Vulnerable Customer Policy

November 2024

 

Introduction

Revolution Money are committed to ensuring that all employees can understand the signs that a client may be vulnerable, and how best to handle such situations with care and respect.

Remember all our clients are important to us, and those suffering any incapacity or vulnerability must be particularly looked after and treated with the care and respect they deserve.

 

All employees, regardless of grade or level who have any client contact must read this policy regularly to ensure they understand it fully.

All employees will have telephone conversations with people who find it difficult to make an informed decision about the choices offered to them. Examples of such issues include

• Those who have a diagnosed condition like dementia
• Those who have an undiagnosed or a temporary mental health condition such as severe anxiety
• Those who have recently suffered bereavement
• Those with learning difficulties or literacy issues
• The elderly
• Those who have problems understanding the language.

There may be individuals that do not realise they are vulnerable or those that should not be making significant life decisions due to their vulnerability.

Contacting our clients by phone to seek instructions, updating them on the progress of a case, or simply to keep the client informed and aware of how we are dealing with the everyday situations arising on their case, is important for both parties. It is therefore important that vulnerable clients can fully understand the conversations we have with them.

At Revolution Money we must understand that all our clients could be automatically vulnerable by way of their level of indebtedness however, it is imperative that we strictly follow this code to ensure absolute fairness and equality of service to all our clients who have added risk factors. These guidelines have been provided as a practical framework to help everyone in our organisation to communicate with our vulnerable clients with the utmost care and respect.

Identifying vulnerable clients

To address the needs of vulnerable clients correctly it is important to be able to identify them.

Look out for risk factors:

• Bereavement
• Illiteracy
• Illness
• Age
• Disability
• Mental health issues
• Language barrier
• Other impairment

 

In many cases more than one risk factor is present which increases the client’s vulnerability.

Revolution Money employees must be alert to the signs that the person they are talking to may not have the capacity, at that moment in time, to make an informed decision about the implications of the arrangements that they are being asked to make, or advice they are being provided with. This is not a diagnosis of a condition. It is just an extension of our employees’ existing skill of listening, identifying needs, and adjusting their approach accordingly.

The Mental Capacity Act says that a person is unable to make a specific decision if they cannot understand information about the decision to be made, cannot retain that information in their mind, cannot use or weigh that information as part of the decision-making process, or cannot communicate their decision.

Employees should be alert for signs such as

• They ask you to speak up or to speak more slowly.
• Can they hear the complete conversation or are they missing important bits?
• Do they understand what you are saying?
• They appear to be confused.
• Do they know what is being discussed?
• Do they ask unrelated questions?
• Do they keep wandering off the point in the discussion and talking about irrelevancies or things that don’t make sense?
• Do they keep repeating themselves?
• Do they say “Yes” in answer to a question when it is clear they haven’t listened or understood?
• They take a long time to get to the phone and sound flustered or out of breath, indicating they may have a lack of mobility due to age or illness.
• They take a long time to answer questions.
• Where there is a language barrier, they may not fully understand what is being said to them.
• They say that they don’t understand figures put to them, a previous phone conversation or recent correspondence.
• The client’s age.

Practical tips provided to our employees when talking to vulnerable clients

You must speak clearly and enunciate

• Set expectations for the call.  Outline all the information that will be required such as account numbers, personal details, and how long the call is likely to last.
• Be patient and empathise with the client.
• Don’t rush them. If they need to put the phone down to find account details it could take them some time.
• Guide the call to keep it “on topic”.
• Don’t assume that you know what the client needs.  It is too easy to rush through if the client is reacting slowly or not able to explain what they need.
• Clarify understanding at every point posing the question “is there anything you’d like me to explain in more detail?”
• During the initial advice stage, the use of the TEXAS & IDEA model.
• Ask the client to explain to you what they understand about important parts of the call.
• Offer alternatives to dealing with things by phone where appropriate.  Perhaps they would prefer to transact the business by post or email.
• Don’t assume that the person you are talking to is fully sighted.  They may be unable to read serial numbers or statement details.
• Don’t assume that the person you are talking to can hear everything you are saying.  They may have a hearing impairment.
• Remember that a vulnerable client can sometimes be forgetful or overly trusting.
• Give the client time to explain fully.  Do not interrupt or show impatience.
• Listen for what is not being said, not just what is.  For example, an absence of understanding, commitment, timing type questions on the part of the person receiving the call should ring alarm bells.
• Ask if there is a better time to call.  Some people will function better in the afternoon than in the morning.
• Ask whether there is anyone else they need to talk to before making the decision.
• If in doubt on how to deal with a situation that is presented during a call, seek advice from your line manager before proceeding.

