The legal stuff

Vulnerable Customer Policy

Our Commitment to Vulnerable Customers – The Financial Conduct Authority (FCA) requires all firms within financial services to recognise and understand the impact that life events, health, resilience, and financial capability may have on their customer’s needs. At ANNA, we’re committed to making sure that all customers, including vulnerable customers, are treated fairly and have equal access to ANNA’s products and services.
Vulnerable Customer Policy – That’s why we’ve implemented a Vulnerable Customer policy within our business. This policy sets out our expectations when dealing with vulnerable customers.
Colleague training – Our employees are trained to identify vulnerable customers and provide the additional support they may require to meet their needs and achieve positive outcomes. We also acknowledge that vulnerability can take many forms, and is specific to each individual customer.
To register as a vulnerable customer, please contact us via email:
1. Introduction
  1. Absolutely No Nonsense Admin Ltd (“ANNA”) is committed to ensuring that all customers, including vulnerable customers, are treated fairly, and have equal access to ANNA’s products and services.

    ANNA must operate appropriate processes that consider the circumstances of individuals (and small and medium enterprises) and be able to identify whether they are vulnerable or susceptible to a detriment (whether permanently or temporarily) and tailor the way in which we communicate and deal with them to take account of the vulnerability.

    If you feel that you may be in a position of vulnerability, please contact ANNA’s Customer Experience Team in-app or email:

    Objectives of this policy

    The main objective of this policy is to set out ANNA’s approach when dealing with vulnerable customers to ensure that we deliver fair customer outcomes.

    The policy also aims to achieve the following:
  1. To define the different types of vulnerability and susceptibility
  2. To outline how ANNA approaches the identification, recording, and management of vulnerable customers
2. Definition of vulnerable customer
  1. The FCA’s definition of a vulnerable customer;

    Is “someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care”

    The FCA considers that the following factors act as drivers to actual or potential vulnerability:
  1. Health – health conditions or illnesses that affect the ability to carry out day to day tasks, both permanently and on a temporary basis
  2. Life events – major life events such as bereavement or relationship breakdown
  3. Resilience – low ability to withstand financial or emotional shocks
  4. Capability – low knowledge of financial matters or low confidence in managing money
  1. An individual may suffer from one or more of these types of vulnerability at the same time, which may make them especially susceptible to harm.
3. Applicable Regulation and Legislation
  1. Vulnerability is a key priority for the FCA, and it expects firms to exercise extra care when customers may be vulnerable because where vulnerable customers are not treated fairly, their circumstances often mean they face an increased risk of harm.

    The FCA expects firms to have policies and procedures in place to deal with customers who may be at greater risk and to take into account the potential negative impact on vulnerable customers in product availability, product design, distribution channels and post-sales servicing of ANNA’s products and services.

    One of the FCA’s operational objectives is to secure an appropriate degree of protection for customers. The FCA would be more likely to intervene where they identify actual or potential harm for vulnerable customers

    In meeting this objective, the FCA must have regard to the general principle that customers should take responsibility for their choices and decisions. However, there can be factors that may limit the ability of vulnerable customers to take on this responsibility. This risk is further supported by the recent introduction of the ‘customer best interest rule’ which requires Firms to act in the best interests of their customers, considering the capabilities of the customer, their current and future needs and the appropriate support required to prevent any potential or actual vulnerability being perpetuated or worsened by colleagues’ actions, inaction or ANNA process.

    The FCA also has regard to the general principle that financial services firms should be expected to provide customers with a level of care that is appropriate, having regard, amongst other things, to the capabilities of the customers in question. The level of care appropriate for vulnerable customers may therefore be different from what is required for other customers. The FCA will take action against firms that do not afford appropriate processes and procedures for vulnerable customers, whether intentionally or not.

