This Scorecard is due to be updated in 2018
It is in the interest of every business to deal fairly with all consumers. If it is apparent that a potential customer or service user lacks the capacity to make a voluntary, informed decision about the benefits and/or implications of their purchasing or contractual decisions, then a business needs to act responsibly and take extra care in its dealings to ensure that no unfair advantage is taken. A refusal to do business with disadvantaged or vulnerable consumers is in no one’s interest and also may be in breach of anti-discrimination legislation. Not every consumer is always at risk, but marketing messages and business conduct may affect some consumers differently from others, when they are making decisions about buying goods or services.
‘Vulnerable groups’ are mutable but may include “those that experience a higher risk of poverty and social exclusion than the general population” . This may be people who:
● Have a low income or are unemployed
● Are from a non native-language background or are from an ethnic minority
● Have a disability (intellectual, psychiatric, physical, sensory, neurological or a learning disability)
● Have a limiting, longstanding illness
● Have poor reading, writing and numerical skills
● Are homeless
● Are pregnant
● Are households with certain tenure and accommodation types
● Are young
● Are old
● Live in a rural area with reduced communications.
As an example of the complexity of this issue, 23% of UK households did not have access to the internet in 2011 and these people tend to be low income, low education, with higher levels of illness or be elderly - yet more and more services are delivered on-line, including those of the private sector.
Actions by businesses to promote fair treatment of vulnerable customers include:
● Making certain that business actions do not take advantage, intentional or not, of any disadvantaged or vulnerable group
● Ensuring all staff are fully informed on current practices and policies
● Keeping the needs of current and potential consumers in mind when designing any marketing strategy
● Training staff to be flexible and aware of relevant regulations and laws, such as those on fair trading and anti-discrimination
● Not rewarding staff or agents for unfair, pressure-based selling
● Ensuring marketing and service information is written and presented in a simple, clear and accessible way
● Disclosing all terms and conditions, without hidden small print. If necessary, give customers time to properly consider and understand terms and conditions and possibly offer a 'cooling off' period
● For some vulnerable customers, considering whether a guardian, carer or other appropriate person should be present to support or act on their behalf
● Encouraging a customer to take further advice before making a contract or a purchase, if there is any doubt about their full understanding
● Making certain that complaints are resolved openly and quickly and if appropriate/necessary, set aside a contract or agreement without penalty.
Dealing fairly with vulnerable customers builds a good business reputation and creates customer loyalty, not just with an individual but also with family, carers and community. Poor treatment has the opposite effect.