Vulnerable Consumer Policy

1.0 Introduction

Ensuring that customers in vulnerable circumstances are treated not only fairly, but with empathy and sensitivity to their circumstances is a growing priority for the Financial Conduct Authority and other regulators. Vulnerable clients are likely to need additional assistance at some stage in order to avoid detriment (financial or psychological) when attempting to arrange appointments, discussing treatment plans, undergoing treatment, making payments or arranging payment plans.

The purpose of this policy is to ensure that the way in which we conduct our business does not have a negative impact on vulnerable customers.

A vulnerable consumer is defined as someone who has personal circumstances that place them at a higher risk of detriment, particularly if a company does not act with the appropriate level of care.

Dental Care @ 62 is committed to ensuring that all its staff can identify vulnerable consumers, and that they are able to handle a situation involving a vulnerable customer with the required levels of care, attention and respect. 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:

• low literacy, numeracy and financial capability skills
• physical disability
• severe or long-term illness
• mental health problems including common mental disorders (CMD)
• low income and/or debt
• caring responsibilities (including operating a power of attorney)
• being ‘older old’ for example over 80, although this is not absolute (may be associated with cognitive or dexterity impairment, sensory impairments such as hearing or sight, onset of ill-health, not being comfortable with new technology)
• being young (associated with less experience)
• change in circumstances (e.g. job loss, bereavement, divorce)
• lack of English language skills
• non-standard requirements or credit history (e.g., armed forces personnel returning from abroad, ex-offenders; care-home leavers, recent immigrants).

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.