Vulnerable Customers Policy
We are committed to ensuring all our customers are treated fairly and we meet their specific needs to the best of our ability. The goal of Edinburgh Bicycle Coop has always been inclusivity, ensuring all our customers are not disadvantaged in any way.
Who are considered vulnerable customers?
The Financial Conduct Authority (FCA) defines a vulnerable customer as “someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care.”
Our promise is to treat all our customers fairly and when dealing with people with any vulnerability, we will take account of such vulnerability to ensure that the way that we sell and provide our services does not cause them harm.
Examples of vulnerable customers
- Vulnerability can take many different forms and is not always obvious. While not all customers in these groups may be vulnerable, we will consider a customer’s individual circumstances where a potential vulnerability is identified. There are many different types of vulnerability – some examples are given below (this is not a definitive list)
- Customer has difficulty in understanding basic numeracy
- Customer is unable to read, or if English is not their first language
- Customer has a mental health issue
- Customer has a physical disability
- Customer mentions having been diagnosed with a serious illness
- Customer repeatedly asks the same questions despite explanations having been given to them
Identifying a vulnerable customer
Most of our communication with customers is face to face and, in some instances, over the phone or on digital platforms. If a member of staff believes that a customer could potentially be vulnerable, then they will ask non-intrusive questions in order to understand the customer’s circumstances. This will allow our staff to identify if the customer is in fact vulnerable and determine how we can tailor our approach for that customer.
Our teams have access to FCA guidance (https://www.fca.org.uk/publication/finalised-guidance/fg21-1.pdf)
Our commitment to engaging with vulnerable customers
We will use the following FCA guidelines to identify vulnerable customers:
- Discuss any concerns about the transaction where the meaning and implication may not be completely clear to a vulnerable customer.
- Listen carefully to the customer, to ensure they fully understand the technicalities of the transaction.
- Direct a vulnerable customer who may be struggling with the detail of the transaction to a source of fair and clear advice.
- Ask if a friend or family member is available to assist if a vulnerable customer is struggling to fully understand technicalities of the transaction.
- Ensure information gathered is with the customer’s explicit consent, and processed in line with GDPR and the Data Protection Act 2018
What we will do:
- Stop or pause the sales process if we believe the customer is not fully aware of what they are entering in to.
- Stop or pause a credit application if we believe the customer is not fully aware of what they are entering in to.
- Provide the customer with direction toward clear, fair and relevant information that allows an informed decision regardless of circumstance.
- We will not refuse to deal with a customer due to their vulnerability.
- We will not rush or hurry a vulnerable customer and allow time to get all the relevant information together.
V12 (our partner finance provider) have a dedicated Specialist Support Team that can help. You can contact them on 0333 122 1112 or by email on firstname.lastname@example.org.
If you believe you meet the criteria of a vulnerable customer, please let us know as soon as possible of any needs you may have, or any ways in which we can help.
Edinburgh Bicycle Cooperative