What our employees do when a vulnerable client is identified?

When a vulnerable client has been identified, or the employee reasonably believes that they are dealing with a vulnerable client, they should immediately update Hubsolv.

The employee must discuss and gain authority regarding making any reference to the clients’ specific vulnerability within the client case notes before doing so.

The Compliance Department will consider the client’s vulnerability issues and assess the employee’s attitude and approach. This applies across all areas of the business. More intervention may be required from the Insolvency Practitioner on these cases to ensure they agree with the action being taken considering the client’s specific vulnerability.

The Data Protection Act 2018 requires that any information stored must be recorded with the full knowledge and consent of the client and must be kept accurate and up to date. If the communication needs of an individual are due to a disability, care must be taken about the recording of any medical data, as it is classed as sensitive and personal, and must be checked for accuracy. It should be relevant but not excessive. The data will be deleted when the statutory timescales are met after the relationship no longer exists between Revolution Money and the client.

A client’s circumstances can change.  The case may not have been noted as vulnerable previously, but this does not mean that the client will not be vulnerable in the future.

If a client does not want to be called again as a direct result of their incapacity or health issues, then the matter is referred to the Team Manager to respond with suggestions of alternative means of communication, to the client’s satisfaction.

When a problem occurs because of the client’s incapacity, and perhaps lack of understanding, the Team Manager will have systems in place to track back and listen to calls to find out where the misunderstanding took place and identify what procedural changes or additional training is required to prevent it happening again.

In some cases, vulnerable clients will not have the capacity to make the decisions that are required to deal with their case. The employee should try to identify a carer or someone who is authorised to act on behalf of that client with respect to financial affairs.  It is vital that we have authority from the client to communicate with any third party. The employee could also ask if there is a valid Power of Attorney in place. Evidence must be provided of Power of Attorney, along with appropriate identification, before any further private or confidential information is passed to that person.

Ensure that Attorneys or authorised persons know exactly what is expected of them.

Should you feel the client is unable to continue with our services then the client is to be referred to a more suitable organisation such as Citizens Advice where they can receive face to face advice. In this instance you should explain clearly the referral and the reasons why.

What to do when the client alleges their incapacity is life threatening such as suicidal thoughts

It is possible that clients might say that they intend to harm or kill themselves. This can be distressing for those concerned but there are some important points you should know that will help you if a client threatens this. Being prepared and having well managed processes in place helps us to reduce distress and achieve an outcome where everyone is safe. You should be alert to clients who may declare or whose behaviour indicates an intention to attempt suicide or self-harm.

Whilst some clients may say they intend to kill or harm themselves as a threat or tactic, others mean it. Our procedures and actions must assume that it is a real possibility that the client will carry out their threat.

You are not a counsellor, but it is important that systems, processes, and responses are in place, and you know what to do if a client says they intend to harm themselves. This will enable you to deal with the client and for you to receive the correct support from the firm. You may hear things from clients that are potentially upsetting but you are not responsible for sorting out a client’s life.  However, by talking to them calmly you can help identify their needs and encourage them to seek appropriate support. If you are prepared and know how to make an appropriate response to the client, it is likely that you will not only handle the call better but any shock or upset you may feel will be reduced.

The guidance and six-point plan does not fully identify every way in which a client may say they will kill or hurt themselves or specify the action to take in every situation.  However, the principles of the plan will help you to deal with these situations if they arise.

Please remember that everyone is expected to

• Read and understand the six-point plan and discuss any concerns with their manager
• Refresh their knowledge of the plan at least annually and following any incident
• Be able to access the six-point plan quickly if needed
• Record any incident as soon as possible
• Review the incident with their manager

The six-point plan

Please make sure you follow the six-point plan when dealing with clients who threaten suicide or self-harm.

