Helen PettiferHelen PettiferJune 25, 2019


Every customer deserves to be treated fairly and with respect.

It sounds simple enough, yet many company policies, procedures, and attitudes create unnecessary barriers – especially when it comes to vulnerable customers.

From plastic surgeons to bankers, there is a growing realisation that organisations are often falling short in good practice when it comes to vulnerability. Moves are underway to regulate industries in order to deliver services with a greater customer focus.

Who are your vulnerable customers?

Vulnerability is not set in stone. According to the Financial Conduct Authority, “Vulnerability can come in a range of guises, and can be temporary, sporadic or permanent in nature.”

Any of us might be fully capable today, but a sleepless night before a stressful job interview might leave you less able to focus tomorrow. Throw in the news that, for example, a close relative has been in a serious accident, and suddenly dealing with everyday tasks becomes a challenge. Emotionally vulnerable and unable to fully focus, it makes all the difference when others are understanding, patient, and respectful.

Identifying vulnerable customers is not easy, especially when it is a dynamic state. An organisation can better meet a customer’s needs if they are made aware. Being open and honest about a condition or situation can be helpful, but disclosure is not straightforward.

Assistance: An organisation can better meet a customer’s needs if they are made aware of vulnerabilities

Five challenges of disclosing a vulnerability

In order to inform others of the specific support needed to access and use their services, an individual has to:

Be aware of their needs: A person with dementia or impaired cognitive learning is not going to necessarily recognise that they are any different from anyone else. Equally, some conditions may not be diagnosed.

Admit their needs: Would you notice that your hearing has faded or that your habits have become addictions that impact on everyday life?

Understand how disclosure will benefit them: This is very personal information and most people would prefer to keep it to themselves, unless they can see the benefits.

Trust the individual and organisation: How will the information be used? Who will have access to it? Will it have a negative impact on the service received?

Have the right opportunity to share the information: If the frontline staff are unapproachable or the environment is not conducive to a private conversation, it is unlikely that disclosure will occur.

Vulnerability taskforce

The finance industry is proactively encouraging positive change and inclusivity. As an example, the BBA is working with consumer groups and charities, as a ‘Vulnerability Taskforce’. Their aim is to improve outcomes for customers in vulnerable circumstances.

One clear objective is that every organisation has smart data systems in place to record information that is disclosed. The focus is on ensuring sufficient continuation to support a ‘tell us once’ approach. Another focus is on building staff awareness through Vulnerable Customer Training. The aim should be to develop a customer-focused company culture, where the stigma of vulnerability is removed.

It is only when everyone is engaged in the process that consistency in approach can be achieved. As such, all employees should be equipped to spot the signs of vulnerability, respond appropriately, and ask the right questions in order to deliver the best outcomes. The awareness and skills can also come into play when colleagues are in need of additional support.

Disclosure and GDPR

If individuals share information, they expect it to only be available to those who need to know and only for the purpose of improving customer service. This throws up the question of how organisations store and protect personal information in line with GDPR.

Having researched good practice, my recommendation is to be solution focused. In most cases, it is not necessary to know the cause of the vulnerability.

Employees should be encouraged to steer the conversation to what an individual requires in order to access and use services. The data may simply say that this customer needs a longer appointment slot or should be provided with information in large font. This greatly reduces the risk of personal information being shared.

How can organisations encourage customers to disclose vulnerability?

Addressing all of the points raised in this article, I advise companies that wish to treat every customer fairly and with respect to:

  • Create and implement a vulnerable customer policy that can be responsive and flexible to individual needs
  • Train all staff to build awareness, competency, and consistency across all departments
  • Develop a supportive, solutions-focused culture that encourages disclosure
  • Be proactive in understanding the customer journey and remove the barriers to make their services more accessible and inclusive
  • Use data systems to effectively support customer service excellence

It should not be difficult for any individual to access and use the services they need. No matter what industry, being fair and respectful is simply good practice.

Helen PettiferHelen PettiferMarch 14, 2018


The 2018 UK Complaint Handling Awards took place in London in February, and as a Customer Service Trainer, I was honoured to be invited to join the panel of judges.

Our panel was given responsibility for judging the Proactive Complaint Handling in the Utility Industry category. Five companies had been shortlisted and each one provided us with a written report and presentation. The aim was to highlight their approaches to both reduce complaints, and effectively manage complaints when they were received.

Investing in positive change

In truth, all of the nominated companies had been driven into action by the costs associated with poor complaint handling in the past.

OfWat (The Water Services Regulation Authority) governs the utilities industry and their objective is to build customer confidence in water and waste water services. As such, OfWat issues fines every time a customer makes a formal complaint and if the complaint isn’t resolved within 10 days, the fine increases.

With the cost of fines impacting on profits, the five finalist companies had recognised the value of investing in positive change.

As a judge, I wanted to see evidence of the companies stretching beyond the standards set by OfWat. In order to be praised for proactive complaint handling, I was looking for changes to the company culture and initiatives that were clearly rooted in delivering customer service excellence.

Complaint handling champions

It was fascinating to see the different approaches to tackling the problem and presenting the information. The judging panel learnt all about ‘training igloos’, recruitment campaigns, and processes to enhance efficiency.

All measures had clearly made a tangible difference to internal complaint handling procedures, but one company’s approach really stood out. United Utilities was presented with the Proactive Complaints Handling Award, and the decision was unanimous.

United Utilities

Serving 7 million customers in the north-west of England, United Utilities had been on the receiving end of too many complaints and they were taking too long to resolve them. There were no systems in place to learn from customer feedback, so many problems kept reoccurred. The company had earned a poor reputation and staff morale was low. They realised it was time for radical change.

What impressed me was that, rather than simply bolting on additional resources, the company involved the whole team in developing ideas to transform performance. They addressed their response to complaints and how to use customer feedback to inform change. In addition, they had adopted innovative ideas to reduce the number of complaints that are reported.

Speaking with customers

One noticeable point was the benefits of speaking directly with customers. Emails and letters have their place, but a telephone conversation on the day that the complaint was received has proved far more effective. A conversation helps to quickly clarify, and in some cases resolve, the issue.

Another strategy was to use a company bus and covered stands to have an active presence in the towns they were serving. This approach made the company far more approachable. Its impact has been especially beneficial when a burst main or other issue has had an impact on multiple customers. They’ve been there in person to provide information, updates, and practical support.

Reputation restored

Being party to the presentations, I took great delight from the fact that these companies had worked hard to restore their reputation and regain customers’ trust. The starting point was admitting the problem and having the motivation to take action.

Any business should openly seek the opinion of customers and not just those who they know will deliver a glowing report. Complaints may be hard to take, but it is better to know when you aren’t meeting customer expectations, because it gives you the opportunity to improve.

The awards provided evidence that any company can become successful, if they focus on delivering a truly customer orientated service.

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