Ofgem has recently published its new consumer vulnerability strategy, outlining its expectations of how energy companies should treat consumers in vulnerable situations. The strategy highlights a British Standard – BS 18477 Inclusive Service Provision – as a useful tool to help organisations identify and respond to consumer vulnerability more effectively.
Consumer Futures, in conjunction with Citizens Advice and Citizens Advice Scotland, has defined consumers in vulnerable positions as: “People who cannot choose or access essential products and services which are suitable for their needs or cannot do so without disproportionate effort, cost or time”.
All consumers are different, with a wide range of needs, abilities and personal circumstances. These differences can put some people in a position of vulnerability or disadvantage during certain transactions and communications, potentially putting them at risk from financial loss or other detriment. The factors that can place consumers in vulnerable situations can be extremely complex and may include health issues or a change in personal circumstances.
These complexities can make identifying vulnerability something of a challenge, particularly for organisations concerned about being overly intrusive or insensitive to their customers. Despite their best intentions, some suppliers may be excluding or disadvantaging consumers by the way they deliver their services. There are several reasons this may happen, including practical issues, such as: the transitional nature of each individual’s circumstances; reluctance on the consumer’s part to share details about personal issues over the phone or at point of contact; and the implications for companies when it comes to storing or sharing data related to potential vulnerabilities.
BS 18477 provides guidance to help organisations use non-intrusive methods of enquiry to identify possible signs of vulnerability or “trigger factors”. Early recognition of problems may prevent escalation of issues, particularly when related to outstanding payments, debt or anxiety from not being able to understand a bill.
BS 18477 asks organisations to first assess the impact of their services, to think about their accessibility, where consumers may be disadvantaged or excluded, and what changes might be made to make the organisation and its services more inclusive.
In other regulated sectors, consumer-facing organisations such as the Financial Ombudsman Service (FOS) report seeing great benefit from training staff to deal more effectively with enquiries and complaints from people in vulnerable situations and from ensuring their inbound communication channels and systems are accessible. As a result of the FOS training programmes, staff awareness, confidence and well-being also increased.
In the energy market, tariff systems and initiatives such as the Priority Service Register (PSR) have been set up to provide support to those who may need assistance or be in potentially vulnerable situations. PSRs were introduced to identify those of pensionable age, disabled or chronically ill and who may require a more flexible approach or additional free services.
A BSI white paper highlights several areas where an inclusive approach in dealing with consumer vulnerability could benefit organisations and their customers. Compliance with the relevant laws is one such area. The BS 18477 standard can help organisations meet their obligations relating to the Equality Act and Consumer Protection from Unfair Commercial Practices regulations, for example.
For any organisation providing services to the public, a good reputation for service and corporate responsibility can inspire trust and loyalty, helping keep existing customers and win new ones. Identifying and responding to vulnerability promptly and effectively may reduce costs, as well as showing companies are “doing the right thing” by their customers.
Adopting the British Standard will help suppliers of essential services think about how their services and wider business activities affect vulnerable consumers. Organisations providing fair, flexible and more inclusive services are proving their commitment to good customer service and social responsibility. In a highly competitive market, showing that you care is important, both to the success of your business and the way it is perceived by existing and potential customers.
Nick Fleming, services sector content manager, BSI
This article first appeared in Utility Week’s print edition of 13th September July 2013.
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