1. Take the statement seriously and manage the conversation with the client
2. Summon a colleague to act as your support partner
3. Gather information to gauge the level of risk
4. Summon emergency help
5. Provide referral advice
6. Review and seek support

 

Point 1. Take the statement seriously and manage the conversation with the client

 

If you are talking to a client on the telephone and they threaten suicide or self-harm, there are some points to consider helping you to talk to the client in a natural way

• Stop what you are doing and give the client your full attention. You need to handle the call and should not hand it off to a colleague.
• Give the client the opportunity to talk.  If they have this opportunity, they may feel better at the end of the conversation
• Remain calm and listen carefully
• Do not be judgemental.  What may seem insignificant to one person may seem enormous to others
• Try to be yourself.  If you remain calm and at ease it may help the client gain perspective
• Express concern for the client but remember, you are not a counsellor
• Ask the client about their plans you are gathering important information (see step 3)
• Reassure the client that help is available
• Do not attempt to resolve the client’s personal crisis
• Don’t tell the client you know how they feel
• Don’t dismiss the client’s problems or feelings
• Don’t be sworn to secrecy

 

Point 2. Summon a colleague to act as a support partner

• Do not put the client on hold but do summon help by alerting your manager if available or another colleague.
• Role of the support partner
• Handling threats of suicide or self-harm from clients can be distressing and challenging for the person taking the call. A support partner must be summoned to assist you. The support partner will be aware of the six-point plan and will assist by
• Unobtrusively monitoring the situation for the well-being of their colleague and the client
• Take notes of the conversation
• Helping to assess the degree of risk to the client
• Organising action to taken such as finding contact numbers for local support services or speaking with the manager then calling emergency services

 

The support partner must be able to hear or listen into the conversation as best they can. It is likely that the support partner will be the manager of the person taking the call as they will be in the best position to assist. Whoever the support partner is they will be aware of action to be taken in such incidents, aware of procedures and available to help

 

Point 3. Gather information to gauge level of risk

• Talk to the client to gather information. You may not feel comfortable doing this, however any details we can gather will help the client as we can pass these details onto the relevant authorities if needed.
• It is important that you listen. Don’t be afraid to talk to clients about their plans. Encourage the client to talk to you. This could include asking questions such as:
• Have they attempted this before? Have they received treatment, and have they spoken to anyone else about how they feel?
• Do they have specific plans? What are they and when do they intend to do it?
• Do they have the means to carry out their plans?
• Have they already acted? If so, what, and when?
• Where is the client? Do they intend to go elsewhere?
• Are there any children involved or left at home?
• It is important however not to put too much emphasis on it. Try to focus on the here and now in the discussion.
• Remember not to be sworn to secrecy. If a client says they will tell you something only if you will not tell anyone else, you can say that you cannot make that promise.
• Do not give advice or try and solve their problem for them
• Avoid making the client feel that they must justify their feelings.
• Reassure the client that there is help available to manage the way they are feeling.
• Remember to record key information such as location and plans.

 

Point 4. Summon emergency help

• If the client is distressed and at serious risk, is in immediate danger, or has already harmed themselves, you may decide that you should contact the emergency services.
• You or the support partner may wish to discuss contacting emergency services with your manager but if the situation is urgent or if the client has already acted do not delay in making the call. Managers must ensure that colleagues who are dealing with the situation have permission to act as they think best. In some circumstances this may mean calling the emergency service immediately the client indicates they intend to attempt suicide or self-harm even if your manager is unavailable.
• Make sure you know your local procedures for contacting the emergency services for example you may have to dial 9 for an outside line before dialling 999.
• The firm will support decisions that you make whilst dealing with incidents that arise. You will later review the incident with your manager which will include identifying lessons for the future. Your decisions will be respected.  However, during the review it is possible that you or your manager may offer suggestions to be considered if a similar scenario occurs.
• You may need to call the emergency services on behalf of a client who lives in another area. You should tell the emergency services operator that you are calling from a national centre and let them know the client’s location and other relevant details of the threat.
• You do not need the client’s consent to call the emergency services, but it is important to let the client know what is happening and why, when this is possible, if you feel it will not make the situation worse.

