
Louise Mushet
Louise is a senior service designer who is passionate about using her skills for good. She's a whizz at driving design research, translating insights into opportunities, and bringing people and ideas together through skilful facilitation.
As you may have read in Sarah’s recent blog, financial services firms have just one year – until July 2023 – to build their design solution to safeguard vulnerable customers.
We’ve recently completed a 10 week design sprint with one of our more advanced financial services clients, where we helped to build awareness and create a toolkit on this very topic.
We learned a lot. Much of it too important to keep to ourselves. So in the spirit of being inclusive – and given the shifting regulatory landscape – we wanted to share what we learned with you.
Recognise that everyone is vulnerable

Understanding vulnerabilities is important, but it’s what you do about it that matters.
As part of our research recruitment, we asked participants to identify and disclose their vulnerabilities. As shown in the image above, these can range from having any health condition, suffering a bereavement, losing a job, or experiencing a relationship breakdown.
But during the interviews themselves, we began to hear of other examples that people didn’t initially disclose. In fact, participants didn’t seem to recognise them as vulnerabilities at all.
For example, almost everyone we heard from had been a victim of fraud or had experienced difficulties during the pandemic – but didn’t see these as things which made them vulnerable. This means there’s a huge degree of intersectionality occurring within individuals that they probably aren’t aware of, but we should be.
Thats why the Financial Conduct Authority (FCA) introduced guidelines around the fair treatment of vulnerable customers in early 2021. They define 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.
FG21/1: Guidance for firms on the fair treatment of vulnerable customers
This is broken down further in their four drivers of vulnerability, which is well worth a read.
Table: Characteristics associated with the 4 drivers of vulnerability
Health | Life Events | Resilience | Capability |
---|---|---|---|
Physical disability | Retirement | Inadequate (outgoings exceed income) or erratic income | Low knowledge or confidenceinmanaging finances |
Severe or long-term illness | Bereavement | Over-indebtedness | Poor literacy or numeracy skills |
Hearing or visual impairment | Income Shock | Low savings | Poor English language skills |
Mental health condition or disability | Relationships breakdown | Low emotional resilience | Poor or non-existent digital skills |
Addiction | Domestic abuse (including economic control) | Learningdifficulties | |
Low mental capacity or cognitive disability | Caring responsibilities | No or low access to help or support | |
Other circumstances thataffectpeople’s experienceoffinancial services eg, leaving care, migration or seeking asylum, human traffickingormodern slavery, convictions |
Vulnerability is broad, transient, and situational.
When it comes down to it, anyone can be vulnerable at any time.
When reading this breakdown it becomes easy to recognise not only which vulnerabilities others may have, but which of those we may have ourselves. Vulnerability is broad, transient, and situational. When it comes down to it, anyone can be vulnerable at any time.
So what can you do about it?
First, build inclusive mindsets
Inclusive design needs to be at the heart of what we do.

