21 questions, 21 steps - new guidance on vulnerability launched this week

21 questions, 21 steps - new guidance on vulnerability launched this week


Author: Jenny Ogden

Applies to: UK wide

Shoosmiths has contributed to the latest industry guide on vulnerability.

Vulnerability: a guide for debt collection, 21 questions, 21 steps is primarily aimed at the debt collection sector but its underlying messages are equally applicable to a much wider field.

The guidance, sponsored by the FLA and the UK Cards Association, was written by Chris Fitch (Personal Finance research Centre, University of Bristol and Money Advice Trust), Jamie Evans ((Personal Finance research Centre, University of Bristol ) and Colin Trend (Plymouth Focus Advice Centre). The guide runs to 94 pages and contains practical advice and case studies which can easily be translated into processes and procedures.

The guide, designed for businesses dealing with debt collection, can be used to dip into in respect of specific situations or aspects of dealing with those in vulnerable situations.

The introduction deals with an update on where we are today compared to where we were when the forerunner of this guidance was first published. The pace of change and innovation within the industry and the need to continually strive towards better customer experiences, means our thinking about and our interaction with those in vulnerable situations, needs also to continually evolve.

The guide goes on to tackle some key issues facing the industry in respect of vulnerability and gives non-judgmental, practical advice. The first segment of questions and steps focuses on staff actions. The first step is about sharing knowledge and experience between staff. Implicit within this is achieving consistency across the board. One of the biggest problems firms face, is ensuring there is a consistently good customer experience no matter what part of a firm is contacted. This applies even more so when a vulnerable person contacts a firm. The experience and standard of service given to the vulnerable person, should be consistent across the business.

Having a forum to share good practice and experience and also a mechanism to take on board from the people on the front line, what works and what doesn't, is invaluable. In the guide, there are questions and steps dealing with identifying vulnerability and linked to this, help with encouraging disclosure and about how to record disclosures. Other key issues covered are dealing with disclosures from third parties, together with help in respect of gathering further information, supporting the vulnerable person and working with external agencies.

The second section focusses on some very topical issues for the industry. More and more staff are reporting having to deal with suicide threats and step 13 covers some practical advice on this. There are also the important issues of staff resilience (step 17) and how to deal with addictions (step 16).

The final section is about business organisation and the setting up and maintaining of a framework which will result in better customer journeys for the vulnerable. There is guidance about effective training, quality assurance and internal checks to make sure that what happens in practice actually reflects the policy and procedures put in place.

The guide also lends itself to being a benchmark for best practice. The underlying messages hold true for businesses to import, even where there are commercial and practical considerations, which mean full implementation into their policies and procedures, is not possible. Businesses should compare their processes and procedures to the guide's recommended best practice and identify any areas for improvement. These can then be put together into a vulnerability action plan, with actions prioritised in respect of importance and given some realistic time scales for completion. A survey of staff could also be conducted to see if those working on the frontline put into practice the policies and procedures; that they do know where to turn to for help and assistance; that they know what support is available to them personally.

Read the guide here


This document is for informational purposes only and does not constitute legal advice. It is recommended that specific professional advice is sought before acting on any of the information given.