Vulnerable Customer Policy 

**Purpose**

The Purpose of this policy and procedure document is to identify and support vulnerable customers and to promote transparency and openness in all the business practices and processes that we and our staff create and engage in. It also defines the steps to be taken by all staff when dealing with a Vulnerable Customer Situation.We and our staff are committed to ensuring that all customers are treated in a fair and consistent manner, but also understand that some circumstances require additional interactions and/or steps to ensure that the customer is getting a product/service that is suitable and ethical.Our staff are provided with training on what makes a customer vulnerable and how to identify, assess and deal with any vulnerability. We are committed to ensuring that any customer who has a relationship with Miss Amber.MD is treated in a fair, reasonable and supportive manner.

 

**Scope**

This policy and procedure document relates to all staff (meaning permanent, fixed term, and temporary staff, medical practitioners, any third-party representatives or sub-contractors, agency workers, volunteers, interns and agents engaged with the Company in the UK or overseas) within the organisation and has been created to ensure that staff deal with the area that this policy relates to in accordance with legal, regulatory, contractual and business expectations and requirements.

 

**Definition**

The 2 main definitions of a vulnerable customer as used by Miss Amber.MD Customers who are unable, for whatever reason, to make an informed decision at the time of dealing with them - customers falling into this category include those with language barriers, learning difficulties, those with mental health issues suffering from bereavement, learning difficulties or the elderly. These customers may struggle to make a decision on whether the service or product we are providing is in their best interests.b. Customers whose welfare (financial, mental or physical) could be put at risk through choosing the service or product we offer - these customers include anyone who is going to be put at detriment from taking up our offer. This could be financially if taking out a loan or setting up a payment plan causes them added financial stress.The FCA defines a Vulnerable Customer as:"Someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care."

 

**Objectives**

We are committed to providing the highest level of due diligence and ethical treatment with regards to any customer or potential customer who is identified as being vulnerable or being at risk from a vulnerable situation. To this end, we have developed the below objectives which are used to create our internal procedures for dealing with vulnerable customers. We aim to:- Ensure that we have the suitable, relevant and compliant tools, controls and measures in place to identify, handle and monitor vulnerable customers- Train staff in the identification, communication and understanding of what vulnerabilities are and how to approach them- Have robust vulnerable customer procedures in place at all times and ensure their continued relevance and compliance with the regulations and guidelines- Research and take expert advice on specific vulnerabilities such as Mental Health and Debt so that our staff and procedures are adequately aligned with the standards- Ensure that all materials, content and information is user-friendly, easy to understand and jargon-free- Ensure that all systems and automated processes are regularly audited for compliance- Ensure staff, product and information flexibility to provide a complete and ethical service to all customers, regardless of their situation- Ensure a consistent and structured approach across the organisation and our staff- Implement strict and robust policies and procedures for affordability assessments and data protection- Have specialist teams and/or staff in place to deal with specific vulnerabilities and provide them with additional support, training and evaluations

 

**Debt And Mental Capacity**

Mental health is one of the most common issues that can result in a customer being vulnerable. We provide thorough staff training and support to identify and deal with customers who have declared or meet the criteria for having mental health problems.We follow the Code of Practice relating to the collection of medical evidence about mental health conditions and always aim to:- Take steps to establish whether the mental health problem affects the customers' ability to manage money or their debt- Work with the customer in a patient, clear and helpful manner to resolve the debt problems and use workable solutions- Provide reasonable periods of time for the customer to provide evidence of any mental health condition and place accounts on hold during this period- Prevent any interest and/or charges from being added to the account during the consultation period- Work with authorised 3rd parties to help the customer resolve their debt issuesWhere we have identified that a customer is considered vulnerable, we always encourage them to disclose any potential mental capacity limitation and actively look out for indicators of a potential mental health capacity limitation.Any information collected regarding a mental health problem is kept secure and encrypted always and is only retained for as long as necessary under the DPA regulations.

 

**Procedures**

We understand that the term 'Vulnerable Customer' applies to numerous and varied situations and circumstances, therefore we have outlined the procedures in this document for each Vulnerable Customer type as identified in our Vulnerable Customer Policy.Where a customer has been identified and/or declared as being vulnerable, Miss Amber.MD Aesthetics Institute always ensures that the below steps/processes are followed in every instance:- Ensure that all staff are provided with the training and tools to identify, understand and deal with vulnerabilities and vulnerable customers- Email/telephone sales information and/or advice is followed up in writing containing the discussed content and any relevant terms & conditions and disclosure information- Ensure that ways to contact us are clearly visible on all communications and our website and provide a choice of ways to communicate with us, including: - Post - Email - Face to Face - Telephone - Online Chat- Ensure that all written materials are clear, to the point and jargon-free- Ensure that where applicable, the products/services that we offer are flexible and made to suit the customers' needs and requirements- Offer flexible outcomes on products/services as dictated by the customers' situation and circumstances- Deal with any authorised 3rd party in a helpful and transparent manner- Ensure that any sensitive and/or confidential information disclosed to us regarding the customers' vulnerability is safe and secure and stored and destroyed in accordance with The Data Protection Act 1998- Ability to flag accounts where a vulnerable customer has been identified so that other staff can see at a glance how the account is to be handled in the future

 

**Audits And Monitoring**

We carry out regular internal audits and gap analysis monitoring in all business practices and procedures to ensure that our Vulnerable Customers ethos and objectives are being met.Regular reviews of the audit results are held with senior management and an ongoing record of gaps, actions and improvements is maintained. Vulnerable Customer compliance as well as providing gap analysis reporting used for M1 and regulator evidence.

 

**Training & Staff Support**

We are committed to ongoing professional development and 1:1 training sessions and workshops around the ideas and ethos of Vulnerable Customers and to ensure feedback is given at all times.