Vulnerable Customer Skills

The Financial Conduct Authority Defines Vulnerability As:

"Someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care"

When we think of vulnerable customers it's common to think of those who are elderly or have a disability. However, there are many more types of vulnerability, some of which can be temporary. Types of vulnerability can include (but are not limited to):

Customers that are:

Elderly, on low income, carers, lone parents, leaving care, suffering from a bereavement, recovering from a relationship breakdown, living alone, recently released from prison.

Customers that have:

Low literacy or numeracy, learning disabilities, cultural barriers, physical disabilities, mental health issues, English as a second language, health problems, lack of internet access, loss of income.

Regulators such as OFCOM, OFWAT and OFGEM are also placing an increased focus on the treatment of vulnerable customers. The 3 key pieces of evidence they seek are:


A strategy or policy that details the organisational plan for managing customer vulnerability

john-schnobrich-520022-unsplash (1)

Systems to internally identify, communicate and link information on vulnerable customers


Products and services that are tailored for vulnerable customers

And when the regulators aren't satisfied the fines can be significant. For example:

  • April 2018, An online betting company was imposed a fine of £1m, for allowing hundreds of vulnerable people to keep betting after they asked to be barred from doing so, while sending promotional material to 50,000 more
  • Dec 2018, A commercial bank & financial service provider to pay £32,817,800 - unfair treatment of customers, failing to act on information appropriately and failing to be open and co-operative in the retail bank sector
  • Oct 2018 An Insurance service provider £5,280,800 - related to complaints-handling, culture/governance and unfair treatment of customers in the general insurance and protection sector
  • Aug 2018 An insurance service provider £684,000 - for breaches of PRIN 10 and CASS relating to client money/assets in the general insurance and protection sector
  • April 2015 An utility provider forced to pay £7.75 million for overcharging. The £7.75 million went to Citizens Advice to be used to help vulnerable customers
  • December A utility provider forced to pay £11.1 million to vulnerable energy users
  • May 2014 A utility provider forced to pay £12m to vulnerable customers following their mis-selling

Ember have developed a range of solutions to help you build an effective strategy including:

  1. A one day facilitated workshop to understand the signs and develop the skills for conversation management with vulnerable customers
  2. A bespoke facilitated workshop including examples from your own organisation with an option of a video or a Virtual Reality Experience to reach hearts and minds
  3. A digital module to introduce the importance of vulnerable customers and raise awareness and knowledge (can be used alone or as part of a blended learning strategy with the above classroom modules)
  4. A daily quiz check with Errol Owl, our online learning platform that tracks knowledge and skills on vulnerable customers in an engaging and supportive way (click here to find out more about Errol Owl)

Get in Touch!

Fill out my online form.