Protecting the most vulnerable people in society falls not just to government but to the organizations and businesses they need to interact with.  

Have you ever tried switching bank accounts online, only to end up feeling confused by the technology? If so, you have been a vulnerable consumer. Consumer vulnerability is fluid and dynamic and we move in and out of periods of being vulnerable. Our personal circumstances, such as going through a bereavement, a divorce or a period of ill health, can make us more fragile at certain times in our life.

In the business world, consumer vulnerability refers to any situation in which an individual may be unable to engage fully or effectively in a market. This may result in an increased risk of being exploited by unscrupulous organizations or not getting a fair deal. It’s important for businesses to assist vulnerable consumers so they can get the goods, services and support suitable for their needs. 

A more inclusive approach to designing products and services guarantees they are accessible to, and usable by, as many consumers as possible. Yet inclusive design isn’t always well understood and organizations are often unsure where to start. Complaints management expert Michael Hill explains how standards can ensure everyone gets a fair deal. 

What exactly is a vulnerable consumer?
Vulnerability may be a temporal state. A consumer may be vulnerable when dealing with an organization due to the presence of personal, situational or even external conditions. These may include organizational behaviour, market environment, or crises such as the COVID-19 pandemic or extreme weather conditions. 

A consumer in a vulnerable situation may be at risk of harm from their dealings with an organization. This may of course be unintentional. For example, a customer experiencing bereavement is more likely to suffer from anxiety and stress if an organization makes it difficult to complain about the inflexible systems used when interacting with the organization. To help address the situation, a new standard – ISO 22458 – encourages organizations to consider consumer vulnerability when designing inclusive services rather than categorizing specific consumers as vulnerable.

When are consumers most vulnerable?
Most of us find ourselves in a vulnerable situation at some time in our lives. Vulnerability can be temporary, sporadic or even permanent, such as long-term health conditions. But a vulnerability may also change over time and can be unpredictable. Therefore, organizations should recognize that unusual behaviours when consumers interact with the organization (or a failure to interact) need to be understood and acted upon. For example, failure to reply to correspondence, avoiding contact or unexpected missed payments are all behaviours that may need to be explored further. Organizations need to make sure that staff are appropriately trained and supported to ask the right questions and identify how they might best help or advise consumers. 
What would be your top tips for organizations to design inclusive service?

Providing fair, flexible and inclusive services is important to help meet the needs of all consumers more effectively. Yet it’s often tough to know where to start. As Chair of the working group that developed the standards, I would recommend five tips for organizations to follow:

1. Be aware of the issues around consumer vulnerability

Conduct some research to gain an understanding of vulnerable consumers. This could be by exploring existing data such as surveys and complaints, talking to consumers about their lived experiences of vulnerability or working in partnership with stakeholder groups such as specialist charities and consumer advice agencies. The aim should be to better understand the nature and scale of vulnerability characteristics present in your potential and existing customer base, as well as the impact of vulnerability and how this can affect the consumer experience, needs and outcomes.

2. Support your staff 

Rigid, inflexible rules and time limits imposed on conversations with customers too often prevent staff from doing the right thing for the consumers they serve. Organizations should ensure frontline staff are appropriately empowered and supported, particularly in being able to act flexibly in helping and supporting consumers. Depending on the size of the organization and the nature of the services provided, a specialist consumer vulnerability team can provide ongoing advice for those consumers requiring extra care and assist staff on the frontline.

3. Design flexible services where possible 

Overly standardized services designed to meet the needs of the “average consumer” can be detrimental and even cause harm where consumers in vulnerable situations are negatively impacted. Services need to be designed with sufficient flexibility to support changes in consumer circumstances and staff should be empowered to provide tailored solutions to consumers.

4. Embed inclusive design into the organization’s culture 

Inclusive service design requires more than just developing and publishing a policy document. ISO 22458 defines nine principles that should be embedded into the culture of an organization. Top-level management will need to demonstrate their commitment and the principles should encourage all staff to look out for vulnerable consumers and help them to overcome any challenges they might face when interacting with the organization.

5. Ensure ongoing review and improvement 

Organizations need to continuously review and evaluate their approach to inclusive service. The pandemic has shown that situations and personal circumstances can change in an instant. Staff need to know how to best serve those consumers in vulnerable situations. Guidance for staff will need to be regularly updated and services will also often need to be promptly assessed and adapted. 

With ISO 22458 now published, what impact do you think this will have? Which sectors or organizations will use this standard and why?
Around the world, there has been increasing organizational awareness of consumer vulnerability, the risk factors involved and the benefits of adopting an inclusive service approach. Consumer vulnerability is a global issue. Governments and regulators are increasingly recognizing the need to promote accessible, inclusive services to prevent or minimize the potential of organizational behaviour harming those most vulnerable.

ISO 22458 provides the tools for organizations to behave fairly and ethically while also complying with laws and regulations. The standard specifies requirements and guidelines for organizations on how to design and deliver fair, flexible and inclusive services that will increase positive outcomes for consumers in vulnerable situations and minimize the risk of consumer harm. It is applicable to any organization that provides services, including service-related products, to consumers, regardless of location or size. 

The standard will be particularly beneficial to those organizations providing essential services or operating in markets where significant harm and detriment can be experienced by consumers, such as utilities, financial services, transport but also government and public services. That said, any services organization can benefit from designing and implementing inclusive service, and I expect that the standard will be increasingly adopted not only by those organizations operating in regulated markets, but also those seeking to gain competitive advantage. Most of us find ourselves in a vulnerable situation at some time in our lives. 

What, if any, is the cost of failing to address vulnerable consumers? A concrete example would help. 
There are obvious moral and potential legal costs for failing to address the needs of vulnerable consumers. Organizations may find themselves acting outside of the law or regulatory rules, and therefore subject to legal proceedings and fines. There are also reputational costs, such as negative publicity and potential loss of business. Consumers may choose to take their custom elsewhere if an organization is perceived to cause harm to those who are most vulnerable in society. 

However, the benefits for organizations implementing inclusive services should outweigh the costs. This is because inclusive service design will widen the customer base for any product or service and reduce detriment to consumers. This also reduces organizational costs since avoidable errors, when left unrecognized, are far more expensive to resolve later on in a process. 

An Australian study commissioned by the Centre for Inclusive Design found that “inclusively designed products and services that have end users in mind can reach and benefit up to four times the size of the intended audience and enable organizations to increase their revenue by growing the size of their target markets”. As another example, here in the UK, an insurance firm worked with a charity to develop a product specifically designed for disabled people. Cover for home adaptations and specialist equipment were included as standard, resulting in the company growing its customer base. 



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