The Glasgow Watch Company Ltd (“Glasgow Watch Co”) is committed to identifying, assessing, and managing vulnerable customers in accordance with our own defined objectives and policy, as well as any regulations and guidelines set out by our regulators. We aim to treat all customers, who we define as being vulnerable, in a fair, clear, and respectful manner.
We have implemented several identification and assessment tools within the procedure section of this document, aimed to identify, assess, and deal with all Vulnerable Customer situations and to consistently ensure that our staff are aware of and knowledgeable about Vulnerable Customers, including how to handle certain situations. Our policy content states our intent and obligations with regards to handling customers with vulnerabilities and includes external guidance in our procedures and information as provided by the Money Advice Liaison Group (MALG).
The purpose of this policy and procedure document is to identify and support vulnerable customers and to promote transparency and openness in all the business practices and processes that our staff create and engage in. It also defines the steps to be taken by all staff when dealing with a Vulnerable Customer situation.
Glasgow Watch Co are committed to ensuring that all customers are treated in a fair and consistent manner, but also understand that some circumstances require additional interactions and/or steps to ensure that the customer is getting a product and service that is suitable and ethical.
This policy and procedure document relates to everyone within the organisation and has been created to ensure that we deal with customers in accordance with legal, regulatory, contractual, and business expectations and requirements.
The 2 main definitions of vulnerable customers are:
The FCA defines a Vulnerable Customer as:
“Someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”
The FCA notes four factors that can act as drivers to actual or potential vulnerability. These factors (and the examples provided) are non-exhaustive, but are referenced in this policy as part of our approach to vulnerable customer awareness and communication:
In February 2021, the FCA published further guidance for treating vulnerable customers fairly in their FG21/1 Guidance for Firms on the Fair Treatment of Vulnerable Customers. The regulator noted that protecting vulnerable customers was still one of their key focus areas and the additional guidance aimed to ensure that firms are treating vulnerable customers fairly. Through driving improvements in the way firms treat vulnerable consumers, the FCA wants to bring about a practical shift in the actions and behaviour of regulated firms.
The FCA advised that because anyone can find themselves in vulnerable circumstances at any time, their guidance and rules apply to most firms who should be focusing on four main areas to achieve good outcomes for vulnerable customers:
Vulnerable Customer awareness goes hand in hand with treating customers fairly and ensuring adequate consumer protections. In accordance with the Consumer Duty, Glasgow Watch Co has carried out an assessment of the nature and scale of characteristics of vulnerability that exist in our sector and within the target market we operate in.
Complying with the Consumer Duty requirements mean us going above and beyond considering generic customer vulnerabilities that are person or situation specific and reviewing and monitoring vulnerabilities and characteristics that apply because of our target market. We have developed policies, controls and tools to comply with the Consumer Duty and specifically the requirements contained in PRIN 2A.
Customer interests are considered from product/service design through to after-sales care and everywhere in between.
Glasgow Watch Co follows the guidance for firms on the fair treatment of vulnerable consumers and aims to improve outcomes for customers in vulnerable circumstances. We are committed to ensuring that good outcomes are attainable for all customers, regardless of their circumstances, situations, or vulnerabilities.
In its aim to ensure adequate and fair customer protections, the Consumer Duty requires that the needs of customers in vulnerable circumstances and customers with protected characteristics under the Equality Act 2010 are considered. This includes developing and implementing policies, controls and tools that meet the needs of customers with protected characteristics, as defined by The Equality Act 2010.
Glasgow Watch Co is aware that certain groups of customers may have, or be more likely to have, characteristics of vulnerability. These groups can often share a protected characteristic which could result in vulnerable circumstances. We continuously monitor the outcomes of all customers and review the associated management information on a regular basis.
Where there is a pattern or any evidence that customers that share a protected characteristic are more susceptible to experiencing harm from our products or services, we carry out an assessment and ensure that we are complying with both the Equality Act 2010 and the Consumer Duty.
We aim to:
Glasgow Watch Co’s target market is typically male (70%) and females (30%), aged 25-70, middle- and high-income earners, nationwide.
Glasgow Watch Co have identified the following potential characteristics of vulnerability in the target market.
Glasgow Watch Co has identified and reviewed multiple factors that may pose harm or act as a barrier for vulnerable customers using our services and have developed measures and controls to reduce or eliminate the impact of these.
We have assessed the impact of vulnerability on the needs of our customers by reviewing our target market and existing customer base to identify the types of harm or disadvantage that are relevant to our industry and business activities.
We have reviewed and incorporated the FCA guidance on dealing with vulnerable customers and have used their accurate understanding of the drivers of vulnerability and the impact that being vulnerable can have on a person’s ability to engage in consumer credit.
We recognise that vulnerable customers are more likely to experience certain barriers or issues because of their vulnerability and we continuously work hard to ensure that our products, services and advice are flexible, accessible and inclusive.
In accordance with the FCA guidance, we understand that the below potential harms can be a factor for many vulnerable customers, and we pay specific attention to these areas when dealing with any customer who has been identified as vulnerable or potentially vulnerable.
