In the year that has passed since the FCA’s first consultation on vulnerable customers, the emergence of a global pandemic, along with the social and economic disruption left in its wake, has ensured vulnerability is now on the corporate agenda for financial services institutions. The stakes are high: beyond the regulatory and social imperative, banks and insurers risk reputational, customer and financial losses if their vulnerable customers are ignored or mistreated. Marketforce, Smart Communications and Pegasystems brought together a panel of senior figures from across the financial services sector to discuss the increased awareness of vulnerability and the strategies, processes and technologies needed to deliver solutions that are appropriate, empathetic and work for everyone.
Tony Tarquini, Director of Insurance at Pegasystems, highlighted that almost 100 per cent of organisations surveyed recently were increasing their investment in this area, with 44 per cent committing very significant amounts. “And when we looked at the motivations, regulatory pressure was way down the list,” he said. “Customer engagement, reputation and social pressure were the main drivers.”
“Organisations are making these investments because it’s the right thing to do.” However, Tarquini pointed out that investment in capabilities to serve vulnerable customers can also be used to provide better service and deliver fairer outcomes for all customers.
“Are we focusing too much on identifying the vulnerable rather than spending time on understanding the underlying need?”
Laura Tough, Head of Member Vulnerability, access and inclusion at Nationwide Building Society, echoed this. She gave a thought-provoking presentation to kick-off the roundtable, which opened with the provocative question: “Are we focusing too much on identifying the vulnerable rather than spending time on understanding the underlying need?”
She pointed out that advanced analytics and AI make it increasingly possible to crunch through huge amounts of data and delve into the minutiae of a customer’s life, whether it’s potentially reckless spending habits or someone regularly attending the cancer unit and browsing cancer charity websites.
“Do you reach out and offer proactive support?” she asked. “There are so many variables in each individual’s circumstances that it can be a minefield and lead to really poor customer experience. Or it can be a false positive or something the customer really doesn’t want us to know about them.”
“You have to have a very high degree of confidence in your data and have to have a licence to engage so that you don’t overstep that privacy boundary”
“You have to have a very high degree of confidence in your data and have to have a licence to engage so that you don’t overstep that privacy boundary,” stressed Tough.
However, Chris Childs, Enterprise Account Director EMEA, Smart Communications, said it was possible to do both. “Outreach can be both targeted – and broad-based enough to remain sensitive, so that you reach out to those that exhibit behaviours associated with key areas of vulnerability,” he said. “Doing so in a way that outlines your programs as a value-added service of doing business with the bank can keep it from crossing the privacy line and ensure people experiencing these issues know you are there to support them.”
Laura Tough said the best approach is to understand needs and how they might be met. “That means designing inclusively,” she said.
“Designing well is for everybody and reduces the risk and potential cost to the firm and mitigates the risk of detriment to those with additional needs.”
Our participants agreed that “designing well” means communications must be clear, simple and accessible for everyone. There should be a choice of channel – not all vulnerable customers want face-to-face support, with some welcoming webchat to discuss difficult financial circumstances while for others this extension of another synchronous channel will be a drag on their busy lives. Terms and conditions should be sufficiently flexible to accommodate change in circumstances after point of sale. Customer facing staff need to be trained and know what they can do to help someone who is vulnerable, rather than just handing them off to a vulnerability specialist.
“It’s not about filtering vulnerable customers own a special pathway,” said Tough. “Designing well is for everybody and reduces the risk and potential cost to the firm and mitigates the risk of detriment to those with additional needs.”
“One harm could come from five or six different types of vulnerability so I would rather teach people about the harm and focus on how we can mitigate that.”
It was a message that certainly resonated with many on the participants. “We have spent many years training our people to identify different types of vulnerability but really we should be focusing on the harm that vulnerability can cause,” said one participant “One harm could come from five or six different types of vulnerability so I would rather teach people about the harm and focus on how we can mitigate that. It means we have to pivot systems and support to sit around that.”
Our participants agreed that rather than trying to identify vulnerabilities, it was better to make it as easy as possible for customers to share their vulnerabilities in an empathetic and unintrusive way, whether that’s online, via the phone or face to face. “The more people realise we can do practical things to help them, the more they will come and tell us what’s going on and what support they need,” said one.