This is more than a buzz word or tick box activity. It requires challenging existing cultures and behaviours of exclusion, bias and stereotyping.
This means adopting a truly human centred approach that embraces diversity. It also means creating products, services and experiences that are accessible, usable and societal by default. It means designing for all.
So these are some of great tools and practices that we use to define what an inclusive mindset means in a client’s context.
Next, introduce inclusive resources
You need to use some practical resources to embed an inclusive design mindset. We’ve found that the following four are good starting points:
Agree your principles
The foundation of any good design practice starts with some rules, guidelines, outcomes or commandments to follow. The open source bank of Design Principles are a good place to start if you’re looking for some examples or inspiration.
While you can use a source like design.principles for inspiration, we strongly encourage you to create your own so that they fit your context and can be picked up easily and used by your colleagues.
Set your standards
Take your principles to the next level by thinking about how you can apply and measure your process and design. GOV.UK’s Service Standard is always a good place to start, along with WCAG & COGA.
We recommend mapping standards to checkpoints in your team workflows. This is so they slot more easily into your current ways of working, rather than being treated as an add on at the end of projects.
Building awareness and motivating culture change is essential, but without doing this in parallel with integration into product and customer journey design you won’t have the desired outcomes for your customers.
Build your archetypes
Using guidance from Indi Young, we are always mindful of making our archetypes and personas genderless, ageless, raceless, and classless so as not to encourage any unconscious biases.
As Luke talks about in the video above, archetypes are not to be confused with personas or segmentation. Archetypes represent user expectations and behaviours, and should embody your principles.
Although you may be less familiar with archetypes than with – say – customer demographics or segmentation, they are really effective in building awareness and empathy. It’s crucial to instigating behaviour change.
Write design personas
Personas get a mixed press, we know. Many believe they have run their course of usefulness. But used with intention, we believe they can still add value. Again – read Indi Young’s excellent blog post on this subject to better understand a possible role for personas when it comes to building empathy, without injecting bias.
You can use them to highlight specific needs of fictional characters, increasing understanding of the issue and empathy with a problem. Especially important for colleagues who are far removed from the customers being served. Personas can therefore be used as a tool to bring WCAG & COGA guidelines to life.
Finally, spread inclusive practices
Mindsets and Toolkits amount to nothing if no one knows about them, or how to use them. We’ve listed some techniques we’ve had success with to increase awareness, understanding and engagement with inclusivity.
Begin with an audit
Starting with the most used products and services, we recommend highlighting improvements which can be made across each journey by using your Principles and Standards. These should then feed into new propositions or added to existing backlogs and Jira tickets to improve consistency and accessibility. This could be done by the designers or owners of specific products and journeys.
Update your policies

Yes. It’s not one of the most exciting places to start, but trying to affect change without policy backup is much, much harder. Change happens in the policies.
So create an ethics policy if it doesn’t already exist. This shouldn’t be a hand-wavey document full of nice words; it should be a set of clear, concrete, and measurable tests by which to hold the business to account.
The Specialist Risk Group have some great examples of how you might design and review your policies. At Nile, we focus on making sure that policies which dictate how you do business have – at a minimum – no detrimental impact on vulnerable customers.
While this sounds quite a low bar, our understanding of vulnerability means this includes existing and prospective customers whose ability or circumstances require the business to take extra precautions or actions to make sure they’re not disadvantaged in any way. That’s quite expansive, when then rubber hits the road.
Start a roadshow

With your policies and resources in your pocket, it’s time to be proactive.
Get out on tour. Share your mindset and toolkit with people you think might be fellow champions, or where you could have the biggest impact.
These could be virtual Show & Tells, physical roadshows, or digital assets that people can access on your intranet. Use real world examples from your audit to evidence HOW inclusivity is being embedded.
Some of our clients are doing this by hosting Playback Workshops with their colleagues and sharing their learnings with other organisations at the Vulnerability Academy.
Train your teams
Once people are aware and excited about inclusive practices, it’s time to start helping them learn how to do it. This could be an extension to the presentations and workshops, or integrated with existing training that may exist within your organisation.
Encourage individuals to include this as part of the personal development and training plan. Some of our clients are doing this by offering a combination of face to face and online training on vulnerable customers which will be led by the Money Advice Trust.
Connect a network of champions

When trying to embed cultural change within an organisation you can’t rely on information alone, or process and practices – you need people.
People to champion the work and advocate for it. Find, harness and grow these communities to continue to spread Inclusive Design practices. You won’t be able to do it on your own. Some of our clients are doing this by harnessing their existing Inclusion Network, Vulnerable Customer team, Customer Services team, and individuals within Design and Digital – all great starting points.
Nile is here to help
I hope this has been a helpful read for you.
Please let me know of any tips you have for embedding inclusion in your work, or if you’d like to work with us to explore these challenges together. Feel free to post in the comments, get in touch with the team or contact me directly if you’d like a chat!