We recognise that we are often the first contact a vulnerable customer will have and their understanding and ability to handle such situations is essential to achieving good outcomes.
We also recognise that a consumer may find it difficult to make an informed decision about their available options for a variety of reasons. The risk factors that contribute to consumer vulnerability in financial services include:
Living with a disability, illness or diagnosis does not in itself make someone vulnerable. In the context of financial services, it is the person’s situation and barriers to accessing such services that may make them vulnerable. Equally a person may be vulnerable without any disability, illness or diagnosis, for example if they are recently bereaved or frail.
Based on the above factors, we have been able to consider the impact to customers and possible effects and outcomes of these potential harms. This has enabled us to consider the needs of vulnerable customers and to develop effective controls, products and services aimed at making our company approachable, inclusive and accessible.
We ensure that all current staff are provided with the training and tools to identify, understand, and deal with vulnerabilities and vulnerable customers.
Our training programme is provided to all new and temporary staff reminding and updating them on the requirements, guidelines and company ethos of managing Vulnerable Customers.
We recognise that informing, training, and assessing front line staff and those with dedicated vulnerable customer roles is essential in removing barriers and reducing potential harm. We work hard to ensure that our staff have adequate and effective skills and knowledge to help vulnerable customers and to ensure that the right and relevant product, service, or advice is provided every time.
Training is provided through eLearning assessment. Training involves the identification of vulnerable customers as above and correct procedure as outlined below.
Signs we look out for when identifying vulnerability in customers:
Where a customer has been identified and/or declared as being vulnerable, Glasgow Watch Co follows the steps below.
We also use the TEXAS Model outlined by many advocates of vulnerable customers, including MALG and the FCA. This model enables us to train our employees in effective handling of disclosures of vulnerabilities. It helps employees to identify, assess and support vulnerable customers.
The steps of the model include:
Prior to moving ahead with the sale:
After the sale:
We recognise that it is essential to know and understand how to record information relating to vulnerable customers. If a vulnerability or issue is raised, it is imperative that this information is accurately logged, so that all subsequent dealings with the customer have the same approach and continuity of care. We add this information to the customer’s account on our CRM.
All new employees are to be trained on the above during induction and have access to ongoing support where it is needed. We provide all new employees with access to the latest guidance on vulnerabilities and at-risk groups and ensure regular updates are received from such professional bodies or trade.
We also utilise vulnerable customer assessment eLearning to check the understanding, skills and capability of those who deal with vulnerabilities as part of their role. Any new staff will be required to test and verify skills and capability annually. We are responsible for ensuring that all employees have access to resources and publications relevant to vulnerabilities.
We are proactive in ensuring that all customers know how and where to access internal and external support and guidance. Where this applies to vulnerable customers, we actively tell customers where to obtain additional support as relevant to their situation.
If we identify a customer who may need specialist advice which we are unable to offer we will refer them to, or we will seek guidance from an appropriate organisation such as:
Such signposted information is provided:
We recognise that how we communicate with all customers, but especially those who are vulnerable, is essential in ensuring good outcomes. All forms of communication are assessed by Innes Hopkins to ensure that any potential vulnerabilities are taken into consideration.
We provide multiple communication methods and options and do not insist that one way only be used. An example of this is those who are suffering with depression or anxiety often cannot talk on the phone or interact socially, and so insisting on face to face or telephone communication would lead to additional harm to the customer.
We have ensured that all forms and methods of communication and information are presented in a way that is accessible and understandable for all customers. Such methods include (but are not limited to):
Glasgow Watch Co will make reasonable adjustments to its service delivery considering the service scope and the type of services it provides. A reasonable adjustment could consist of any of the following:
All employees will be given extensive training on using our CRM system and understand how to record and log information and how to action any specific system controls to flag vulnerable customers or potential concerns.
In accordance with its customer journey, Glasgow Watch Co anticipates that most of the pre-sale and post-sale customer interactions will be via online, email or telephone.
Where Glasgow Watch Co have a telephony pre-sale conversation with customers, we will seek to understand the customer’s needs and individual circumstances up front to determine whether the credit product is suitable for the customer’s needs. Our rationale for doing so is that customers with apparent or more subtle vulnerabilities are more likely to enter into an unsuitable credit agreement on a poorly informed basis, and therefore we will seek to ensure that the structure of the credit products aligns to the customer’s needs by seeking to understand the same at the start of any telephony sales conversations with customers.
When interacting with customers by email, a different skillset to be attentive to detail is required. Our staff, when reading email communications from customers, must be attentive to read what is being communicated by the customer (i.e., the content) and how it is being communicated (i.e., the manner). The ‘how’ element may indicate characteristics which denote that the customer is vulnerable or may give insight into a driver of a customer’s vulnerability.
Our staff will be observant to establish what a customer’s written communication style says about the customer and whether this can indicate the existence of an indicator of vulnerability. For example, an email communication from a customer littered with significant grammatical and spelling errors may indicate low literacy skills or maybe that the customer is not fluent in English. We will seek to make things as easy as possible for the customer by facilitating contact through a channel that is most suitable for the customer and which they are comfortable using.
