| File Reference : | GG-1-17 Consumer Vulnerability |
| Date File Updated | 07-10-26 |
| Category | General Guidance | Tags: ISO 9001, |
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This guidance helps staff identify and respond to consumer vulnerability, with risk factors, a table of triggers, the BRUCE tool and example questions that avoid intrusive questioning.
This guidance document is supplied in fully editable MS Word format and can be easily customised and edited. The document uses pre-defined style formatting throughout, with all text in Calibri font for improved readability.
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Further guidance on consumer vulnerability and ISO 22458:
These files are included in the alphaZ subscription. The guidance is also included in the ISO 22458 Toolkit and the integrated toolkits that include it.
If you'd like hands-on help putting your consumer vulnerability procedure and records in place, our remote support services provide direct expert input from our team, by the day, by project, or on an ongoing basis.
Consumer Vulnerability Guidance
A general guidance document on consumer vulnerability for everyone who deals with consumers, including sales agents. It explains what a vulnerable consumer is, how to identify vulnerability through risk factors, triggers and the BRUCE tool, how to find out a consumer's needs without intrusive questioning, and how to handle records, cancellations and complaints.
Topics Covered
- What is a vulnerable consumer - someone especially likely to suffer harm in dealings with a service provider, because of personal, situational and market factors
- Risk factors and triggers - common risk factors such as age, bereavement or caring responsibilities, and a table of triggers, possible causes and solutions
- The BRUCE tool - checking behaviour, remembering, understanding, communication and evaluation to help identify a consumer who may be vulnerable
- Identifying individual needs - finding out a consumer's needs and preferences without intrusive questioning, with example questions and how to collect information sensitively
- Alternative arrangements and records - providing arrangements you are authorised to give, raising others with a manager, and recording vulnerability information with consent
- Third parties and sales agents - confirming a representative's authority, and checking a consumer can take responsibility for a contract and understands its terms
- Cancelling, withdrawing and unavailable services - accepting cancellations in any format, several contact attempts before withdrawal, flexible repayment terms and updates during service problems
- Complaints, data and legal requirements - the complaints process in the code of conduct, confidential handling of consumer data and awareness of the legal requirements
Who Is It For?
Everyone who deals with consumers, including sales agents, and the supervisors and line managers who review requests for alternative arrangements.
Included in the ISO 22458 Toolkit
This guidance is supplied with the TT-1-17 Consumer Vulnerability training talk, which is part of the ISO 22458 Toolkit and the integrated toolkits that include it.
Using the Guidance
Issue it at induction to anyone who deals with consumers, and keep it as a reference alongside the vulnerable consumer code of conduct and procedure. Record who has received it, for example on the training matrix.
Triggers, Causes and Solutions
A table sets out common triggers, what might lie behind them and practical responses. A consumer who says they cannot pay might be offered reduced payments for a short period or a payment holiday. Someone who cannot read a bill can have it explained by phone or sent in the format they ask for, and someone worried about the time a call takes can be offered a call back.
Adapting the Guidance
Edit the guidance to match your own arrangements - the names of your code of conduct and vulnerable consumer procedure, who reviews requests for alternative arrangements, and the payment, cancellation and complaints options you offer.
Related Documents
Other documents that work alongside this guidance:
- CC-CV1 Code of Conduct Vulnerable Consumers
- PP-1-17 Consumer Vulnerability Policy Procedure
- P-115 Consumer Vulnerability Policy
- F-Q102 Vulnerable Consumer Report
- F-IMS58 Vulnerability Risks Register
- GG-1-16 Data Protection
- ISO 22458:2022 Awareness Training Course
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- GG-1-17 Consumer Vulnerability Word, 49 KB