“Vulnerability isn’t set in stone…vulnerable isn’t a homogenous group of people”
It was clear that the participants felt the nature of vulnerability was changing. The pandemic has thrown huge numbers of customers into potentially vulnerable categories, with many facing financial distress for the first time and others battling mental health, physical health and bereavement issues as a result of the crisis. “Vulnerability isn’t set in stone,” said one participant. “People come and go. For some it’s transient; for others, it’s longer term.”
“It’s important to remember that vulnerable isn’t a homogenous group of people,” said another. “It’s very varied and diverse.” This diversity can be challenging for organisations trying to craft support and solutions.
“Some people may not feel they are vulnerable and they just want to have relevant products and services that meet their needs,” said one participant. “People don’t want to feel singled out or judged. How can we use our data to surface relevant information and channel that in a sensitive way to customers?”
Staff training and support has become a key issue for many organisations. The strains and stresses created by the pandemic are taking a toll on customers, and frontline staff are facing the fall-out. “People are more argumentative and more belligerent,” said one participant. “Things are ramping up and we’ve had some awful situations where customers are threatening to kill themselves. It’s very distressing for our staff, many of whom are very young and don’t have the life experience to deal with some of these extreme situations.”
Others agreed, noting there has been an increase in verbal abuse during the pandemic, both for contact centre staff and those in branches, some of whom even face physical abuse. All agreed the situation is expected to worsen in 2021 as job losses continue to mount and mortgage relief come to an end.
For frontline staff, the daily exposure to these levels of distress can be very damaging. “Their level of resilience has plummeted because of the stress,” said one participant. “Our distribution leaders are really focused on supporting the morale of frontline staff, who are dreading coming into work yet we are asking them to be more patient, calm and empathetic than ever.”
With many contact staff now working from home, it’s harder for organisations to deliver the support. “Before we would have team huddles and time-outs after difficult calls and we’re trying to find ways to keep that going while they are working from home,” said one participant. “We have a red flag process so they can get their manager to come and support them as if in a call centre, using call listening to get that real-time support and back up.”
Chris Childs of Smart Communications said technology can help by giving staff tools to anticipate difficult calls and adjust their response accordingly. “Data to identify behaviour associated with vulnerability prior to the interaction can help them manage the situation with the greatest level of care,” said Childs. “Tips and details on programs immediately surfaced in their workstations can help them respond quickly, craft the appropriate messages and provide the customer with resources for support, all helping the agent to be better prepared for this difficult task.”
Organisations are training mental health champions and empowering staff so they can do more to help customers. This gives staff some control and a feeling they are making things better, whilst also having the back-up of handing off to someone with the skills and authority to take it further if required.
“Sometimes we have to fulfil our duty to the customer, which is to let them spend their money the way they want to. It’s a very difficult area.”
Our particpants also discussed the limits of what they can do. Whilst friction can be added to journeys to help prevent fraud and scams, customers do have agency to make decisions about their own lives and have clearly defined privacy rights. “It can be very difficult for frontline staff when they can see someone is extremely vulnerable, who is spending recklessly or giving their benefits away to someone they’ve just met in the street,” said one banking executive. “The temptation is to step in and overrule the customer but, while it may be unpalatable, sometimes we have to fulfil our duty to the customer, which is to let them spend their money the way they want to. It’s a very difficult area.”
It was a thought-provoking and important discussion, and one that will certainly need revisiting as the pandemic and its fallout continues to impact customers.
Smart Communications is a leading technology company focused on helping businesses engage in more meaningful customer conversations. Its Conversation Cloud™ platform uniquely delivers personalized, omnichannel conversations across the entire customer experience, empowering companies to succeed in today’s digital-focused, customer-driven world while also simplifying processes and operating more efficiently. Smart Communications is headquartered in the UK and serves more than 650 customers from offices located across North America, Europe, and Asia Pacific. Smart Communications’ Conversation Cloud platform includes the enterprise-scale customer communications management (CCM) power of SmartCOMM™, forms transformation capabilities made possible by SmartIQ™ and the trade documentation expertise of SmartDX™. In 2021, the company acquired Assentis, a leading European software solutions provider specializing in customer communications management (CCM) with a focus on the financial services industry.
To learn more, visit smartcommunications.com.
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