Staff within an organisation creating a sound vulnerable customer management system such as BS18477 need to consider carefully how records are managed and maintained.

Adequate staff training is needed to ensure that vulnerable customers have their records clearly marked with any salient risk factor that is detected, that could affect service provision further down the line.

Such information should be carefully stored with the consent of the customer and of course in alignment with GDPR.

This data should be made available to staff who might deal with future customers with vulnerabilities that have been recorded. Once identified it is prudent for adequate alerts to be made to ensure that service provision offered is suitable further down the line.

Often customer records in large sales orientated organisations just hold data on the potential sales opportunities and not issues or ‘red-flag’ concerns relating to vulnerability.

The business should establish internal policies and procedures for the collection, access, update, retention, and disposition of key records although this is likely to be in place to address GDPR Article 30. 

Care should be given to only obtain the appropriate amount of information from a vulnerable customer and not excessive or irrelevant amounts of data.

In addition, the organisation must have robust procedures for dealing with third parties who may be acting on the behalf of the vulnerable customer.

Again, the author advocates that the organisation performs a culture assessment to define the driving forces within the business. 

For further information and to book your BS18477 – Inclusive Service Provision 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.