Our process for dealing with potentially vulnerable customers
1.1. The purpose of this document is to set out the policies and procedures that the Firm has in place to ensure the fair and appropriate treatment of customers, who the Firm understands or reasonably suspects to be vulnerable or particularly vulnerable.
1.2. This document is for the use of the Firm’s staff who interact with customers in any capacity or otherwise operate in a capacity where they can be reasonably aware of information that indicates a customer is vulnerable or particularly vulnerable and provides a documented framework to promote the consistent fair treatment of customers who are vulnerable or particularly vulnerable.
2 REGULATORY REQUIREMENTS
2.1. Consumers are placed at the centre of the FCA’s regulatory regime and their protection is one of the FCA’s operational objectives. The FCA advances its consumer protection objective through its high-level principles, as set out in the Principles for Businesses module of the FCA Handbook, and specific conduct rules that apply to the Firm’s regulated activities.
2.2. The Principles for Businesses that underpin the fair treatment of vulnerable customers are as follows:
2.2.1. Principle 2 - A firm must conduct its business with due skill, care and diligence;
2.2.2. Principle 3 - A firm must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems;
2.2.3. Principle 6 - A firm must pay due regard to the interests of its customers and treat them fairly; and
2.2.4. Principle 7 - A firm must pay due regard to the information needs of its clients, and communicate information to them in a way which is clear, fair and not misleading.
2.2.5. Principle 6 underpins the Firm’s obligation to ensure the fair treatment of vulnerable customers in that the fair treatment of customers depend, in part, on the characteristics of the customers concerned therefore, to pay due regard to their interests and treat them fairly, the Firm must understand what makes such customers vulnerable, understand their needs, and ensure the consumer credit products it provides supports the fair treatment of vulnerable customers.
2.3. The Principles of Businesses are supplemented by conduct rules which require the Firm to establish and implement clear, effective and appropriate policies and procedures for the fair and appropriate treatment of customers, who the firm understands or reasonably suspects to be vulnerable or particularly vulnerable.
2.4. GDPR (General Data Protection Regulation) puts in place requirements which prohibits the processing of specific data (Defined in section 7.2) without the appropriate justification or consent.
3.1 DEFINITION OF VULNERABLE CUSTOMERS
3.1.1. The FCA defines a vulnerable consumer 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’.
3.2 SPECTRUM OF VULNERABILITY
3.2.1. The policies and procedures set out in this document ensure that the Firm identifies and appropriately treats all consumers that sit on a spectrum of vulnerability in the context of the Firm’s consumer credit offering (i.e. are susceptible to detriment should the firm not act with appropriate levels of care).
3.2.2. The Firm has identified the following customers to sit on its spectrum of vulnerability vis-à-vis the Firm’s consumer credit offering. The Firm has set out below the customers that sit on its spectrum of vulnerability from lowest risk to highest risk based on (1) the likelihood of the vulnerability materialising to consumer harm should the Firm not act with appropriate levels of care and (2) based on the potential impact on the relevant customers with the vulnerabilities should the harm materialise:
3.2.3. Customers with communication difficulties (including learning difficulties and English not being their first language, dyslexia) A customer with a reduction in physical or mental capacity Customer with health issues - illness, whether physical or mental illness, severe or long term A sudden diagnosis of serious illness to the customer or close family member Personal circumstances of the customer – factors such as financial difficulties, bereavement, caring responsibilities or redundancy
4 IDENTIFYING VULNERABLE CUSTOMERS
Due to our business model and very limited interaction with the customer directly however our team will try to identify vulnerable customers when we interact with them directly to allow us to take extra steps to assist outside of our standard procedures. This will include asking questions, looking for indicators and providing customers multiple opportunities to declare any vulnerabilities. However, it is not always possible to recognise these characterises. Therefore, we urge customers to make us aware if they feel that they may fit the criteria for a vulnerable customer. This may include the below Health; - Physical disability - Severe or long term illness - Hearing or visual impairment - Poor mental health - Addiction - Low mental capacity or cognitive impairment Life Events; - Retirement - Bereavement - Income shock - Relationship breakdown - Caring responsibilities Resilience; - Inadequate or erratic income - Excessive debt - Low savings - Low emotional resilience Capability ; - Low knowledge or confidence in managing finances - Poor literacy or numeracy skills - Low English language skills - Poor or non-existent digital skills - Learning difficulties - No or low access to help or support
5 DEALING WITH THIRD PARTIES REPRESENTATIVES
We understand that due to a vulnerability a customer may ask our business to deal with a 3rd party on their behalf in the event that they have cause for concern with the heating product they have purchased. We require that 3rd party to be identified in writing where possible along with the relationship to the 3rd party. In addition, we require the 3rd party to have a working knowledge of situation to ensure a positive outcome for all parties.