Where a customer or third party (e.g., a third party acting under an Ordinary Power of Attorney, Lasting Power of Attorney etc.) makes representations on behalf of a customer, it is likely to be indicative that the customer will have health-related vulnerabilities (i.e., mental capacity limitations). In such circumstances, the Senior Manager will contact the relevant third party to obtain further information about the customer’s circumstances to inform the most appropriate action to take.
Where a customer informally provides consent for a third party to manage their account either by email or via telephone conversation on a recorded line post-sale, staff should reiterate their understanding for absolute that explicit consent is being received from the customer and to ensure both parties are clear on the scope of their consent. as confirmation that a customer is giving explicit consent for a third-party to manage their transaction.
Should a customer who has been identified as vulnerable by Glasgow Watch Co and been flagged to no longer receive any communications due to a third-party making representation on behalf of the customer, we ensure that staff do not describe the customer as vulnerable as this can be extremely offensive for the same bearing in mind that some vulnerable customers may not consider themselves to be vulnerable.
Our goal is to make sure that everyone in our company has the training they need to support customers’ wellbeing. Whether that’s managing difficult conversations or signposting them towards external organisations that can provide extra support, we want to make sure our employees feel empowered, comfortable and confident when helping our customers in vulnerable circumstances.
All members of staff will be provided with vulnerable customer training before being permitted to speak to customer on the phone which includes training of the procedures outlined in this document. Further training will consist of completing courses that focuses on the rules required of a credit broker, one of which the subjects covered is Dealing with Vulnerable Consumers.
Vulnerable Customer Training will be carried out on at least annual basis.
Staff will also be offered practical and emotional support where it is required, particularly if they have handled a particularly distressing call. Support will include allowing time out following a difficult or challenging phone call, time off for staff to share experiences, either face-to-face meetings or remotely and/or the provision of self-help information.
We recognise that any person can become vulnerable at any time and not all vulnerabilities can be categorised or labelled. However, through our research and assessments of publications into vulnerabilities, we have developed and implemented certain measures and controls for vulnerable categories and issues that are more common and identifiable.
Glasgow Watch Co has dedicated procedures in place for dealing with specific vulnerabilities such as financial difficulties and mental health issues.
We have ensured that adequate and effective signposting is available to assist those who require extra help, and we also carry out regular reviews on our written materials and products/services to ensure that they are accessible for all.
We welcome customer feedback and include customer communication in our vulnerable customer training sessions. Feedback and complaints are reviewed regularly to ensure that any issues raised by those considered vulnerable are addressed and revised as soon as possible.
We have ensured that our communication channels and customer service processes encourage customers to share information about their vulnerability and associated needs and we use this information to further develop our existing procedures, controls, materials and products/services.
The Consumer Duty requires us to focus on the needs of customers in vulnerable circumstances and those customers with protected characteristics as defined under the Equality Act 2010. With the aim of ensuring that all customers can expect to receive good outcomes, the Duty requires us to consider the characteristics, situations and circumstances of vulnerable and protected customers and to develop products, services, processes and communication models that meet the needs of all.
The Equality Act 2010 is intended to reduce socio-economic inequalities relating to the discrimination and harassment of any individual based on certain personal characteristics and to prohibit victimisation in certain circumstances. The Equality Act 2010 specifies protected characteristics upon which it is unlawful to discriminate (either directly or indirectly), harass or bully.
These characteristics are:
Glasgow Watch Co already has an effective Equal Opportunities Policy in place which highlights our obligations and policy on complying with The Equality Act 2010 in relation to our employees. The Consumer Duty requires us to go further in our compliance with the Act by also considering the needs of our customers where they are categorised by one or more of the protected characteristics.
We monitor customer outcomes and where available, consider the impact a protected characteristic may have on a customer's vulnerability. We continuously review and improve our products, services and materials to ensure that they are effective and offer flexible options in these areas to meet the needs of vulnerable customers and/or those categorised by one or more protected characteristics.
We carry out regular internal audits and gap analysis monitoring on all business practices and procedures to ensure that our Vulnerable Customers ethos and objectives are being met. These audits include using a Vulnerable Customer Audit Checklist which enables us to assess every policy and procedure area against assessment questions designed to test our Vulnerable Customer processes and regulatory compliance.
Monthly reviews of the audit results are held, and an ongoing record of gaps, actions and improvements are maintained. We will carry out daily call monitoring on all calls to assess against our objectives and standards for dealing with vulnerable customers.
We have several measures and controls for monitoring and assessing our approach to vulnerable customers. These include:
We will ensure that all staff are provided with the time, resources, and support to learn, understand and implement the Vulnerable Customers procedures and associated policy into their business practices. Senior Management is responsible for a top-down approach and in ensuring that all staff are included.
is responsible for Vulnerable Customer audits and gap analysis monitoring and their subsequent reviews and action follow ups. There is a continuous audit trail of all Vulnerable Customer audits and feedback to ensure continuity through each process and task.
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