Consumer vulnerability can arise from many differing circumstances, not just issues that individual consumers face but often problems that the organisation has created itself.

Consumers can become confused and bewildered with bundles of offers and terms and conditions in vague language that don’t clearly define the characteristics of the service or product offering. Or at worst are misleading.

Sales agreements and brochures should be written in clear terms that can be understood with ease by the intended audience.

If such documentation is not prepared with clarity or ease of understanding this could put consumers at a disadvantage. Indeed, within the regulatory arena this could be an issue with regards TCF (Treating customers fairly). 

Vulnerability issues may also be increased if a consumer must make an important or rapid decision. Particularly if the outcome has significant potential impacts upon their finances or indeed health.

A good area to consider the issues of ‘complexity and confusion’ with regards product / service offerings is at the ‘design and development’ stage of a CVMS (Consumer vulnerability management system). The design of a new solution should start with the basic intended outcomes of the offering and be built around the intended consumer needs. 

What should not happen is the deployment of a standard sales channel that fails to recognise the complexity of contract / service terms aligned with the solution. Good service design is discussed within BS 18477 and indeed under the FCA’s design and development of new products.

By adopting TCF principles at the early stages of a product life cycle – complexity and confusion and the potential for mis selling can be reduced.

For further information and to book your BS18477 survey please contact: Marcus J Allen at Thamer James Ltd. Email: marcus@thamerjames.co.uk

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.