Vulnerability Training for Employees

Vulnerability training for employees is not only essential for FCA authorised firms, but also any business that may be dealing with customers. Having employees who are able to identify when a customer is vulnerable and knowing how to help them is an essential business function.

At Know Your Compliance Limited, our Vulnerable Customer training and toolkits are designed for regulated industries. However, many sectors have used our templates as a bassed to customise their own content in this important customer facing area.

What is a Vulnerable Customer?

There are many situations and events that can make a customer vulnerable. As a person reading this article, you will have no doubt experienced vulnerability yourself! Most of us have had to deal with bereavement, financial difficulties, anxiety or illness. It’s easy to forget the not all vulnerabilities are permanent!

You might be perfectly capable of getting quotes for your home insurance each year. But, what if you’ve just lost someone close and your mind isn’t functioning the way it usually does? Your mortgage application will still need to be processed even though you fell down the stairs and broke your leg…pain, medication and stress weigh heavy on an already stressful process.

Employees need to understand that a vulnerable customer comes in many forms. Long-term, short-term, physical, mental, chronic, acute! Training your employees is as important for your business as teaching them how to use the phone or computer system.

The FCA defines a Vulnerable Customer as “someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care.”

Defining Vulnerabilities

Know Your Compliance Limited have spent 10+ years working on templates, policies and training packages for vulnerable customer compliance and awareness. That means we’ve absorbed a LOT of information on the subject. Below are the best descriptions we’ve come across for defining what a vulnerable customer is.

1. Customers who are unable, for whatever reason, to make an informed decision at the time of dealing with them – customers falling into this category include those with language barriers, hearing difficulties, those with mental health issues, suffering from bereavement, learning difficulties or the elderly. These customers may struggle to decide on whether the service or product you are providing is in their best interests.
2. Customers whose welfare (financial, mental or physical) could be put at risk through choosing the service or product we offer – these customers include anyone who is going to be put at detriment from taking up our offer/product/service. This includes financially (i.e. if taking out a loan or setting up a payment plan could cause them added financial stress).

Ask Your Employees These Questions

Wondering if you actually need vulnerable customer training for your employees? Maybe you are a small business and think weekly team meetings will have the same effect. In truth, you may be right! We’re not trying to sell you a Vulnerable Customers Training Package if that’s not what you need. If you are able to cover all the questions and answers in weekly meetings, then we would just advise you to document the minutes and still test outcomes and knowledge.

However, why not ask your employees some of the below questions to see if they really know as much about vulnerable consumers as you hope they do!

• Have you read (and do you understand) the FG21/1 guidance paper?
• What is meant by providing customers with an appropriate degree of protection?
• How can you understand the needs of your target market and customer base?
• Does the business have a Vulnerable Customers Policy?
• How would you identify a vulnerable customer during a phone call?
• Suggest ways to offer consistently fair treatment to customers?
• What do we mean when we say “The business should consider customer needs from product design through to communications”?
• Have you ever been a vulnerable customer?
• Name 6 different types of ‘vulnerability’?

Training & Testing

Training and testing are like staples in a stapler…..they work best together!

Employees are often the first point of contact a vulnerable customer has. Their  understanding and ability to handle difficult situations is essential to your business achieving good outcomes. Where employees do not have adequate or appropriate training, customers can suffer further harm or undue stress as a result.

A trained employee is an informed employee. Their ability to see or hear clear indicators of a vulnerability means they are much more likely to encourage a disclosure from the customer. A good training program will only take you half way toward vulnerable customer compliance.

Follow up all training sessions with employee testing and assessments. Post training should always include Vulnerable Customer Q&A Tests. These serve the dual purpose of testing your employee knowledge and understanding as well as acting as evidence of your training framework.

You should also give each employee a feedback form after all training sessions. These should be completed anonymously to encourage unbiased feedback. It helps to ensure your training session and the trainer delivering it is suitable and effective.