New Vulnerability In 2021

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Sarah Lawrence

Sarah Lawrence

Sarah has spent over 20 years of experience in the financial services industry, including over 16 years working at the Financial Ombudsman Service. Sarah specialises in customer service and complaints handling, with extensive experience of management and mediating complaints and is dedicated to passing on her knowledge and experience to businesses to improve complaints handling, customer service and consumers’ perceptions of the industry.

As we start to look forwards into 2021, we can’t talk about horizon scanning without referring to vulnerability. This has been a hot topic for some time now, with both the FCA and the ombudsman focusing their attentions on this subject. Couple this with what I can only describe euphemistically as ‘events’ from 2020, vulnerability should still be one of our industry’s top priorities.

The thing is, simply saying that we need to think about vulnerability isn’t enough. Real tangible action has to be made to show that you’re treating all of your customers fairly, regardless of their circumstances. And with the advent of Covid, there are large sections of society that are facing more difficulties than they’re used to, a ‘new’ vulnerability in itself.

Taking it back to basics, the FCA have identified four key areas of vulnerability and these are worth listing here:

  • Health: This can cover illness or disabilities, but they affect the person’s ability to carry out day-to-day tasks.
  • Life events: Something that has a massive, but possibly shorter-term impact on someone such as the death of someone close, the loss of a job, or even relationship breakdown.
  • Resilience: This means that someone has a reduced ability to deal with financial or emotional shocks, such as what we’ve seen during Covid.
  • Capability: Low confidence or knowledge of financial matters when it comes to managing money or in other areas that might impact on this area, such as literacy or digital skills.
Vulnerable consumer

Knowing these vulnerabilities means that, in principle, things should be more straightforward to administer. The reality, however, is that this area can be tough. We know from speaking to businesses that they’re doing their best when it comes to trying to level the playing field for their customers, but the difficulty is how do you spot someone that needs additional support? How do you know whether you can log something to show that this has been taken account of?

There are no straightforward answers to this because staff, there are many cases where spotting customer vulnerability is difficult. This means that the staff member needs to use their judgement when a listening to a customer talking about their situation. They need to assess whether that person is actually vulnerable, whether they could become vulnerable or what they could be vulnerable to. And if these needs aren’t spotted and met, then they are not being treated fairly.

Which is where the potential for complaints can come in because it doesn’t take much for a customer to feel they’ve not been treated fairly when they are being asked to take full responsibility for something beyond their control. As you can imagine, this is definitely something we’re seeing more of, as more people become ‘new vulnerables’ due to circumstances beyond their control, such as losing their job.  

Preparing staff to ensure they’re trained in vulnerability, to be able to show empathy and emotional intelligence so that they can react to the customer the right way, is critical. It also means being able to use those key complaint handling skills to be able to address what are incredibly emotive complaints, centred around customers feeling they’ve not been treated fairly.

And don’t get me started on the need for staff to understand working within the requirements for disclosure under GDPR rules, or how you need to ensure that customers aren’t having to repeat their distressing stories to multiple departments within your business.

For these reasons and more, vulnerability, is difficult to deal with. It requires a particular type of person to be able to deal with this type of complaint, and to be able to manage all the requirements while also ensuring that staff are sufficiently invested in the process to deal with these difficult and emotive complaints.

That’s why vulnerability will continue to be a hot topic as we move through 2021 and beyond.

Vulnerable Consumers


RegTech is a relatively new word but one that is key to the long-term success of managing compliance issues, complaints included, in the future. Regtech is the collective name, used by the FCA, to describe software solutions that manage compliance related processes more effectively, so increasing the probability of firms’ complying with the regulation, and at a lower cost.

Worksmart has picked up the ACQ ‘Complaints Management Solutions Provider of the Year’ award for the last two years for their complaints and feedback management system, Caresmart.

Caresmart has three key features that directly address the issues raised above:

  1. Vulnerability Flag: Caresmart enablers case handlers to mark complainants as potentially vulnerable.
  2. Helping Vulnerable Customers: The vulnerable customer flag provides the case handler with a list of vulnerability categories to allow for accurate identification within the case, along with any specific details about the vulnerability, if required. The system also allows for the identification of any customer support needs too.
  3. Reporting: The system also provides a set of Vulnerability reports, along with vulnerability filters being available on all the standard reports. This helps the business look at vulnerable customers ‘in the round’, so helping clear analysis of people’s needs and what the business can do to help. 


Watch this space for another blog about this issue, later in this series. 

In the meantime, if you would like to know more about how Caresmart could help transform your complaints processes,  contact our friendly and knowledgeable team on: 01908 613613 or email us on:




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