As Consumer Duty continues to shape the responsibilities of FCA-regulated firms, identifying and supporting vulnerable customers is a priority for contact centres and customer service teams. With an estimated 50% of UK consumers considered vulnerable at any time according to FCA published findings, your teams are pivotal in delivering the right outcomes for these customers.
Here, we address key questions and provide practical insights to help contact centre managers and customer service leaders identify and support vulnerable customers while meeting FCA expectations.
How Can Contact Centres Identify and Monitor Vulnerable Customers?
Contact centres are often the first line of engagement for customers, making them vital in identifying vulnerabilities. There are two primary approaches to this:
1. Direct Identification
- Engaging directly with customers during calls or interactions to ask about potential vulnerabilities.
- Using surveys (anonymous or targeted) to gauge the prevalence and types of vulnerabilities across the customer base.
2. Indirect Identification
- Leveraging data sources, such as credit reference checks or account history, to spot financial vulnerability.
- Implementing tools like voice analytics (human assessment) to detect emotional distress or other signs of vulnerability during interactions.
Proactive engagement is key. Many contact centres rely on reactive approaches – such as waiting for customers to disclose vulnerabilities – which leads to low identification rates. By actively and systematically engaging customers, firms can identify a broader range of vulnerabilities, from financial challenges to health and lifestyle issues.
Strategic (Top-Down) vs. Operational (Bottom-Up) Approaches
Effective vulnerability management requires both strategic and operational efforts:
Top-Down Understanding
- Conduct surveys to understand the overall prevalence of vulnerability within the customer base.
- The FCA’s Financial Lives survey, which shows 47% of UK adults are vulnerable, serves as a benchmark for assessing your own customer base.
Bottom-Up Identification
- Train agents to record vulnerabilities identified during conversations or other interactions.
- Adjust products, services, and communications accordingly – for example, offering large-print communications to customers with visual impairments.
Contact centres must balance these approaches, using top-down insights to design processes and bottom-up data to tailor individual support.
The Role of Proportionality for Contact Centres
The FCA’s proportionality rule applies to how firms approach vulnerability, and this impacts contact centre operations:
For Smaller Contact Centres
- Focus on gathering and documenting vulnerability data directly from customer interactions.
- Simple processes for recording and responding to vulnerabilities can ensure compliance.
For Larger Contact Centres
- Implement both top-down surveys and bottom-up data collection to achieve comprehensive coverage.
- Use multiple customer touchpoints – onboarding, complaints, renewals, claims – to build a complete picture of customer vulnerability over time.
Larger firms often struggle with embedding bottom-up processes, resulting in underreporting. Many report only 3–5% of customers as vulnerable, well below the FCA’s expectation of around 50%.
What Is the FCA’s Expectation for Proactive Engagement in Contact Centres?
The FCA requires firms to actively engage with customers to identify vulnerabilities. For contact centres, this means:
- Proactively asking about customer needs and challenges during interactions.
- Using surveys, call scripts, and review processes to assess customers for both temporary and permanent vulnerabilities.
- Capturing all relevant information, including mild vulnerabilities that may affect outcomes.
Practical Tip: Many contact centres fear that asking about vulnerability may disrupt service delivery or sales. In practice, customers respond positively when approached with sensitivity and clear communication.
How Does the Consumer Duty Affect Contact Centres?
Under the Consumer Duty, firms must ensure that vulnerable customers receive the same quality of outcomes as non-vulnerable customers. To achieve this:
- Assess All Customers: Aim for full coverage through systematic engagement and tailored support.
- Address a Range of Needs: Include health, lifestyle, and financial vulnerabilities in assessments.
- Focus on Outcomes: Monitor and report on the outcomes for vulnerable customers to ensure parity with non-vulnerable customers.
Without a robust process for identifying vulnerability, contact centres risk failing to meet the FCA’s expectations and, more importantly, failing to support customers effectively.
Download Our Comprehensive Guide
Ready to enhance your contact centre’s approach to identifying and supporting vulnerable customers? Download our full guide: Customer Vulnerability: Your Questions Answered
Elephants Don’t Forget, MorganAsh, FWD Consulting and the Collaboration Network have answered pressing questions about applying and embedding the FCA’s requirements on customer vulnerability within your firm. This resource provides practical strategies and actionable insights to help contact centres proactively identify vulnerable customers, comply with FCA guidelines, and improve customer outcomes.