Organisations that are regulated need to address consumer vulnerability. This is not just to meet the supervisory requirements but makes good business sense.
The first place to start is with the corporate risk register. Most organisations will hold a risk register with a ‘RAG’ approach. Such registers may identify external and internal corporate risks.
Vulnerability needs adding to this register, with the executive board agreeing the importance to the business.
In the present climate the author believes that this risk register should be frequently updated to reflect potential shifts in vulnerability as the UK exits slowly from ‘lockdown’ with the attendant issues that will surely follow.
So, what risks should be considered? The following are normal and are detailed within BS18477. Issues such as: job security, recent redundancy, basic skills set, age, disability, mental health, sudden change in circumstances, bereavement, illness, and new caring responsibilities.
New risks might include extended furloughing where consumers may feel safeguarded but the actual circumstance at the end of such a protracted leave of work – may be very different.
The executive team should monitor closely the external risks and update the register with regards consumer vulnerability. This would determine the red flag indicators that must be addressed within the business.
At this stage, the executives can design and develop appropriate products and solutions to address the risks identified. Such a structured approach will help all stakeholders in the long run and demonstrate that a proactive approach has been adopted to assist vulnerable consumers.
BS18477 – Inclusive Service Provision is an ideal Standard with external certification from BSI. The author assists organisations seeking such registrations.
For further information and to book your BS18477 survey please contact: Marcus J Allen at Thamer James Ltd. Email: [email protected]
Marcus has twenty years’ experience in delivering Governance, Risk and Compliance solutions to over two hundred organisations within the UK. Marcus holds the respected Diploma in Governance, Risk and Compliance from the International Compliance Association and holds a master’s degree in Management Learning & Change from the University of Bristol.