    The FCA’s Principles for Businesses underpins the fair treatment of vulnerable customers:
  1. Principle 2: Skill, care and diligence. A firm must conduct its business with due skill, care and diligence.
  2. Principle 3: Management and control A firm must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems.
  3. Principle 6: Customers’ interests. Firms need to understand the needs of vulnerable customers to pay due regard to their interests and treat them fairly.
  4. Principle 7: Communications with clients. A firm must pay due regard to the information needs of its clients and communicate information to them in a way which is clear, fair and not misleading.
  5. Principle 9: Customers: relationships of trust. A firm must take reasonable care to ensure the suitability of its advice and discretionary decisions for any customer who is entitled to rely upon its judgement.
  6. This Policy acts in accordance with the Equality Act 2010, which provides it is illegal to discriminate and strengthens protection for specific protected characteristics. This means when a customer who has a disability is identified through ANNA’s operational processes or service, reasonable steps must be taken to ensure they are treated equally, fairly and with respect.
  7. ANNA also acts in accordance with the requirements of the General Data Protection Regulation (GDPR). In practice, this means that ANNA colleagues are required to obtain explicit consent from the customer regarding the recording of information, including both medical data (the vulnerability) and the duration of any vulnerability, for example, whether the vulnerability is thought to be temporary or permanent. Colleagues are expected to ensure the recording of a vulnerability is accurate and reflective of the customer’s most recent circumstances.
  8. ANNA colleagues can record the interventions or adjustments requested by a customer rather than the vulnerability itself, in these instances, ANNA colleagues are still required to obtain the customer’s consent before making a record.
  1. An individual may suffer from one or more of these types of vulnerability at the same time, which may make them especially susceptible to harm.
4. ANNA’s approach to vulnerable customers
  1. ANNA has different approaches to ensuring that vulnerable customers are identified and handled appropriately and this section details ANNA’s approach to identifying vulnerable customers and the processes and controls that it has in place to protect customers throughout the lifecycle of their account.
5. Expectation of ANNA colleagues
  1. The FCA expects firms to be able to spot a vulnerable customer should they provide personal details during a call or in customer correspondence and respond appropriately to this information.
  2. Relevant ANNA colleagues receive training for communicating with vulnerable customers to ensure they are empowered and trusted to be alert to the signs that the person they are talking to may not have the capacity, at that moment in time, to make a decision or provide the correct information. As such, relevant ANNA colleagues are expected to be able to confidently and competently effectively identify the customers’ needs and adjust their approach accordingly.
  3. It is acknowledged that vulnerability can take various forms. The following are types of possible circumstances and characteristics which may suggest vulnerability. This is not an exhaustive list and is used as guidance only. The identification of vulnerable customers must be individual, proactive, and aimed at removing barriers to accessing our products and services, to result in both a good and fair customer outcome.
Low literacy and/or numeracy abilityCommunication challengesPhysical disability, visual impairment, hearing impairment health or illness that affects the carrying out of day-to-day tasksDementia/mental capacity limitations
Domestic abuse including economic controllow income and/or debt, including outgoings exceeding income and erratic incomeMedical / Health conditionNo, or low access to help and support
Addictions (Gambling, drinks, drugs)Advanced age (this can be associated with the onset of ill health, a deterioration in hearing and/or sight, a weakening in cognitive ability or reduced dexterity or not being comfortable with new technology)Inability or lack of confidence using technologyEnvironmental (such as floods, subsidence or any other matter relating to a claim or complaint)
  1. In order to act in accordance with the requirements of this Policy, ANNA colleagues are expected to:
  1. Be alert and ensure they listen to what the customer is saying or writing, and look out for triggers or clues to vulnerability
  2. Take time to understand the reasons behind any difficulties the customer may be facing, such as job loss, illness, divorce, or learning difficulties as this will help colleagues to understand what the best option or outcome for the customer is
  3. Set expectations clearly – whether this be over the duration of the process, or the service, it is useful to set expectations at the earliest possible stage
  4. Apply discretion or adapt the existing process where appropriate
  5. Communicate very clearly and if required slow down and be patient and empathetic. Be prepared to repeat or allow time for the person to make notes or agree to confirm in writing
  6. Clarify understanding at trigger points by asking questions such as ‘is there anything else you would like me to repeat or explain?’
  7. Ensure there are no barriers to the appropriate and fair treatment of a customer, including barriers to support throughout the product lifecycle
  8. Where vulnerability is identified, this will be recorded accurately, sensitively and regularly reviewed for relevance
6. Controls and Adherence
  1. The Vulnerable Customer Policy will be clearly signposted on the intranet and accessible by all colleagues
  2. ANNA designated business leaders are individually responsible for the processes and procedures regarding vulnerable customers in their respective business areas
  3. Compliance undertakes regular horizon scanning to mitigate future issues and concerns by anticipating potential risks that may emerge and monitoring regulatory developments, sharing regular updates with key ANNA stakeholders
  4. ANNA’s recording of sensitive personal data meets General Data Protection Regulation (GDPR) requirements, regarding each vulnerable customer record and additional support measures. Customer policy records can be maintained for a minimum of 7 years in accordance with the Data Classification and Data Retention Policy
7. Training
  1. Regular assessment of internal activities: assessment considering regulatory requirements, conduct risks and alignment to industry standards. Independent assessment of risk management, controls, and processes.
  2. Head of Operational Excellence - Internal Audit
  3. ANNA provides annual mandatory e-learning training for colleagues, one of which is a module on vulnerable customers that all colleagues must complete and pass each year. ANNA colleagues performing roles within the Complaints and Customer Experience Team are required to undertake further detailed training in respect of vulnerable customers.
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