programme. You can also refer to the support tools on the Group Intranet for specialist services that might be of assistance.