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Ofcom sets out vulnerable customer guidance

July 23, 2020

By Colin Mann

People suffering financial, health or emotional problems should be treated fairly and given the right support by phone, broadband and pay-TV providers, under best practice industry guidance issued by UK comms regulator Ofcom.

The coronavirus pandemic has increased the potential for customers’ circumstances to change suddenly and providers are already offering additional support to people who are struggling to pay their bills to help them to stay connected.

But anybody can face circumstances that make them vulnerable – either temporarily or permanently. These might include physical or mental health problems, debt or unemployment, bereavement or becoming a victim of crime.

Ofcom figures suggest that 14.1 million people have a disability, that 2.5 million people are living with cancer, almost 1 million people are affected by dementia, one in six adults experience common mental health problem every week and 318 people are declared bankrupt or insolvent every day.

Ofcom’s job is to make sure that, whatever a person’s vulnerability, communications providers offer a high level of customer care, and the services and support people need.

Ofcom requires providers to have policies and procedures in place to make sure that vulnerable customers are fairly treated, and accordingly it is setting out the practical measures that providers could adopt, in light of these rules.

“We’re setting out industry best practice to help ensure vulnerable people are treated fairly and sympathetically by their phone, broadband and pay-TV providers,” explained Jane Rumble, Director of Consumer Policy at Ofcom. “This is especially important at a time when many customers may be worried about their physical and mental health, as well as their finances.”

What providers can do:

  • Plan for treating vulnerable customers fairly. Companies must publish clear, up-to-date policies which are easy to understand. These should be led from the top, with senior leaders accountable for embedding them in their organisation’s culture. Ofcom recommends that providers consult with experts, consumer bodies and charities to strengthen their understanding of different vulnerable customers’ needs.
  • Identify and communicate with vulnerable customers. Customers may be more willing to share information about their vulnerability if they know they can get extra support from their provider by doing so. Providers should therefore ask customers at the earliest opportunity whether they have any accessibility or customer service needs that the provider can help with, and offer a range of ways to explain the help, support and services available – such as online forms, phone, post, email, web chat or video and text relay.
  • Keep information about vulnerable customers’ needs. Frontline staff should accurately record and update customers’ needs in line with data protection legislation. This should be shared with other frontline staff on controlled internal systems, to avoid customers having to repeat themselves if passed to another department.
  • Train staff appropriately. All frontline staff should be trained on how to communicate with empathy and support, recognising that some vulnerable people may be reluctant to discuss their personal circumstances. They should be trained to recognise the potential characteristics, behaviours or verbal cues of someone who might be vulnerable and also be fully aware of the additional services available to help them. Specialist teams who primarily deal with vulnerable customers, including those in financial difficulty, may benefit from additional training.
  • Monitor and evaluate. Providers should regularly monitor changes in complaints levels, customer service survey results or other customer feedback. They should also consider mystery shopping, as well as focus groups and panels to gain feedback and share best practice.

Best practice examples suggesting how customers should be treated

People who are behind on their bills

Ofcom would expect providers to:

  • prevent customers from being disconnected wherever possible, allowing the customer time to get help and support, without the threat of enforcement action during that period;
  • offer payment holidays or deferrals, or freeze additional fees and charges;
  • discuss a realistic, reasonable and flexible repayment plan;
  • offer tariff advice, whether switching to a cheaper tariff or social tariff;
  • refer customers to debt organisations or charities that can provide free advice and support; and
  • use a range of communications channels to get in touch with the customer.

Victims of crime

  • make sure victims don’t pay for mobile phone services they have been unable to use if their phone is taken away by the police as evidence;
  • listen carefully with empathy and compassion, taking time to ensure the customer has the right information, which might include a crime reference number;
  • avoid pressuring victims to provide any more information than necessary, to avoid them reliving experiences;
  • and offer new numbers, temporary SIMs or handsets where appropriate.

Next steps

The measures set out in Ofcom’s guidance are not intended to be exhaustive. Ofcom will work with providers and review the guidance over time. it will also monitor companies’ performance – including against its Fairness for Customers Commitments, which are designed to strengthen how companies treat their customers.

Ed Dodman, director of regulatory affairs at telecoms sector complaints handling body Ombudsman Services, welcomed publication of the guidance, suggesting it gives telecoms providers a clear framework for ensuring vulnerable customers are treated fairly and get the support they need. “We are particularly pleased to see Ofcom encouraging companies to use complaints data as a way of informing their approach to vulnerability. Many of the themes included in the regulator’s new guidance have been discussed in the vulnerability workshops that we have been holding for telecoms providers over the past couple of years.”

“We know from these sessions that there is a commitment amongst providers to do the right thing by vulnerable customers. Today’s announcement will help to ensure a consistent approach across the sector to the challenging issue of vulnerability,” he concluded.

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