6 MAKING ADJUSTMENTS TO SERVICE DELIVERY
We possible we will adjust services that we offer, this adjustment is based on the personal situation of each customer. This include but not limited to, larger scale print information, read aloud options for key information. Control contact times including visitation of our service agents. It will be at the discretion of business what adjustments are made and approved by the Worcester Bosch Consumer Credit team as an overseer of our consumer credit offering. This is in reference to the heating products we provide, as we do not directly offer financial products it will ne the provider (Novuna Personal Finance) to provide adjustments to the service delivery.
7 MAKING RECORDS
7.1 ORDINARY RECORDS
In general due to our business model, we keep very limited records on our customers. Normally only if a complaint is raised directly with us will we make a customer record. However in the case that we do the following applies. • If we identify particular communication needs, we store that information so future contacts are handled appropriately with their permission • We record that we are satisfied that the customer completely understood everything that was discussed • We allow customers to make a personal declaration about their capabilities or communication needs and store this information with their permission • Any records that are held are with the full knowledge and consent of the customer and are deleted when the relationship no longer exists in accordance with GDPR
7.2 SPECIAL CATEGORY PERSONAL DATA
We do not and will not collect or store special category personal data. Due to our business model and not directly offering financial products the obligations relating to special category personal data falls to the provider (Novuna Personal Finance) to fulfil the obligations.
8 OBTAINING EVIDENCE
8.1 CIRCUMSTANCES WHERE EVIDENCE IS REQUIRED
In the limited cases that a customer does contact us directly we base our requirements on the below. Due to the personal nature of each vulnerability we aim to reduce the burden on our customers to provide evidence of a vulnerability where possible to do so. In each case we will assess the need for evidence and the customers’ ability to provide it, coming to an agreement with the customer.
8.2 TIMESCALE TO OBTAIN EVIDENCE
Due to the personal nature of each vulnerability we aim to reduce the burden on our customers to provide evidence of a vulnerability where possible to do so. In each case we will assess the need for evidence and the customers’ ability to provide it, coming to an agreement with the customer including what a reasonable time scale to provide this information.
8.3 INTERNAL INVESTIGATION
Due to the limited interactions with customers directly and not providing services directly and investigation would be conducted by the provider with our support.
9 ACCOUNT REVIEWS
We will review accounts of customers where a vulnerability has been identified on a case-by-case bases. This may include to improve our response or to ensure the support offered was appropriate. When a review is completed, the following departments will be involved. 1. Customer Relations Teams 2. Consumer Credit Team The oversite of all reviews will be provided by the Approved Person.
10 MAKING REFERRALS TO THIRD-PARTY SUPPORT PROVIDERS
If during our interactions with a customer where a vulnerability has been identified we are able to sign post the customer to additional support or advice we may provide them with information from the following services. • Stepchange • Money Advice Trust • CAB • Samaritans • Age UK • Alzheimers Society • Mind
It is the responsibility of our board to approve all company policies and the approved person to oversee the review of this policy on an annual basis.
11.2 INTERNAL AUDIT
All policy’s of this type are reviewed by the consumer credit team on an annual bases overseen by the Approved Person who is also a legal board member.
All company policies are reviewed on annual basis by the board of directors to ensure they meet the company requirements. In addition auditing is completed by the wider parent company as and when needed.
12 RECORD KEEPING
12.1 RECORD STORAGE
In line with the process identified in Section 7, the Firm does not obtain or record customer information in relation to its consumer credit business model and hence the Firm does not record Vulnerable Customer information save as should a complaint be received. In the event a complaint is received this will be recorded in line with the Firms complaint handling policy.
12.2 RECORD RETENTION
In line with the process identified in Section 7, holds all records inline with GDPR requirements as set out in our data protection policy and deleted when the relationship expires.