Vulnerable Customer Policy

August 2024

This policy is also available as a document: Vulnerable Customer Policy (PDF)

Introduction

Our Vulnerable Customer Policy sits alongside our Customer Service Policy, and it reflects our commitment to treat all customers fairly and respectfully, with equality and diversity at the heart of everything we do.

Where any of our customers tell us that they are vulnerable, we will ensure that we assist where we can to support them and to provide a customer focused high quality service.

Our Vulnerable Customer Policy reflects our commitment to providing an excellent level of service to the people we deal with, whether they are solicitors, applicants, opponents, suppliers or members of the public: our customers.

This policy, which links directly to our Corporate Values, sets out how we will interact with people and how people should interact with us.

Understanding the definition of vulnerability

A customer in vulnerable circumstances is someone who, due to their personal circumstances, such as those listed below, is especially susceptible to harm, particularly when an organisation is not acting with appropriate levels of care.

When is a customer vulnerable

When our staff are dealing with customers, their vulnerabilities can be revealed during conversations or in correspondence. These should serve as flags to staff, who should then ask questions to try and uncover the full extent of the vulnerability.

These flags in conversation or correspondence could include disclosure of:

  • long term underlying illness
  • physical or mental disability
  • bereavement of family member or close friend
  • loss of income
  • struggling with financial matters/obligations/debt
  • being homeless
  • age
  • domestic abuse.

Other flags could be discovered in the course of our engagement with the customer, such as:

  • difficultly understanding simple financial matters
  • difficulty retaining information – including over multiple interactions
  • relying on a third party for advice.

Time, consideration, sympathy and flexibility will be key tools in handling the initial discussions.

Extra care should be taken if several of the flags overlap, as this would indicate a vulnerability that may require extensive and or external support to achieve a good customer outcome.

Our Principles

We seek to recognise customers in vulnerable circumstances and encourage all to self-declare if appropriate, safe in the knowledge that we will:

  • adapt our business processes and professional services, so our customers do not suffer detriment at any point where they have been identified as vulnerable
  • process information gathered in line with GDPR, Consumer Protection regulations, The Adults with Incapacity Act 2000 and the Equality Act (2010) (Specific Duties) (Scotland) Regulations 2012
  • consider the application of the above as ‘business as usual’ and not part of a separate compliance or ‘stand-alone’ exercise.

Our staff will aim to deal compassionately, empathetically and effectively with those in vulnerable circumstances by raising awareness of vulnerability and by providing training to all within our organisation in appropriate methods of engagement.

When we encounter customers in vulnerable circumstances and recognise that they may be in immediate danger of significant abuse or harm, or may need immediate support, we will take action to contact the appropriate authorities to mitigate the risks they face.

More information

Please contact:

Cindy Morrice
Head of Civil Finance
Email: morriceci@slab.org.uk.