Business briefing: vulnerable customers

• This is a brief followup to my recent post about vulnerable customers and the FCA’s New Consumer Duty.
• For a deeper dive into this topic, read Louise’s post on Building your inclusive design capability.

I want you to start with a quick mental check on your firm’s approach to serving vulnerable customers right now.

Ask yourself or your leadership the following questions:

• What are the SPECIFIC activities underway which are directly responding to the FCA New Consumer Duty?
• Do you suspect you are falling short of market expectations when serving vulnerable customers? 
• Are your competitors further ahead in building an inclusive design model?

If you’re in a financial services firm and you’re unsure about any of the answers, you should take a hard look at your roadmap for the next year. The FCA’s New Consumer Duty legislation comes into force in July 2023. If you aren’t taking steps to address vulnerable customers now, you’re risking a fine then.

In this short note I’m going to outline what inclusive design is, why it’s relevant, and how to start embedding it across your business.

What is inclusive design?

Inclusive design is a methodology to create products, services and environments which aim to be maximally usable by – and cause no harm to – people, no matter their possible vulnerabilities.

It recognises that ‘accessibility’ is not a tick-box exercise – not something which can be added on at the end, or quickly ‘tested’ pre-launch.

However, until early 2021 there wasn’t a good commercial understanding of what inclusive design means in practice, especially across essential services such as banking and insurance.

So this is where we need to think about vulnerabilities. Inclusive design us all about designing for vulnerability; meeting people where they are and catering for their differences in background, ability, age, economic situation, geographic location, language, race, or personal context. Understanding you customers’ vulnerabilities is important if you’re going to integrate inclusive design methods across your business.

Why is it relevant?

The FCA itself writes:

“Firms may wish to consider taking an inclusive design approach to meet the needs of customers in their target market, including those with characteristics of vulnerability.”

Section 6.31 – FG22/5 Final non-Handbook Guidance for firms on the Consumer Duty

In early 2021 the Financial Conduct Authority (FCA) introduced guidelines around the fair treatment of vulnerable customers embedded as part of a healthy culture throughout businesses.

In these guidelines, 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.

The four drivers make it easy to recognise the breadth of possible vulnerabilities, many of which we might recognise as having experienced ourselves.  Vulnerability is broad, transient, and situational. When it comes down to it, anyone can be vulnerable at any time.

Again, this is the crux of Inclusive design; designing for all. Being fully human-centred and learning to leave our subconscious biases and stereotypes at the door.

Where do you start?

If you’re in a financial services firm and you’re unsure about any of the answers, you should take a hard look at your roadmap for the next year. The FCA’s New Consumer Duty legislation comes into force in July 2023. If you aren’t taking steps to address vulnerable customers now, you’re risking a fine then.

But don’t worry – you can begin making progress today. There are many first steps you can take, depending on your organisation maturity level, available resources, and whether you have a clear definition of what inclusive means in your business. 

Based on some recent projects, Louise – one of our senior service designers – has collated a useful introduction to building your inclusive design practice.

Nile is here to help

With the FCA clock ticking this could feel like an intimidating challenge. But I urge you not to bury your head in the sand about this.

Nile has been working in the field of inclusive design since 2006. We started by running accessibility testing and audits on websites and nascent digital banking services. 

Our practice has evolved and deepened over the last 16 years. This year in particular, the Nile team are focusing on supporting our clients to develop their understanding of vulnerable customers, and build and embed sustainable inclusive design practices.

If you’d like to talk this over, I want you to get in touch with me or our friendly client partner team. We’re always available to talk and help you make sense of things.