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Why the CSA need a signed copy of your complaint




Blog: Financial services and vulnerability: From principles and panels, into practice and change

Chris Fitch is Research Fellow at Bristol University’s Personal Finance Research Centre where he leads a programme of work on financial services and vulnerability. He will be sitting on the vulnerable customers, mental health and debt collection panel at the Credit Services Association’s UK Credit & Collections Conference #ukccc on 15 September 2016.


A few weeks ago, I heard a young woman save someone’s life. She wasn’t a counsellor. She wasn’t a paramedic. She wasn’t a doctor. She worked in debt collection. The actions she took stopped an extremely distressed customer from taking their life.

At the UK Credit & Collections Conference 2016, I’m looking forward to hearing how the industry is working with customers in such vulnerable situations. Two years on from the Financial Conduct Authority’s paper on ‘vulnerability’, positive changes are happening. And these changes have come from the debt collection sector – how collections professionals have taken the FCA paper, and turned high-level principles into frontline practice.

Doing this is far from easy. And it would be wrong to think that everyone is getting this right, or that everyone has started to make these changes. And it would be very wrong indeed, to conflate ‘progress made’ with ‘job done’.


So, where is the debt collection sector with vulnerability, and what still needs to be done?

Early in 2017, with my colleague Jamie Evans at the University of Bristol, we will be launching the findings of a new UK wide study with frontline collections staff which will aim to answer both these questions (find out more here:

Although these results are not yet all in, what is already apparent is that significant thought is being given by organisations across the financial services on how best to identify and support customers in vulnerable situations.

For smaller to medium-sized organisations, this can often mean meeting the challenge of how best to ‘cut’ new vulnerability specialists, teams, or processes from the existing ‘organisational cloth’ – while some guidance exists on doing this, some firms argue that this is a far easier task for a larger and better resourced organisation.

For medium-sized to larger organisations, we have heard about the stiff challenge of ‘rolling out’ a consistent vulnerability policy and process across the business.  This includes not only getting the training and development of staff ‘just right’, but also introducing quality assurance ‘scorecards’ which measure and calibrate staff performance, ensuring that the relevant data about a customer’s vulnerable situation is identified and recorded, and developing flags/indicators that are robust.

For some organisations, such a ‘roll out’ may also mean persuading other parts of the business - such as credit provision - to learn from the experience and successes that the collections department has achieved. This doesn’t always happen, and some businesses fail to appreciate what they have already achieved within collections, and start afresh with a ‘global process’ that will only slow progress.

Whatever the size of the business, these are all difficult challenges – but having now worked alongside (and inside) these organisations for the last decade, I know that they can be overcome.

What still needs to be done?


1. Start with the basics.

Everyone – no matter how experienced they are in the debt collection field – should start by asking themselves whether they are meeting the basic requirements. Are they really looking out for all the behavioural indicators when it comes to identifying vulnerability, or just the shorter list printed by the FCA in their Occasional Paper No 8? If they’re still using a list, then this will mean some customers will not be identified, or getting the support they need. Are firms really aware of their responsibilities when it comes to the Data Protection Act and vulnerability – a number still seemingly don’t have a firm grasp on the basic requirements? Are organisations asking the right questions of their customers to encourage disclosure, to manage disclosure, and to understand a vulnerable situation?  This isn’t always the case.

And, finally, we need to get our basic data recording and monitoring right. If we don’t know how many customers in a vulnerable situation we are encountering in our business, then we are likely to do three things:

  • Under-estimate the challenge (“it doesn’t really happen here, we’re very transactional”;
  • Over-estimate the problem (“literally everyone we work with is vulnerable, our specialists are completely over-run); or
  • Put it on the ‘to do’ list (“it’s important, but we’re working towards it – it’s an evolving process for our business”.

Simple data-recording will allow every business to know exactly how big the challenge is, how much resource it requires to deal with it, and the return on this investment over time.

So before we rush to ‘real time’ speech analytics of conversations, investment in new database systems, and apps and gadgets, let’s get the basics nailed on. Otherwise, we have an unstable foundation on which to build.


2. Look outside the collections industry

There is a lot of work taking place at the moment on vulnerability – however, not everything is being produced within the creditor sector, or targeted at it.

The energy and water sectors are now getting to grips with the issue, and we can expect them to produce some useful future material, including guidance on face-to-face engagement between ‘field agents’ and customers in vulnerable situations.

We also know that the debt advice sector is now actively considering vulnerability – earlier this year, Colin Trend and the Money Advice Trust published a ’12 steps guide’ for advisers which contained new information on vulnerability, including working with customers with terminal and serious illness.


 3. Make best use of technology

Technology holds a key to progress. Not the key.

While we need to remember that discussions around vulnerability will always require a human interpretation and response, speech analytics promises to help us either identify a potential issue during real-time routine conversations, or to retrospectively ‘crawl’ over data to understand why these issues are being missed.

Equally, engaging with customers online and via social is already happening, and provides a productive way to make and sustain contact. However, we need to ask about how we identify and support customers in vulnerable situations who use these channels. What is feasible? What is expected?


Everyone has a part to play in addressing vulnerability – and potentially saving customers’ lives

A few weeks ago, I heard a young woman save someone’s life. She worked in debt collection, rather than the NHS, but she stopped a customer from taking their life.

While discussions about suicide with customers are rare events, they do happen. What saved this customer’s life was the practical action that this debt collection agent took.

However, to take this action, she needed the training that her firm gave. Which drew on the policy on suicide and crisis events that someone else in the firm created. Which was developed because someone at a senior management level recognised the need for this. Which happened because we all know that we have a part to play.

Next week’s panel on vulnerability will return to this theme - like everyone, I look forward to hearing how you are all working with customers in such vulnerable situations.