 

Point 5. Provide referral advice

• If the situation is non-urgent, for example the client is in distress but has no immediate plans to self-harm, encourage the client to seek help.
• You may offer client contact details for one of more of the following support organisations:
• Seek help from their GP
• Samaritans (a confidential emotional support service available 24 hours a day) 08457 909090
• MIND (Mental Health charity providing confidential mental health information services in GB only) 0300 123393
• Get connected (for under 25s) 0808 8084884
• Campaign Against Living Miserably (CALMs) (for men in crisis) 0800 585858
• Breathing Space (a free confidential phone and web-based service for people in Scotland experiencing low mood, depression or anxiety) 0800 838587
• Bereavement Trust (helps people overcome grief and sorrow that can follow bereavement) 0800 435455
• Cruse Bereavement Care (offers free confidential advice to bereaved people) 0844 4779400

 

Point 6. Review and seek support

Review

• Record details of the incident as soon as possible so it is fresh in your memory.
• It is important to record as much information as you can detailing what the client said, their behaviour and any decision you made and action you took. Useful things to include are:
• Time and duration of your contact with the client
• The client’s behaviour, for example fast or slow talking, not replying, talking incoherently
• Key information you provided to the client
• Any actions the client said they would take such as contacting their GP, visiting a friend.
• These records will be maintained for six years after our relationship with the client has ended as they may be needed in future for legal and system review purposes.
• Discuss the incident with your manager. It is good practice to review the incident and record the review discussion as soon as possible.
• This is an opportunity for you to reflect on the incident, to discuss your feelings about it and agree any support to help you deal with your reactions to the experience.
• The discussion will include:
• How you handled the incident
• Whether the procedures in place for handling these situations worked effectively
• If there any lessons to be learned for future handling and responses
• Any support for you that has been agreed.

Support

• This type of experience can be upsetting, and you need to look after yourself and be reassured that you have done what you can to help the client.
• You are not expected to counsel clients and are not responsible for actions the client might take or if they decide not to seek help. Individuals will be affected differently, and you may feel the need to discuss your experience and seek support from your manager and colleagues.

 

Managers must ensure that anyone who has managed an incident in which a client threatens suicide or self-harm has opportunities to discuss the incident and how they are feeling. Managers must support their colleague, this could include giving the colleague time away from their duties, listening to the colleague and ensuring that the colleague is aware of the counselling services available.

 

What to do if the client threatens suicide or self-harm by letter

• Occasionally a client may say they intend to attempt suicide or self-harm in a letter. In such cases it can be difficult to assess the level to risk to the client and decide an appropriate response.
• If you receive a threat of self-harm in a letter, you must consider whether the declaration is specific and urgent. If you consider there is a specific risk that the client may attempt suicide or self-harm you must consider the six-point plan and what is appropriate and reasonable in the circumstances. If you are sufficiently concerned about a client, you may contact the emergency services. You must tell your manager you are considering doing this and record details of the incident and the action you tool.
• You should consider if the client is providing general information such as I have frequent thoughts of self-harm or if the client is stating a specific intention.
• If you consider the client has provided general information and is not specifically declaring an intention to attempt suicide or self-harm you do not need to take any further action. If you are unsure what to do, talk to your manager.
• What to do if a third partly tells us a client intends to attempt suicide or self-harm
• It is possible that a third partly may tell us that a client intends to attempt suicide or self-harm. A third party could mean a client representative, a family friend, organisation, or someone with a connection to the client. This is not an exhaustive list.
• In these circumstances it is reasonable to expect the third party to manage the situation. For example, you may suggest the third party encourages the client to contact their GP. You may provide contact details of organisations which could help (Step 4 of the plan).
• You must inform the third party that you will not be taking any further action and you must record the details of the incident and your discussion with the third party. If you doubt the third party can manage the situation and you believe the client is at serious risk or is in immediate danger you may call the emergency services in line with step 5 of the plan. It is good practice to tell the third party what you are doing. You must record details of the incident, your discussion with the third party and action taken.