Marketing to vulnerable groups

Register your interest in this issue

Does your business have practices and policies to deal fairly with disadvantaged or vulnerable consumers?

EXCELLENT Answers

No EXCELLENT answers have been published for this question.

GOOD Answers

No GOOD answers have been published for this question.

OKAY Answers

No OKAY answers have been published for this question.

POOR Answers

No POOR answers have been published for this question.

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.

Fair Treatment

'Fair treatment' is not a term used in legislation because it is too subjective - but it is something that is widely recognised in its absence. Fairness is both relative, such as ‘low income’ in the UK being defined as 60 per cent of median household income, and it is an evolving issue, e.g. should people who pay bills online be charged less than those that pay in cash? A business is in a position to define what constitutes ‘fairness’ in a particularly business context or commercial sector and so deliver such ‘fair treatment’ to customers.

Answering YES

All Businesses MUST

State their business sector

Indicate which vulnerable groups their business operations are directed towards

Explain what practices and policies are in place to protect vulnerable customers

All Businesses MAY

State any philosophy or key values which govern or influence their business approach to vulnerable groups

Answering NO

All Businesses MUST

Explain why they do not meet the requirements to answer YES to the question, listing the business reasons, any mitigating circumstance or any other reasons that apply

All Businesses MAY

Describe any practice that exists, even if it does not meet the specifications for answering YES

Mention any future intentions regarding this issue

DON'T KNOW is not a permissible answer to this question

NOT APPLICABLE is not a permissible answer to this question

Version 1

To receive a score of 'Excellent'

Provisions for vulnerable/disadvantaged sections is a core value of key philosophies

Examples of policies and practices which may support an EXCELLENT statement (not all must be observed, enough should be evidenced to give comfort that the statement is the best of the four for the business being scored):

  1. Extensive training and awareness provided to management and staff to deal with people with special needs
  2. Detailed best practice guidelines on how to approach and deal with vulnerability
  3. Keeping such needs in mind when designing products and services (e.g.: disabled access, Braille scripts, audio recordings)
  4. Recognising different kinds of vulnerabilities and having bespoke policies to deal with each
  5. Developing an action plan tackling unfairness when dealing with disadvantaged consumers and/or work closely with relevant charities
To receive a score of 'Good'

Actively taking measures to improve products and services for vulnerable groups

Examples of policies and practices which may support a GOOD statement (not all must be observed, enough should be evidenced to give comfort that the statement is the best of the four for the business being scored):

  1. Has identified which consumers are more likely to become vulnerable and has developed a framework of how to deal with each one
  2. Offers disadvantaged groups specific support, contact information, advice and clearly-stated warnings
  3. Quick and prompt responses to deal with grievances made by members of such groups
  4. Efforts to ensure unambiguity and clarity in all communications
  5. Does not discriminate against any customers (such as differential prices, refusing custom)
To receive a score of 'Okay'

Minimal/ad hoc policies implemented

Examples of policies and practices which may support an OKAY statement (not all must be observed, enough should be evidenced to give comfort that the statement is the best of the four for the business being scored):

  1. No disadvantaged or vulnerable group of consumers identified
  2. Making an effort to treat all consumers equally but without identifying specific practices for the disadvantaged
To receive a score of 'Poor'

No provisions to deal with these groups

Examples of policies and practices which may support a POOR statement (not all must be observed, enough should be evidenced to give comfort that the statement is the best of the four for the business being scored):

  1. Makes no distinction when dealing with the consumers
  2. Policies exist but only on paper